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IN THE MATTER OF: TENNESSEE GAS PIPELINE CO vs. MONSANTO COMPANY Cause No. 94-CI90145 Deposition of DAVID WOOD NOVEMBER % 1995 Gore & Perry Reporting Company 100 North Broadway, Suite 1175 Saint Louis, Missouri 63102 (314)241-6750 621-4790 (BOO) 878-6750 Full GLOSSARYincluded with this DepoScript TENNESSEE GAS FiPELINE CO. vs. MONSANTO COMPANY TENNESSEE OAS V MONSANTO .Page 1 Exhibit No. 283 Exhibit No. 284 Deposition of DAVID WOOD NOVEMBER 9, 1995 174 182 COMMONWEALTH OF KENTUCKY ROWAN CIRCUIT COURT CIVIL BRANCH Page 2 TENNESSEE OAS PIPELINE COMPANY, Plaintiff, vs. NO. 94-C190145 MONSANTO COMPANY, Defendant. Deposition of DAVID WOOD, taken oo behalfof the Plaintiff, at the offices of Gore & Perry Reporting.Company, 100 North Broadway, in the City of Si. Loub, State of Missouri, on the 9th day of November 1995 before Ronald A. Gore, Registered Professional Reporter and Notary Public. APPEARANCES OF COUNSEL: FOR THE PLAINITFF: Mr. Kevin B. Duff Hedlund, Hanky & John Sean Tower Suite 5700 Chicago, Illinois 60606 FOR THE DEFENDANT: Mr. Roily L. Chambers Smith, Helms, Mulliss & Moore 227 North Tryon Street Charlotte, North Carolina 28202 __________________________Page .. INDEX PAGE Examination by MR. DUFF EXHIBITS Exhibit No. 273 Exhibit No. 274 Exhibit No. 275 Exhibit No. Z76 Exhibit No. 277 Exhibit No. 278 Exhibit No. 279 Exhibit No. 280 Exhibit No. 281 Exhibit No. 282 Page 5 20 102 115 122 124 132 136 152 161 162 Page 5 m DAVID WOOD, pi of lawful age, having been first duly sworn to pj testify the truth, the whole truth, and nothing but [4] the truth in the case aforesaid, deposes and says in pi reply to oral interrogatories propounded as follows, [i to-wit: Pi EXAMINATION [8] QUESTIONS BY MR. DUFF: 191 MR. DUFF: Kevin Duff, representing Tennessee noj Gas Pipeline Company, ini MR. CHAMBERS: Roily Chambers, representing [iq Monsanto and Mr. Wood. [i3] VIDEOGRAPHER: Sir, can you state your name? [Mi A: I'm David Wood. [is] MR. DUFF: Mr. Wood, would you please state [i6i your full name for the record? [i7] A: David Wood. [is] Q: And where do you reside, Mr. Wood? [19] A: In Chesterfield, Missouri. [20] Q: What is the address of your residence? pi] A: 15414 Country Ridge Drive, Chesterfield, [221 Missouri 63017. P3] Q: What is your social security number? P4|A: 497-70-7571. PS] Q: Mr. Wood, have you had your deposition taken ;Page 6 [i] before? PI A: Yes, I have. Pi Q: How many times? [4j A: Total, five or six. [3] Q: Do you recall die matters in which you gave [4 depositions? P]A: Not precisely. 18] Q: Do you remember any of them? pi A: There was a California case involving no] Transwestem Pipeline. There was a Chicago case [ii] which was involving plasticizers in the food (i2) packaging industry. There was another San Francisco [i3] case involving some fire damage relating from -- tm related to damage from askarel transformers. There [is] were others. I don't recall the others in any pq detail. [i7] Q: I'd like to review some groundrules for you [is] today, for today's deposition. I understand that [19] you have had your deposition taken previously, but poj I'd like to just remind you of a couple pi] groundrules. I'll be asking you a series of pq questions, and I'll ask you that give verbal p3] answers. Our court reporter will not be able to [24] pick up any non-verbal responses, and while we have pq the videotape running today, I'd appreciate it if Page 7 [i] you could give verbal responses, so a gesture or m something along those lines won't be picked up. Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 Page 1-Page 7 HARTOLDMONO010986 Deposition of DAVID WOOD NOVEMBER 9, 1995 (3] A: I understand. mQ: Also, if you would -- if I'm asking a [5] question, I'd appreciate it if you'd allow me to [6] finish asking my question. If you ~ and I'll also [7] try and extend the same courtesy to you and not step p] on your words when you're trying to give me an p] answer. Do you understand that? no] A: Yes, I do. nil Q: And if you have any -- if you don't [12] understand a question, or would like to ask me to [i3] clarify a question, please feel free to do so and I [Mi will attempt to so. [is] A: Thank you. n<5i Q: Also, at times counsel will offer -- will [i7] wish to state an objection and we'll also try and [is] not step on his words as well. Do you. understand [19] that? [20] A: Yes, I do. pi] Q: And if at any time during today you feel [22] that you need to take a break, please feel free to [23] let me know and I'll try and accommodate you. [24] A: Thank you. ........... ps] Q: Do you have any questions at the outset [i]the deposition about the groundrules that will be p] governing us today? pi A: No. ' [4] Q: Would you please state your educational [5] background, beginning with when you completed -- ra when you matriculated from high school? m A: When I matriculated from high school, I [8] attended university at Cambridge University in pi England, where I completed an honors degree in [icq chemistry and part two of the law degree at [ii] Cambridge, graduating with a degree under English [12] designation as a BA in chemistry and law. : [i3] Q: What type -- [i4i A: Let me correct that. They classify it as a [i5] BA in natural sciences and law. no Q: You said that you were an honors student in [iti chemistry, is that correct? [is] A: Yes. [is] Q: What chemistry courses did you take when you poi were at the university at Cambridge? [2i] A: Organic chemistry, inorganic chemistry, [221 physical chemistry, analytical chemistry. The other [23] science courses were not so much strictly chemical [24] courses, they were physics, quantum mechanics, [251 mathematics, geology, minerology. ________________________ Page m Q: And did the various chemistry courses that h you just listed include laboratory time? [3]A: Yes. w Q: What sort of laboratory experience did you [5] have in chemistry? [<i A: Very basic physical chemistry, some basic pi analytical chemistry, some inorganic 9 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY synthesis and [8] inorganic product designation type of work. Some [9] organic synthesis. This was an undergraduate [101 chemistry degree even at the honors level, so, I [in mean, that was the basic type of laboratory work [12] supporting the theoretical courses that I was [13] taking. [i4] Q: When you graduated from the university, what nsi did you do next? [i6] A: I joined Monsanto Chemicals in their [17] European organization headquartered in London. [is] Q: And how is it that you chose to begin [19] working for Monsanto Chemicals? [20] A: I wanted to work within the chemical pi] industry, and I interviewed with a number of P2i British, European and American chemical companies. [23] I was offered positions by several of them. [241 Monsanto at that particular point was growing its ps] European business, and offered me a position that Page 10 [i] would involve me in that European growth, and I [2] chose to join them, pi Q: What was the size of Monsanto Chemicals in m London at the time that you began working there? [5] MR. CHAMBERS: I object to the form. When [6| you say size, you mean number of employees, pi physical -- is] MR. DUFF: Let me clarify. How many [9] employees worked in Monsanto Chemicals when you po] began working there? pi] A: I don't know. [121Q: Was it more or less than a hundred? [13] A: It was more than a hundred. It was [141 probably, totally in Europe at that time, less than [15] a thousand. [i6] Q: And just so we're clear, what year did you p7] graduate from the university? ps] A: 1960. [19] Q: Did you begin working for Monsanto in the pal same year? pu A: I began working as an entrant late in 1960, [22] took my first formal position as a technical sales [23] assistant in the spring of 1961. [241Q: As an entrant in late 1960, were you based ps] in London? ;Page 11 [i] A: Yes. pi Q: And did you receive training during that pi time period that you were an entrant? [4] A: Essentially, that was a period of [5] orientation when they were telling me something [6] about what Monsanto was, what Monsanto did, what p] type of functions made Monsanto work in Europe, how p] they saw Europe developing, introducing me to my [9] peers and my superiors at that time. Say, po] generally, giving me an orientation to what my role pi] might become within Monsanto, pa Q: Was it limited to what your role was to be [i3] as a sales person or did it go beyond that? [14] A: At that point it was focused very much on P5] how they saw the sales role developing. Page 7-Page 11 Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONO010987 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [i6i Q: Did you receive orientation regarding the [i7i products that Monsanto sold at that time? [i8i A: In a very general fashion. Obviously, when [19] I was assigned a product as I became an assistant [201 technical salesman, then I was given much more pn specific training related to the product area that I (221 was to handle, mi Q: Were you given training in -- with respect [241 to functional fluids at that time? 125] A: We're talking at the time that I was an Page 12 in entrant? 12]Q: Yes. pi A: Very little. [4j Q: What type of products did you receive [5] orientation regarding? [6] A: Monsanto was in the plastics business at [7] that time, we were in the fibers businesses, we were [g] involved in certain of the stearinic derivatives, pi We were involved in' fine chemicals and generic (101 pharmaceuticals like aspirin. And there were a [ii] range of specialty type chemicals such as the (12) Skydraul aviation fluids, the Aroclor fluids, the [i3] ethyl silicate binder fluids. Monsanto at that (i4) stage, I say, was beginning to introduce into Europe im some specific products which it had generated [16] markets for in the United States and was planning to ti7j try to evolve those markets in Europe, and so they tisi gave me a very broad general description of products [i9] within which Monsanto was active. [2Di Q: Did you receive orientation with respect to pi] Pydraul fluids? [221 A: No. [23] Q: Do you know if Monsanto sold Pydraul fluids [24] in Europe at that time? 125) A: At that time, I don't really recall. Page 13 (U Q: Your sales training period lasted pi approximately how long? ;_ pi A: We haven't -- can I try to ask you to [4] clarify the distinction you're making between my (5) entry level orientation and sales training? I think (6i I referenced that when I became assigned as an pi assistant technical salesman, I then received more [8] specific sales training. (9|Q: I understand. I'm talking about the period [ioi where you classified yourself as an entrant. How [in long was that period? [121 A: Well, I joined them, I think it was [131 September or October of 1960, and I was assigned to [i4] a product and a territory in the spring of 1961, so [i5i at that stage I became more focused. I was still [i6i receiving ongoing sales training. [17] Q: When you became a technical sales assistant, (is] what sort of training did you receive? (i9i A: Product training for the products that I was pm assigned to sell. And some selling training related pu to how you approached potential customers and how [221 you managed the job of selling in a territory. Deposition of DAVID WOOD NOVEMBER 9, 1995 [23i Q: What products did you receive product [24i training for? [25i A: At that particular point in time, in the Page 14 [lispring of 1961,1 was assigned to sell ethyl pi silicate products, organic silicates, and I received pi product training in those products. [4] Q: What application are ethyl silicates used [5] in? [6] A: The major application, by far, is the lost Pi wax casting process, which is a technology and pi process for producing very precise shaped castings pi in high alloy steels for subjects such as the blades [ioi in turbine engines. (uiQ: And as a technical sales assistant, did you [i?i then move into other product areas after the -- [i3i after the time that you were selling ethyl [i4i silicates? [is] A: Later, yes. [!6i Q: What products did you begin selling and [i7] when? [is] A: Sometime between 1961 and 1965 my product [i9] line was extended to include dielectric fluids. [20] Q: What are dielectric fluids? pu A: Dielectric fluids are liquid insulants which pzi have a capability of enhancing the performance of [23] specific commercial electrical equipment such as p4] capacitors and transformers. Monsanto sold a (25] capacitor dielectric called Aroclor, A-r-o-c-l-o-r, Page 15 in and it delivered to the marketplace a transformer pi coolant dielectric which in Europe we called pi Pyroclor, P-y-r-o-c-l-o-r. (4) Q: What were the ingredients in Aroclor at that [5] time? [6i A: Aroclor was sold in a number of product pi forms, mainly distinguished by the difference in the [gj viscosity of the various fluids and their dielectric [9] constants. But they were -- the Aroclor fluids [ioi were essentially based on biphenyl, chlorinated to (in various levels. [121Q: And did Pyroclor also contain chlorinated (i3i biphenyls? [i4] A: It did. But the transformer fluid was a [ii] blend of chlorinated biphenyl with other components. [i6] Q: Was Aroclor pure chlorinated biphenyl? [i7i A: I'm going to have to ask you to clarify that [i8i question in terms of how do you use the word pure in [i9] this context? [20] Q: Was there anything else in Aroclor other pu than chlorinated biphenyls? (22) A: No. It was a mixture of isomers of p3] biphenyl, chlorinated to different chlorination P4] degrees. [25] Q: So the difference between different types of Page 16 (U Aroclor depended on the type of mixture of isomers, pi is that correct? pi A: Yes. Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 11 - Page 16 HARTOLDMONO010988 Deposition of DAVID WOOD NOVEMBER 9, 1995 [4] Q: And the level of or degree of chlorination, pi is that right? (<|A: Yes. in Q: And as a result, also, the differences in ll viscosity were apparent, is that right? pi A: They were an outcome of the degree of [io] chlorination. [ill Q: A characteristic -- they had different [izi characteristics, depending on the level of [i3] chlorination, is that right? [14] A: Yes, that's correct. [15] Q: Pyroclor was a blend that included PCBs, is [iq that right? [i7i A: Pyroclor was a blend which contained Aroclor [iq -- I mean, at that time the term PCB that you just [i9] used was not really a current -- in current usage. poj The designation of Aroclor as being a PCB came later pi] in time. We always defined Pyroclor as a blend of [22] Aroclor with other components. ` (23[ Q: Monsanto at that time referred to its [24] polychlorinated fluids and other products as [25] Aroclors, is that right? Page 17............................................................... in A: Or Pyroclor. If we were talking about [2] something that was a chlorinated biphenyl, then we pi used the term Aroclor at Monsanto. In that we sold [4] Pyroclor, which was a blend of Aroclor with other [5] constituents, I mean, if somebody said what is [q Pyroclor, we would say it is a blend of Aroclor with pi trichlorobenzene, tritetrachlorobenzene and other pi additives. Pi Q: Do you recall what the other additives were [icq that went into Pyroclor? [U] A: Yes. They were additives which were [12] referred to as scavengers. And they were tin [13] compounds or a resin designated as PPO. They were [i4] added in very small percentages with the role of [iq collecting and holding any small amounts of hydrogen [iq chloride which.. were generated within the Pyroclor. [i7] Q: When you say a small percentage, do you mean [is] less than one percent? [i9] A: In the case of the tin compound, I seem to [20] recall that it was about that one percent type of pu level. I think the level for the PPO was -- if [22] that was used instead of the tin compound, that that [231 was somewhat lower. P4] Q: Were the different types of Pyroclor defined ps] by whether or not they had the scavenger as opposed Page 18 Hi to the tin compound as opposed to the PPO? pi A: For the main part, in Europe, we sold Pi straight forward Pyroclor without any w recategorization or amplification, and that was the [5] product that contained the tin compound. If we were [q supplying material to a Westinghouse subsidiary in pi Europe, and the PPO scavenger was a Westinghouse [q development, then we would refer to that as Pyroclor pi PPO. But the product which was the general [icq transformer coolant was just TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY designated as Pyroclor. [in Q: Other than Aroclor and Pyroclor, were there [12] any other dielectric fluids that you sold at that [i3] time? And I'm talking in the period in the early [i4i '60s. [15] A: There was some highly specialized aviation [iq related dielectric coolants which were silicate [17] related, but they were very different nature of [is] business and very different function. [19] Q: Did they contain any chlorinated biphenyls? [20] A: No. pi] Q: Is that because they were silicate related? [22] A: Yes. They were different chemistry. [23] Q: Who were your customers when you sold [24] dielectric fluids from the time you began working ps] for Monsanto through 1965? Page 19 [i] A: In England there were essentially a small pi number of major capacitor manufacturers such as pi BICC, that's B boy, I indian, C Charlie, C Charlie, m British Industrial Calendar Cables. They were the [5] largest capacitor manufacturer in England, and were [6] our largest customer in Great Britain for Aroclor. pi There were a number of smaller companies involved [q with making large power capacitors. There were a pi number of companies that were specializing in small [101 fluorescent lighting capacitors. In transformers, [ii] there were a number of the large electrical (123 manufacturers such as British GE, GE Company of pq Great Britain, English Electric, Brush Electric, all [i4] of whom manufactured distribution transformers, and [is] they formed the customer base. In Europe, our [iq customers tended to be the major electrical [i7] equipment producers in the various European pq countries. I refer, therefore, to companies like [19] Sieman's in Germany, Asea in Sweden. Asea is pq A-s-e-a. pu Q: What percentage of your -- strike that, pq How long did you stay in the position of an [23] assistant technical salesman? pq A: Somewhere between 1961 and 1965,1 guess we [25] -- somehow we knocked the assistant off and I Page 20 pi gained my first stripe and became a fully fledged m technical salesman. I can't remember exactly what pi date that happened. [4] Q: Would you please mark this as the next [si exhibit in number order, m (Discussion off the record), pi ( Plaintiff's Exhibit 273 p] marked for identification), pj MR. DUFF: Mr. Wood, I'm handing you what's [iqbeen marked as Plaintiff's Exhibit Number 273. And pi] I have a copy for counsel, [iq MR. CHAMBERS: Thank you. [i3] MR. DUFF: Mr. Wood, do you recognize this [14] document? usi A: Yes, I've seen it before. [iq Q: Can you please identify this document Page 16 - Page 20 Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONO010989 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY for [i7i the record? [18] A: This is a curriculum vitae of my life and [19] career with Monsanto up until May 1st of 1982. It [mi doesn't include the later parts of my career with pi] Monsanto. [22] Q: And do the items listed under professional [23] activities accurately state the various positions [24] that you held in Monsanto from the time you began [25] until you -- until in A: No, nbt entirely. Because I note it doesn't pjreflect the move from assistant technical salesman, pi which I assumed that responsibility in May the 1st pjof 1961, but I said gained my first stripe and pi became a technical salesman sometime between 1961 [eg and 1965. C7] Q: And, also, this does not reflect the time pi when you were an entrant at Monsanto, is that [9] also -- [io] A: That's also correct. [illQ: Other than those two discrepancies, -- [12] A: And the fact that I mentioned that it only [13] goes as far as May 1st, 1982. It seems to be [14] accurate. [is] Q: So you were a salesman-- you were either [i<s] an assistant technical salesman or a technical [i7j salesman from May of 1961 to June of 1966, is that [is] correct? [19] A: Yes. [20] Q: And during that time period, what reporting pu responsibilities did you have to anyone at St. p2] Louis? Let me step back a moment. Was Monsanto [23] headquartered in St. Louis? [24] A: At that point Monsanto and the businesses p5] with which I was involved was headquartered in St. __________________________ Page 22 m Louis. pi Q: And during that time period from 1961 to pi 1966 what reporting responsibilities did you have to w anyone in St. Louis? [5] A: In the early part of that period, none. My [6| reporting relationship was to my superiors in the pj European organization headquartered in the same pi office in London in which I was based. pi Q: Who were those individuals that you reported ncq to at that time in London? [in A: When I was first appointed as an assistant [i2] technical salesman, I was reporting to a senior [i3] technical salesman called Dennis Hope, and later (i4j when I assumed additional responsibilities involving [15] dielectric fluids I was reporting to a Dr. John [lq Campbell. But both of these individuals were part [13 of the European staff and based in London. [is] Q: And you mentioned a moment ago that later [13 during that period your reporting responsibilities poi changed, is that right? pi] A: During this particular period through 1966, (2q and even beyond that, I had no direct Deposition of DAVID WOOD NOVEMBER 9, 1995 reporting [23] responsibility to Monsanto in St. Louis. Since we [24] were selling products which were themselves managed psj from St. Louis, there was not a formal reporting Page 23 in relationship, but there would be contacting, talking [3 about the business, escorting American visitors from p] the business groups as they made European trips to [4] update us on product information, to allow them to [5] meet the European customers and to exchange ideas [61 about what was going on in that particular industry n in America and in Europe so that we could optimize pi our market presence in America in expanding our [3 European presence. But to precisely get back to [io] your question, no, I had no direct reporting [ii] relationship to St. Louis. [12] Q: From 1961 to 1966, is that right? [13] A: That's correct, yes. [14] Q: After you reported to Dr. John Campbell, who [is] did you report to next? [il A: When I moved to Belgium in 1966 I was [i7] reporting, still, to Dr. John Campbell, but through [18] Dr. John Campbell to a Mr. Donald Cameron, [i9] C-a-m-e-r-o-n. [2o]Q: What was Mr. Cameron's position at that pi] time? [22] A: He was the manager for functional fluids, I [23] believe we were calling the business at that time. [24] Q: Prior to your move to Belgium, did Mr. [25] Campbell report to anybody in the functional fluids Page 24 [i] business? (3 A: He was reporting to Don Cameron. pjQ: And then after your move, were you -- how [4] did your reporting - [5] A: The reporting relationships didn't change m with the move. Just to make sure that we're on the n same page on this one, Monsanto decided to move its p] European headquarters as Britain was entering the m common market, from London to Brussels so that we [io] had a more central European presence. And so a lot ui] of the staff that had been headquartered in London [13 upped and moved to Brussels. So it didn't really [13] change the role -- reporting roles within the [i4j business, it purely changed the location of where we [is] had our central European office. [il Q: Does this CV accurately reflect that when [13 you moved to Brussels your position also changed in (i8i that you became a sales supervisor at that time? [i9i A: Yes. Because as I left England and moved to [20] Brussels, we needed to appoint somebody who was pi] resident in England to act as the day-to-day contact [23 with our important British list of customers for [23] dielectric fluids, and they needed to be supervised [24] and mentored in that role, and so I took on an psi additional supervisor capacity. I Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 20 - Page 24 HARTOLDMONO010990 Deposition of DAVID WOOD NOVEMBER 9, 1995 moved one stage up Page 25 Ml the totem pole at that point. [2] Q: At sales supervisor did you still report to pi Dr. John Campbell or did you then report to Donald [4] Cameron? ra A: At that stage I believe I was still m reporting to John Campbell. Pi Q: What responsibilities did you take on that [8] you had not had previously when you became sales pi supervisor? [icq A: The major change in role was that I had [i i| subordinates to supervise for the first time. [I2|Q: I'm sony, I didn't hear the last thing you [i3[ said. [mi A: I had subordinates to supervise for the (is] first time in my career. As opposed to being an nq individual salesman, I now had a salesman reporting im to me. . [i8i Q: How many salesmen did you have ' reporting to [i9] you at that time? [20] A: Initially, it was one, the one that we had pi] in England. Later, we added additional sales people [Mi for other countries in Europe. [23] Q: Who was the first individual in England? [24] A: Peter Marsh, M-a-r-s-h. [23] Q: And did Monsanto expand into markets in Page 26 [i] other countries during the period that you were pj sales supervisor? [3] A: Again, I'm going to have to ask you to [4iclarify how you're using the word expand in this [5] context. [6] Q: A moment ago you noted that you initially m had one subordinate that reported to you and then [8] thereafter you had other subordinates from other m countries, I believe, is that correct? [10] A: Let me try to place that into contextV As [11] Monsanto moved from London to Brussels, [i2i simultaneously with that move we were also changing [i3] from our previous ' configuration, which was selling [i4i through agencies in many countries, to gradually [i5] establishing a direct Monsanto presence in some [i6] countries. And that happened not immediately across [i7j Europe, but over time we gradually developed a [is] number of independent Monsanto sales offices as [i9] opposed to working through outside independent [20] agents. And so there was a need as we went through cu that progression, which was establishing a stronger m Monsanto presence in total Europe, of having [23] salesmen who were Monsanto employees who would be [24] carrying out a role of selling themselves in some [23] countries and acting as a liaison with the agencies _Page 27 [i] in other countries until the agencies were pi discontinued and we added additional salesmen. So pi this was a progressive expansion of Monsanto's [4] direct presence in TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Europe. Does that clarify what [5] you were looking for? [6]Q: Yes, I think so. p] A: Good. [8j Q: As a sales supervisor for dielectric fluids p] in 1966, was one of your responsibilities to [io] correspond with agents in other European countries? [u] A: Yes. [i2] Q: And what countries did you have agents in [i3] who you corresponded with in 1966? [i4] A: The list is very long. [i3i Q: Would it be easier to say were there any [16] countries in Europe that you did not -- in which [17] Monsanto did not enjoy a presence? [is] A: No. In fact, that wouldn't be any easier. [19] I mean, we obviously had agencies in the major [20] economic centers in Europe; France, Germany, pi] Benelux, Italy, Spain, Norway, Sweden, Denmark. Our [221 contact with eastern Europe was a direct presence of [23] Monsanto salesmen working with the state purchasing [24j agencies in those countries. Agencies that were of psi a different nature, . they were not our commercial .Page 2ft [i] agents, they were the procurement agents of the [21 state. North Africa was handled through agencies pj based in one country, but who would handle a number m of the North African countries. So here you have an [3] entity that is growing and expanding and the tq structure was changing year by year. So those pj European countries where we had agencies, part of my isi sales supervision role at that point in time was, in pi part, giving them support in their country. [io] Q: In 1966 did -- at the end of 1966 did your [ii] position within Monsanto change? [i2i A: Yes, it did. Because recognizing the nature [m of the support I was giving to not only the internal [i4] sales force, but to the agency structure as that was [13] evolving, we recognized that my role was becoming uq one more of product management than purely sales [17] management, and so the role was changed -- the psj title was changed and the role was modestly changed [i9i to that of product supervisor for dielectric ptn fluids. Whereas I had been sales supervisor, I was pi] assigned to be product supervisor. [22] Q: What additional responsibilities did you (23i have when you became a product supervisor? [24] A: As product supervisor there, the type of [23] responsibilities which became additional were those Page 29 in of saying if we had received notification from the pi United States of a particular application for the pi range of fluids which I was involved, and they had m produced some technical literature around that [3] application, then I would have a responsibility for [q Page 25 - Page 29 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONO010991 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY making sure that that technical literature was Pi modified so that it was usable within our European [q client base. So there was a . literature, there was a pi greater responsibility for coordination of sales [io] forecasts with manufacturing to make sure that we [it] had appropriate production scheduling and inventory [iq of products. So the type of things which become [i3j slightly less focused on the customer and making [i4] sure that the product is being centrally managed in [iq an effective and efficient way, were the changes in [iq emphasis. It wasn't that I hadn't had any [i7] involvement with any of these previously, but they [iq became a more focused accountability. [is] Q: With respect to the responsibilities you [20] undertook regarding technical literature, was it pn your responsibility to ensure that adequate and p2) accurate information about the products you were p3] selling was given to your customers? P4] A: Yes. [25] Q: And at that time was it important that your ,Page 30 [i] customers understand such things as toxicity and in safe handling of products? pi A: Very much. W Q: And why was that important? [5] A: Even at that stage, I think Monsanto was [] being recognized around the world as being a p] corporation that took very seriously its [q responsibilities in terms of the safe handling of [9] chemicals that it was delivering to the user no] market. And, therefore, yes, it was an important [in feature of our selling to a customer that we could [12a tell him about the appropriate^ handling of those [p] fluids within his process. [i4] Q: Was it important at that time for Monsanto cisj to convey to its customers all information relating [iq to toxicity that Monsanto believed to be valid? [12] MR. CHAMBERS: I object to the form. [iq A: If we've got an objection here, I mean -- [iq MR. CHAMBERS: If you're able to respond to pq his question, you may do so. pi] MR. DUFF: You may answer. [22] MR. CHAMBERS: Would you like to have the pq question -- P4] A: I'd like it repeated. [25] MR. DUFF: Would you please read the ;- - Page 31 in question back to the witness, p] (The requested portion of the pi record read by the reporter). [4 A: I'm going to ask you to clarify the form of [5] the question in terms of how you're using "valid" (q and "all". There were two words you used there m which I'm having a little bit of difficulty in [q knowing how to be responsive. [9] Q: One was -- [iq A: You used "all" and you used "valid". Deposition of DAVID WOOD NOVEMBER 9, 1995 [in Q: Let me see if I can rephrase the question [12] for you. Do you agree that at that point in time it [13] was important for Monsanto to convey to its [uj customers information relating to toxicity that [iq Monsanto's medical department had determined was [iq scientifically valid? [iq MR. CHAMBERS: I object to the form, again, [iq But if you're able to answer -- [iq A: I can answer that. It was important that [20] Monsanto convey to its customers information that pi] would enable them to gain the benefits of the pq application of our chemicals in a manner which ~ p3] that they would not incur harm in their use of the [24] product. P5] Q: And by the phrase incur harm, what do you Page 32 [i] mean? pi A: I think I can best answer that by the pi example that in the case of capacitor manufacturing n technology, you would impregnate the capacitor [5] winding in -- with Aroclor at elevated temperatures [q and we didn't want people being exposed to Aroclor m vapors at elevated temperatures, and so we would [q include in our literature and in our discussions [q with their manufacturing supervision at the time we no] made visits to their plants suggestions of how they [in might ventilate their work areas to ensure that [iq there was no contact with the vapors of Aroclor at [131 elevated temperatures. So, that is the nature of [i4] the type of thing where I -- I'm trying to [iq exemplify what I'm saying about not incurring harm. (iq Q: So in your example, are you saying that you [i7] agree that at that time it was important for (iq Monsanto to convey to its customers information [iq relating to inhalation of Aroclor vapor that po) Monsanto's medical department had determined was pu scientifically valid? [22] A: Monsanto had worked with various industrial (23] hygiene institutions and authorities, and there were pq sort of suggested workplace standards for [25] concentrations of vapor that should not be exceeded Page 33 mover an eight hour working day, and, yes, we felt it p] important that people should understand that those pj levels had been set, not with precision, but that w they had been set as seemingly providing safety [q guidelines and good work practice and good (q industrial hygiene, and the people, therefore, could m accomodate their work practices to sustain those (q safe working standards, p] Q: So that's what you meant when you said that [icq you -- that it was important for Monsanto to help units customers use products in a way which would [iq avoid harm? [13] A: Yes, that's correct. [iq Q: You also stated that one of your [iq Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 29 - Page 33 HARTOLDMONO010992 Deposition of DAVTO WOOD NOVEMBER 9, 1995 responsibilities when you became product supervisor pi was to coordinate sales forecasts with [i7] manufacturing, is that right? [isi A: Yes, I did. [i9] Q: Were there any other responsibilities that [20] you undertook when you became product supervisor for pi] dielectric fluids in 1966? [22j A: As I tried to portray earlier, it was really P3] an extension and a slight change of focus rather p4] than it being undertaken abaniscio. But there are [25] many facets, and to try to delineate every one of Page 34 [i] them in what goes into the day to day function of pi sales management and product management, I find it a pi little bit difficult to give you a complete shopping w list of them. Obviously, as I say, managing [5] inventories, managing production schedules, [6] literature support, advertising support, talking to pj agencies about the architectural benefits of the PI customers' applications, preparing case histories, pi There are many features of the...-- job, and I'm not sure no] how helpful this is being to you. [ii] Q: Well, is it fair to say that you were [izi responsible at this time for all facets of [13] dielectric product sales and product supervision [14] that Monsanto was engaged in in Europe at that time? [15] A: Yes. [iq Q: When you became product supervisor, did you [i7i still report to John Campbell? [is] A: I think at that stage -- it was at that [i9] point or very shortly thereafter that I was poi reporting to Don Cameron directly, pi] Q: When exactly did you become product pn supervisor? [23] A: I'd have to go back to my --" [24]Q: If that helps, that's -- feel free to refer [25] to that. Page 35 [i] A: I feel that that was accurately stated here, [Z| so, I mean, it would have to have been late in pi 1966. And this states November, and I have no [4] reason to believe that the personnel record does not [5] accurately reflect that that was the date they put a [] notice on the board. Pi Q: Did you prepare Exhibit 273? Pi A: No. I reviewed it. It was prepared by the [9] personnel group. [ioj Q: At Monsanto? Hi] A: Yes. Or it was a joint effort. I mean, we [i2] went back through the records to get the appropriate p3] dates. There was at no point that I have sat down (i4j and with accuracy have said it was May the 1st that (isj that announcement was made and it was -- so -- (iq Q: Do you have any reason to believe (hat you [i7] did not become product supervisor for dielectric [is] fluids in Europe on November 1, 1966? [i9] A: No, I believe that's when it happened. TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [20] Q: And at this time after you had become _ pi] product supervisor, was one of your responsibilities ps} still corresponding with x Monsanto's agents in other [23] European countries? [24] A: Yes. .. [25] Q: Who was Monsanto's agent at that time in Page 36 [1] Sweden? [2] A: A company called Rising and Strand, pi R-i-s-i-n-g and Strand, S-t-r-a-n-d. w Q: Was there one individual or more than one [5] individual from Rising and Strand with whom you [$i corresponded when you were in the position of pi product supervisor? [8] A: Depending on the particular communication, I [9] could have been writing to one or two people. Most noi of the correspondence involving dielectrics would [uj have been sent to Ola Palm. O-l-a, Palm, P-a-l-m. [12] Q: When you were product supervisor, were you [13] responsible for any Monsanto " .`........... -- products that contained [i4j chlorinated biphenyls other than dielectric fluids? ' [is] A: No. [il Q: Were you responsible for any products ^' other [i7] than dielectric fluids? [is] A: At that point, no. I was the king of [i9] " dielectric fluids at that point. t20] Q: For Monsanto in Europe? I2i] A: For Monsanto in Europe. Let's be quite [22] clear, I mean, I was only a small king of a minor p3] European kingdom. [24] Q: Who was Ola Palm? t25i A: Ola Palm was a long term general sales ;Page 37 [i] representative for the agency that we had in Sweden, pi Rising and Strand. I gave you a spelling. [3] Q: How long had you corresponded with ` Mr. Palm m in 1966? Let me rephrase that. [5] A: Yes. [i Q: When did you -- prior to 1966, had ' you and pi Mr. Palm corresponded before? _ [8] A: Yes. [9| Q: When did you first begin corresponding with [ioj Mr. Palm? [uj A: Sometime in the period between 1963 . and [i2] '65. When I began handling dielectric fluids in p3] England initially, I learned -. something of the [i4] business in the English marketplace, and then ps] sometime in that period between '63 and '65, before pil moved to Belgium, I was handling European p7i - marketplaces for dielectric fluids from England, and psi so sometime in that period I would have begun a p9] communication and a relationship with Ola Palm. But pojl can't " place it with any more accuracy than that. pi] Q: How frequently did you correspond with Mr. [22] Palm during that time period from the time you began p3] corresponding with him Page33-Page37 Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONO010993 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY to 1966? [24] A: Depending on what was going on in the [25] Swedish marketplace with dielectric fluids, I might _Page 38 [i]have occasion to write to him, say, in one quarter [2] three times, and then I might not write to him again pj for three more quarters. So, there was no routine [4] frequency. But there were a small number of [5] significant users of chlorinated biphenyls in the iq Swedish marketplace, which was a very competitive m marketplace between ourselves and the major European pi manufacturers of chlorinated biphenyls. Unlike the pj United States where Monsanto was the -- for many [io] years, the sole producer of chlorinated biphenyls, mi there were a much larger number of producers of [121 chlorinated biphenyls equivalent to Monsanto's in [nj Europe. [14] Q: Is it fair to say that you corresponded with [is] Mr. Palm several times a year? [i6| A: I think that would typify it. Not on a [17] regular basis, but it would be several -- it would [is] probably be more than one and it would probably be pq less than ten. [20] Q: But sometimes it might have been once a [2ij month for a few months in a row? [22] As Yes. [23] Q: And when you corresponded with Mr. Palm, did [24j you write to him or did you speak with him? [25] A: Both. Page 39 in Q: And did you meet with Mr. Palm personally at [21 times? pi A: Yes, I did. [4] Q: How many times a year would you travel to [5] Sweden to meet with Mr. Palm? [i A: I didn't visit Sweden'to visit with Mr. pj Palm. I -- ^ [8] Q: Let me rephrase the question for you. How [9] many times did you meet with Mr. Palm in Sweden? [101 A: At least once a year. If commercial [11] considerations demanded, more than that. [i2] Q: And during this competitive period did you [i3] meet with him in Sweden more frequently than once a [i4iyear? [15] A: The whole of that period was competitive. [iq Europe was a very competitive marketplace for [17] chlorinated biphenyls. The French were particularly [is] aggressive at that particular point commercially. [i9]The Germans felt that mainland continental Europe poi was theirs and Monsanto shouldn't be trying to gain [21] a toehold in Europe. So, it was a very competitive [221 period in chlorinated biphenyls in Europe. [23] Q: Did Mr. Palm ever meet with you in London or [24] in Brussels? [25] A: He didn't meet with me in London, I know Page 40 Deposition of DAVID WOOD NOVEMBER 9, 1995 in that. When I had made the move to Brussels, Mr. m Palm would probably make one trip per year to the pi Brussels headquarters office to talk with a number [4] of product managers, because he handled -- he was [5] not a specialist in dielectric fluids, he was, as I [q said, a general representative, and so he would m visit Brussels and meet with me amongst several [8] other product line managers. [9iQ: What was Rising and Strand's role as [io] Monsanto's agent in Sweden? (in A: They would handle the day-to-day contact [12] with Monsanto's customers for all its products. [i3iThey would coordinate with customers the acquisition [i4] of the appropriate import documentation and payment [is] documents, that is, credit and the like. They would [lq arrange for appropriate unloading of cargoes of [17] chemicals moving into Sweden. They had very limited usi warehousing, but they could hold reserve inventories [iq of some products for customers who chose not to [20] inventory themselves the whole of their [21] requirements. They did the sort of things which a [22] good professional sales agency did. [23] Q: Did they monitor the market in Sweden? [24] A: In that they met, and, as I said, had that [25] day-to-day interface with the customer base, yes. Page 41 HI They were expected to give us feedback on was demand [21 growing in Sweden or certain product lines. pi Q; Did they handle press relations in Sweden? [4[ A: No. [5]Q: Who handled Monsanto's press relations in [q Sweden? p] A: We would normally in that type of situation [8] -- if there was a need for Monsanto to make a [9] press release of its own in a number of European poi countries, we would have wprked through our internal [in public relations department and then to an external [121 agency that would be capable of knowing how to [i3] prepare and place a press release in a number of [lq different languages in different European countries [iq with different media. We would certainly involve a [iq Rising and Strand, in the specific example of {\i\ Sweden, if we were going to make a press release, [is] We would be sure that they knew it was going to [i9] happen. But we did not depend or rely upon them in [20] any way of having, themselves, public relations [21] expertise. an Q: Did you rely on Rising and Strand to monitor [23] what the press was saying? [24i A: No. We understood that they were [25] intelligent, well educated individuals, and Page 42 in therefore, they much more so than, say, America at ra that point in time -- Europeans read a lot more p] newspapers than Americans, and they, therefore, tend [4] to be pretty well Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 37 - Page 42 HARTOLDMONO010994 Deposition of DAVID WOOD NOVEMBER 9, 1995 versed in what's going on in the ra media in their country, and if they saw something [q which they felt was pertinent to the business that pi they were conducting for Monsanto, they would bring [q it to Monsanto's attention. But there was no formal pi responsibility of our talking to them and saying did [ioj you check the newspaper this morning to see if there [in was something about a Monsanto or a product line in [121 which Monsanto had any involvement, no. [i3] Q: But a good agent would do that, is that [Hi right? [i3] A: Yes. And they were a good agency. [i6] Q: Was Mr. Palm the only person at Rising and [\i\ Strand who handled dielectric fluid -- the [is] dielectric fluid business for Monsanto? [19] A: No. There would have been other . people who poi would have been in departments involved with customs pi] clearance, shipping and handling, and that sort of [22] thing, who would have been involved with [231 dielectrics. In terms of the interface with the [24] customers-- of Monsanto's or of customers of our [25] competitors for this product line in Sweden, Mr. Page 43 [i] Palm would have been the general sales [2] representative who had Aroclor as one of his product pi line responsibilities. [4] Q: Who were the users of dielectric fluids in [si Sweden at that time? [6] A: The major user of chlorinated biphenyl based m dielectrics were a company called Liljeholmens. Do piyou want that spelled? L-i-l-j-e-h-o-l-m-e-n-s. [9] liljeholmens manufactured a wide range of electrical [ioj capacitors. There was a very large transformer [ii] manufacturer in Sweden called Asea, A-s-e-a. They nzi were a large manufacturer.af transformers, but they [13] did not figure largely in the market for chlorinated [14] biphenyls ' insulated transformers. They tended to [15] make standard oil filled transformers and air cooled [i6] transformers. They had only a very small business in [17] chlorinated biphenyl transformers. And those two [iq companies, essentially, were the major Swedish [19] potential for the type of dielectric fluids that we, [201 Ruan Cologne and Bayer sold based on chlorinated 1211 biphenyls. cm Q: Were there any other users of dielectric rn] fluids other than the two you mentioned? [24| A: I seem to remember there might have been a 125] couple of real small ones, but you're taking me too Page 44 [1] far back. [2] Q: But those two were the major users? [3] A: If I were going to visit Sweden, I would try [4] to charge discussion with those two companies. [3]Q: And there weren't other companies at TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY that [6] time who you made a special point of meeting with if u\ you were to travel to Sweden, is that right? ra A: Not in Sweden. Normally, my trips would be [q Scandinavian in nature, and there were other [ioj manufacturers of electrical equipment in other [uj Scandinavian countries. But Rising and Strand were [12] a Swedish agency. [i3j Q: Did Rising and Strand serve as Monsanto's [i4j agent in any other country other than Sweden? [13] A: No. They were a -- they were a Swedish [16] company working in Sweden. [17] Q: Who were the other manufacturers of [iq dielectric fluids that competed with Monsanto in the [19) Swedish market? [201 A: The German -- the large German chemical [21] manufacturer that I would call Bayer, that you may [221 know as Bayer, B-a-y-e-r. That's my European [23] background, again. And a company in France called era Prodelec, P-r-o-d-e-l-e-c. There was an Italian ps] company called Caffaro, C-a-f-f-a-r-o. And I believe Page 45 in at a time there was a small Spanish producer. And pi in eastern Europe there was a state producer of pi dielectrics based on chlorinated biphenyl, ra Q: In 1966 when you were a product manager -- [5] excuse me. In 1966 when you were product ra supervisor, what share of the Swedish market did p] Monsanto enjoy? [8] A: Less than my supervisors would have liked, m At that stage the major user of dielectric fluids in [10] Sweden was Liljeholmens, and they were delighted by [in the emerging competition for chlorinated biphenyls, u25 and was swinging their contracts between the three [iaj major suppliers, the French supplier, the German [14] supplier and beginning to use Monsanto's presence in [is] continental Europe as leverage with those two [i6] suppliers. So, if we had more than 20 or 30 percent nTl on an annualized basis -- that's the number I have [iq in mind. But, again, this is a lot of years ago, [19) we're going back 30 years. poi Q: At that time did you view the Swedish market [21] as ripe for expansion of Monsanto's dielectric [221 business? [23] A: Yes. Because historically at that point in [24i time the Scandinavian countries were part of a [23] European trading group called EFTA, European Free Page 46 [i] Trade Association, which had duty-free entry for ra products between the member countries of EFTA, and p] England and Scandinavian were part of the European ra Free Trade Organization, whereas France and Germany iq were part of the emerging EEC, or European Economic ra Community, so for the 1 Page 42 - Page 46 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONO010995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY first time there were some p\ trade region benefits to be gained by Sweden pi importing dielectric fluids that had been pj manufactured in Great Britian, and Monsanto [ioj manufactured its European chlorinated biphenyls in [in Great Britain, so as EFTA and EEC emerged, there was [iq a temporary opportunity there for Monsanto to [i3i potentially be able to become a more interesting [14] trading partner for the Swedish economy. [15] Q: And was Brussels -- excuse me, was Belgium [i<s] also in the EFTA. [i7] A: No. Belgium -- the Benelux, Italy, France, psi Germany were part of the origins of the European [ii community. [20] Q: Where in Great Britian did Monsanto [21] manufacture dielectric fluids? [22] A: Our plant was -- we had two major [23] manufacturing facilities. The Aroclors were m manufactured, I think, in Newport, Wales. [25] Q: You mentioned that there was a second Page 47 in manufacturing facility, is that right? [2] A: There was a second manufacturing facility of [3] size in north Wales, and a product line which I [4j handled later in my career was manufactured -- I'm [5]just trying to remember which line was manufactured [<q at which location. 17) Q: Did the northern Wales facility manufacture [s] any chlorinated biphenyl products? pi A; No, it didn't. [io] MR. DUFF: Off the record, [uj (Recess). [I?] MR. DUFF: Mr. Wood, after -- strike that. [13] How long did you hold the position of product [14] supervisor for dielectric fluids in Europe? ' [is] A: Until early in '68. [i] Q: And at that time how did your ii7j responsibilities change? I [isi A: Monsanto had a totally separate line of ns] products which we called the food and fine [20] business. Just to describe that, a fine chemical is pn something which might find a use in a pharmaceutical [221 type of application, it might be a pharmaceutical [23] raw material, something of that nature. And [24] Monsanto at that time was the world's largest [251 producer of the chemical entity aspirin. You've Page 48 [U never seen an aspirin tablet with Monsanto's name on [2] it, but something like 60 percent of the aspirin in [3] the world was manufactured by Monsanto. And that tq was a very large business in Europe. And they isi decided that there were things that needed to be [6] done with the marketplace development of that m business that I had the skills to be able to handle, [8] and, therefore, they assigned me to that food and [9] fine business. [ioj Q: And your position was what at that time? (uj A: Market supervisor for food and fine [121 Deposition of DAVID WOOD NOVEMBER 9, 1995 chemicals, later to become product manager. [i3] Q: And how long were you a supervisor in the [14] food and fine chemicals business for Monsanto? [15] A: If I take your term supervisor to include [16] the market supervisor role and the product manager [i7j role, I was in that role from 1968 until 1974. us] Q: Did you become market -- excuse me. Did [i9] you become market manager after you were market [20] supervisor? [21] A: Yes, I did. [22] Q: And you were product manager during what [23] period? [24] A: I was product -- in the product manager [25] role, which, again, was the heading up that business ;Page 49 in in the European arena, from 1972 to '74. [2] Q: Are you relying on the CV which has been pj marked as Exhibit 273? [4] A: To make sure I give you those dates [5] accurately. I could have given you the years [6] without referring to it, but I needed to check the pi dates. [8] Q: And what position did you hold next after pi you were product manager for fine chemicals? no] A: I held at that stage the position of [in international market manager for fluids in St. [12] Louis, Missouri. [13] Q: And by fluids, what do you mean? [14] A: Fluids were the dielectric fluids which I [isi had had previous experience with in Europe. [i6]Aviation fluids. Monsanto makes a product called [i7] Skydrol, S-k-y-d-r-o-1, which is the hydraulic fluid [isi in commercial aircraft, which we sell around the [i9j world. There was some minor involvement with poi Pydraul, some minor involvement with Therminol. And pi] then there were three or four very specialized small [22] fluids involved with the space program and military 123] avionics which took a small part of my time. [24] Q: What involvement did your position have with [25] Pydraul fluids? _________ .Page 50 til A: If we were selling a Pydraul fluid, for pi example, in Australia, and I were visiting Australia pj to talk about our dielectric fluids business and our n aviation fluids business, I had to have sufficient pi knowledge of what the Pydraul group were doing in m Australia to be able to be an accurate carrier of pi messages and to talk with the people in Australia, [aj to use that example, about what they might do to [9] extend the business or -- so, the major part of the [ioj international assignment was related to the major (iij product lines of dielectrics and aviation fluids. [i2] Q: During the time that you were the [is] international market manager for fluids, were any of pq those fluids -- did any of those fluids contain [151 PCBs? Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 46 - Page 50 HARTOLDMONO010996 Deposition of DAVID WOOD NOVEMBER 9, 1995 [i] A: I think by the time I assumed that position [in Monsanto had already changed the formulations of the [lsipydrauls to be non-containing of chlorinated [is] biphenyls. [20] Q: Is it correct to say that at that time pi] Monsanto's Pydraul fluids were phosphate ester [221 based? [23i A: Yes. 124] Q: And that is because they had had -- strike [25] that. That is because Monsanto's Pydraul fluids at Page 51 [i] that time had been reformulated to remove PCBs and pj PCTs, is that right? Pl A: I believe that's right. [4] Q: And by PCBs you understand me to mean [5] polychlorinated biphenyls, is that right? [6] A: Yes. n Q: By PCTs you understand me to mean pj polychlorinated terphenyls? ' [9] A: Yes. [io] Q: You stated a minute ago and correct me if I [in misstate what you just testified to, that you needed [i2] to know about other products... such as Pydraul in [13] order to be fully informed for the benefit of your, [i4] predominantly, dielectric customers, is that right? Ii5] A: No. No. You did misunderstand me. If you [i6i look at Monsanto's presence in the non-U. S., [i7] non-European marketplace for products which were [isi encompassed in the business of functional fluids, (13 dielectric fluids were the largest international ro business. The aviation fluids were the second pi] largest aviation business. The heat transfer fluids [22] were probably the third largest business. The [23] hydraulic fluids were probably the fourth largest p4] business. And then there were a smattering of these psihighly specialized avionics, aerospace, space, high....* [i] * * * 5 Page 52 [i] vacuum fluids which were very a specialized category pj of products. So, in most cases if I were addressing pi a particular international market situation, the [4] major component of my focus and effort would be on [5] the dielectric business. I probably was --1 was (4 traveling to that country to talk about dielectrics pi business, I would talk to the national airline about pi aviation fluids, and depending on which specific p) country it was, I might or might not get involved in [101 a discussion on heat transfer fluids or Pydraul. So [in if I were to break down the time and effort in my [12] assignment, it would have been in file sequence that [13] I've just outlined. But I was not taking [i4] information about hydraulic fluids for the benefit (i5j of dielectric customers, which is the way you [iei portrayed it. [i7] Qs I understand. [isi A: Okay? [isi Q: Were you responsible for any customers in [20] the United States when you TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY were international market pi] manager? [22] A: I wasn't responsible for companies in the [23] United States. I was responsible for familiarizing [24] myself with dielectric customers in the United [25] States who would have -- who might have Page 53 [i] subsidiaries in other countries. So that if I were [21 to visit South America, Brazil, and visit the pi General Electric subsidiary, that they would feel m that, yes, I knew something about what General [5] Electric and Monsanto were doing in the United [6] States, p] Q: So your responsibilities with respect to 18] companies in the United States was limited to pj situations where those U.S. companies had [io] subsidiaries, affiliates or facilities outside of (ill the U.S., is that right? [12] A: Yes. [13] Q: Did you ever have any contact with Tennessee [i4] Gas Pipeline during your career at Monsanto? [ijj A: No, I didn't. [i6] Q: Did you ever speak with anybody at -- Tennessee [17] Gas Pipeline? [isi A: Not that I can recall doing so. Not in a [19] business context. I mean, I may have met them at poj some industrial gathering, but -- pi] Q: Do you recall meeting with anybody at pg Tennessee Gas Pipeline at any time? P3] A: I don't. P4] Q: As an international marketing manager, did [25] you work with any customers who were solely Pydraul Page 54 [i] customers? pi A: Yes. This was a period of time when pi offshore drilling was an important world-wide [4] development, and there were specific phosphate [j] ester-based Pydraul fluids that we used in the [6] offshore drilling industry to clamp down the caps on pj drilled wellheads, and to move the rig up and down, ra Some of these floating rigs, they were getting very [9] large and very sophisticated at that point in time, [io] So there would be some companies around the world pi] involved in offshore drilling that by the very [12; nature of my travel program, if I was in that (i3j country where offshore drilling was at a high level, [i4] then I would talk to some of the drilling companies [isi specifically about Pydraul and I would have no need (i6i to talk to them about dielectrics or aviation fluids [i7i or anything else, pg] Qs Were any of your Pydraul customers -- [i9] strike that. Did you ever work with customers at pog Monsanto -- strike that. While you worked for pi] Monsanto, did you ever work with any customers who iza used Monsanto fluids in air compressors? p3] A: I won't say that I never met one, but p4] certainly it was a tiny part of my role. I mean, P5] air compresser lubricants were a very small Page 55 I I Page 50 - Page 55 Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONO010997 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY m component of hydraulic fluids, and hydraulic fluids, pj as I said, were a very small part of my work. pi Q: Do you recall any customers who used (4) Monsanto fluids in air compressors? [j] A: No. tq Q: What type of Pydraul fluids were used in the tq offshore drilling industry at the time -- excuse pi me, I'm sorry. At the time, what type of Pydraul [q fluids were used in the offshore drilling industry, [ioi at the time that you were international market pu manager? [i2] A: The major fluid of use in that particular [i3i application was a Pydraul 29 ELT, which was a [i4] phosphate ester-based fluid. [is] Q: Was one of your responsibilities as pq international marketing manager to discuss with im customers the historical presence of chlorinated [isj compounds in functional fluids? [i9] A: No. 5 [2oi Q: Were there times when you did discuss with pi] Monsanto's customers the fact that functional fluids (221 in the past had contained chlorinated hydrocarbons? [23] MR. CHAMBERS: Let me object to the form. [24i When you say functional fluids, you mean more than [251 pydrauls now? Page 56 in MR. DUFF: Yes. (23 MR. CHAMBERS: Okay. It included dielectrics pi and heat transfer and -- [4i MR. DUFF: Yes. 13] A: As I say, the dielectric fluids still did (q contain PCBs at this point in time. To the extent pi that -- most of my conversations, as I traveled pi internationally, were dielectrics based, so I [91 certainly had discussions as I went around my (ioi international business at that time about PCBs in [in dielectrics and Monsanto's view of PCBs in [121 dielectrics. I said the second area of emphasis was [13] to talk about aviation fluids. Aviation fluids, for pq technology reasons, never had contained PCBs. They [iq had to work at very low temperatures, because planes pq get cold up there in the sky. To the extent that I [17] met occasionally, as I portrayed, with people who [iq were involved in hydraulic fluid use, I mean, they [19] were aware that Monsanto had reformulated its fluids m and that the fluids that Monsanto was then selling pi] did not contain any PCBs. So, did we occasionally 1229 get into some dialogue about well, what do you think pq about PCBs? I can't say it never happened, but I [24] was not part of the dialogue that went on with [23] Pydraul users as Monsanto reformulated. That had* 3 Page 57 in happened before I got involved with functional pj fluids after six years away from that business. pi Q: After you were international marketing [4] manager, what position did you hold next? [3] A: Then I became -- what title did we use? Deposition of DAVID WOOD NOVEMBER 9, 1995 (q Market manager, dielectrics. Pl Q: And when did you become market manager for pi dielectrics? Pi A: In 1975. [101Q: And what were your responsibilities when you p 11 were market manager for dielectrics? [121 A: To relate to the market for dielectric [131 fluids around the world, to understand customer and p4| marketplace needs for the types of dielectric fluids pq that Monsanto manufactured, to be able to pq communicate with our customers as new fluids were p7] being developed to potentially replace psi PCB-containing fluids, to represent a proper balance pq between Monsanto's desire to disengage from PCBs and pq our responsibility to the electrical industry to pi] make sure that the -- both our immediate customers [221 and their customers were able to satisfactorily p3i conduct business as this transition away from PCBs [24] was occurring, pq Q: And what position did you hold next? .Page 58 Pl A: I became industry manager, dielectrics. And pi that was January 1st of 1976 and went for a two year pi period through'77. [4i Q: What were your responsibilities as industiy [q manager for dielectrics? [q A: Responsibility then was to make sure that pi Monsanto exited PCBs responsibly and that we pi appropriately evaluated if Monsanto could supply any (q alternative fluid to the industry to replace those poi dielectrics containing PCBs in the applications pu where they had been used, and to make sure that [121 Monsanto was in tune with the conversion timetables pqof electrical equipment producers and electrical pq equipment users, and talk with the EPA as pq regulations were beginning to be formulated about pq identification, location, dismantling and disposal pq of PCB-containing electrical equipment as it went pqout of service in the future. And to make sure that pq approach was appropriately conducted simultaneously pojon a world-wide basis. [211Q: Any other responsibilities? [221 A: That kept me very busy. [23i Q: Did Monsanto -- what did Monsanto determine pq about whether or not it could supply replacement pq fluids for the dielectric fluids that contained [21 A: We came up with some interesting molecules pi to be replacement transformer coolants, but the m industiy ultimately decided to go to a greater use tq of non-fire retardant transformers, coupled with an (q increased use in resituated dry type air cooled pi transformers. And in a couple of situations to use [q a newly developed silicone fluid to insulate [q transformers, even though its properties were seen peg to be inferior to those Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 Page 55 - Page 59 HARTOLDMONO010998 Deposition of DAVID WOOD NOVEMBER 9, 1995 of the chlorinated [in biphenyl-based fluids from an insulation [iq characteristic standpoint. And there was a high p3j viscosity, high flash point oil that was produced by p4] a company called RTE Corporation, which had a usi limited -- very minor success and then failed [i<s] because it really wasn't fire-resistant. So we im tried and failed, but we had already made a psi commitment that when the industry said that it could [i9i change, then we retained the right to cease poi production, as we did, irrespective of whether [211 Monsanto was selling a replacement fluid. Equally, [221 in capacitors, different solutions were found for/tai -- whereas the PCB-containing dielectrics had p4] characteristics which made their use very universal [25] between small and large capacitors, the industry ;Page 60 [i] splintered in the stage of transition and ' came up [21 with a number of different solutions for different pj sectors of the capacitor marketplace, and we, again, [4] had two fluids that were of interest to major pi capacitor_____ producers, but the economics of producing [ej those and using those proved to their evaluation to m be inferior to some alternatives that they looked at pi and so, ultimately,, when they sort of said we're n now ready to make the transition, we stopped [i<q producing askarels and exited the dielectrics ui) business. [12] Q: Was askarel the name that Monsanto used for [13] its dielectric fluids? [i4i A: Oh, I'm sony. I knew we were going to [15] reach a point where I suddenly, habit after [16] life-time, dropped in askarel. Askarel was an [i7] industry term for a -- I've got to remember the uq definition. It's a fire resistant fluid which does [19] not produce fire resistant -- does not produce pq inflammable gases under arc conditions. And so the [21] chlorinatedbiphenyl dielectrics were a member of 1221 the class of askarels. There were other fluids that [23] would fall within the definition of askarel that [24) were not PCBs. [25] Q: Such as what?[i] :Page 61 [i] A: Some of the liquid gas type coolants such pi as, I think, sulphur hexafluoride was considered pi that it could be designated as an askarel. The m major askarel were the chlorinated [5] biphenyl-containing dielectrics, and so a lot of (q people even in the industry and well familiar with p] askarel tended to use chlorinated biphenyl m dielectrics and askarels almost interchangeably. I pi shouldn't have ever mentioned the word askarel, we [io] wouldn't have gotten that definition. (uiQ: After you were marketing manager for [i2i dielectrics, what position did you hold next? [13] A: I thought we had gone -- I went from market pq manager dielectrics to industry manager, dielectrics [15] and you asked me what was my role as industry pq manager dielectrics. TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Am I sort of getting out of [i7j sequence here? [is] Q: No, I think you're correct. What time [i9] period were you industry manager for dielectrics? raj] A: '76 and'77. [211Q: We did cover that. And what position did [22] you hold next? [23j A: Market manager, heat transfer and process [24] chemicals. I had almost forgotten that one. [25] Q: And how long did you hold that position? Page 62 [i] A: From January '78 to December '79. pi Q: What were your responsibilities as market 01 manager for heat transfer and process chemicals? M A: Two major responsibilities. I was now in [5] what we termed the specialty chemicals division, [q which we referred to earlier as the functional p] fluids division. A rose by any other name. It ra really was the same collection of products, but it [9] had become known as specialty chemicals. Two [ioj ........... components of that specialty chemical business were pi] a range of fluids which were used in industrial pj] indirect heating applications. And a second area p3] were what we referred to as process chemicals, which pq were -- the larger part of the process chemical pj] business was the production of solvents for pq carbonless paper systems. [i7] Q: Did you have any other responsibilities in ns] that position when you were market manager for heat [19] transfer and process chemicals, other than those poi that you've stated? pi] A: I said those were the major products. There [22] were two or three other tiny products which were in [23] the development phase, but that was the major part 124] of the assignment. 125) Q: Did you have any other responsibilities ^Page 63 pj other than with respect to those two categories of m products when you were marketing manager for heat oi transfer and process chemicals? M A: Yes. I also had responsibility at that time [5) for ethylene maleic anhydride copolymers. [q MR. CHAMBERS: We may need to spell that. pj As Ethylene, e-t-h-y-l-e-n-e. Maleic, pi m-a-l-e-i-c. Anhydride, a-n-h-y-d-r-i-d-e. [9] Copolymers, c-o-p-o-l-y-m-e-r-s. EMA copolymers poi were used as thickeners in pigment systems which pu were used for coloring fabrics such as cotton. They [12] were used as resins to adhere active coatings to [13] some parts of the carbonless paper system, which was pq why they were included in the same business area as p5] the solvents used in the carbonless paper business, pq and they were used as an essential component in the p7] Page 59 - Page 63 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONO010999 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY compounding of Polaroid film. I had responsibility [is] for the finally divided carbon business that we had [i9] at that time, which was used as a mold release in pm producing copper ingots by the primary copper pij producers around the world. That's about it. [22] Q: And after you were marketing manager for [23] heat transfer and process chemicals, what position [24] did you hold next? [25] A: I made a major career move, I swing across ____________________ _ Page 64 [i] the desk from marketing to purchasing, at my request pi and with Monsanto's agreement. Pi Q: Why did you request that change? M A: Monsanto and I had mutually decided that I [5] would stay in America and not go back to Europe and, [6] therefore, I needed to find out more about the U.S. p] chemical industry. And because you will note that [g] most of my career to that point had been in rather [9] small volume specialty type chemical areas, and if I no] was to make a career in the U.S. chemical industry I pi]needed to learn something about the -- some of the [12] larger volume chemical businesses in the United [i3] States, and we agreed that what better place to [i4] learn about those than in the purchasing role, which [lq gave me access to a dialogue with many of the--p] many of America's leading chemical producers. [i7] Q: So was your position one of purchasing ns] materials for Monsanto to produce products? [19] A: Raw materials. Raw material chemicals. [20] Q: What sort of raw material chemicals were you pi] responsible for purchasing for Monsanto? [2?] A: I was responsible for buying the propylene ps] and ethylene. Do you want any spellings? Monsanto m had at that time been operating a major cracker, psi c-r-a-c-kre-r, down in Texas in the Gulf, and this __Page 65 pi was in a joint venture with Conoco, and when DuPont pj reached out and bought Conoco, they bought us out of pj that Olefin operation in the Gulf, and so we needed [4] to buy major amounts of olefins, o-l-e-f-i-n-s, is] which is the collective name for propylene and [0 ethylene. So that was -- strategically placed pi Monsanto in a position of needing to talk at that m point in time to all the major Gulf coast [9] petrochemical producers, and so I was very involved om with that as part of my career development and [ii] learning more about the U.S. chemical industry. I [12] also bought precious metals for Monsanto, I bought in] catylists for Monsanto, I bought the most broad [i4] range of oxalalcohols, I bought -- [in Q: So you were responsible for all raw chemical uq purchases? [17] A: No. [18] Q: Is that right? [19] A: No. No. No. No. That isn't right. Deposition of DAVID WOOD NOVEMBER 9, 1995 You [20] lept to a conclusion. There were plenty of things I pi] didn't buy. But I -- Monsanto organized its [22] purchasing department at that time into a small St. psi Louis based group that bought the major chemical raw [24] materials for the corporation, so I was one of about [25] four members of that team. But not the only one. Page 66 [i] But Monsanto bought many raw materials, and the ones [2] that I bought, oh, several billion dollars a year pi worth of raw materials, which was a great hi opportunity to learn about the U.S. chemical [sjindustry. [e] Q: After you held the position of manager for [7] raw materials purchases, what position did you hold [8] then? [91 A: I went down to Brazil to become commercial [uq director for Monsanto's operations in the chemical [lijand plastics area, non-agricultural chemical, in the [12] Brazilian marketplace. [i3] Q: And what were your responsibilities in that [i4] position? [i5i A: To represent the interests of Monsanto's [iq chemical group. At that time Monsanto was broken [17] down into the chemicals group, the agricultural [is] group. We had acquired Searle and Nutrasweet at [i9] that time. So, essentially, I handled the complete [2cq range of products offered by the chemical group, and [21] also represented the Nutrasweet interest in Brazil. [22] Didn't get involved with agricultural chemicals, taj And so my responsibility was to sell the products [24] that we made in America into Brazil, to profitably [25] grow the businesses where we had already built Page 67 [i] plants in Brazil to serve the Brazilian and p] Brazilian export market, and to define new projects [3] by which Monsanto could expand its capital hi investments in the manufacture of chemicals in [5] Brazil. [q Q: How long did you hold that position? p] A: Six years. My wife would have it we should esi never have left, pi Q: So was that from approximately 1982 to 1988? no] A: '88. [in Q: What position did you hold next? [121 A: When I came back from Brazil I joined the [i3i resins group, the resins division, and handled the [14] adhesives business and the specialty resin business (isi and the specialty plasticizer business as business uq director. [17] Q: And how long did you hold that position? [is] A: The reason why I hesitate is because we went [191 through a lot of restructuring at this time. I held pm the position per se with slight variations as we pi] moved part of that business from the resins division [22] to the specialties division. In the specialties [23] division -- so I probably held the resins division p4jjob in '88, '89 and into the beginning of '90, then psi in Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 63 - Page 67 HARTOLDMONOO11000 Deposition of DAVID WOOD NOVEMBER 9, 1995 '90 we moved the plasticizer business to the Page 68 [i] specialty division, and I ran that and created the p] polymer modifier business in '90 and '91. We then pi restructured a second time and moved the polymer m modifier business back to the resins division, and p] at that stage I became Director Americas, North and [6] South, for the Saflex business, which is the plastic m interlayer for laminated glass that we were-- that pi we alluded to earlier. And then I took an early pi retirement from Monsanto in the fall of 1993, and [iq that concluded my career with Monsanto. [i i] Q: What did you do following your retirement [121 from Monsanto? [13] A: I took a year to decide whether I would PA retire retire, work for somebody else or start my [iq own business, and decided that . retirement retirement ri6] after a trial period' held no great reward for me or [17] desire for me. I decided I didn't really want to [is] work for anybody else at this point in my career, [i9i and so I formed a small business called David Wood [2oi and Associates that I've subsequently merged and pi] incorporated into a business with an ex-colleague to pq form Paton Wood Associates International. [23] Q: What is the business of Paton Wood p4j Associates International? [25] A: It has two business foci. One is die Page 69 pi development of and implementation of international pj strategy, and secondly, in terms of enhancing that pi implementation in offering a range of skill m development courses and training. [si Q: What type of international strategy are you [6] referring to? m A: There are many companies who today recognize m that the commercial world & becoming more global in pi aspect, and historically they may have been in [io] local, national, regional markets, and this could (in be, for example, a company here in Missouri who has (Pi aspirations to grow into Europe or to grow into [is] South America or to grow into Asia. It could be a |i4] European company that wanted to move into the [i5] American marketplace. Both I and my colleagues have (i6] a lot of hands-on experiences of international [17] business and growing and developing international [is] business, and so we can remove an element of fear nq from the process of corporations expanding into pq international marketplaces, pu Q: Is your partner Cumming Paton? [221 A: Yes, it is. [23i Q: In your consulting business, do you do any pq environmental consulting? [25] A: No. __________________________Page 70 Pi MR. DUFF: Off the record, pi (Noon Recess). TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 01 MR. DUFF: Mr. Wood, I'd like to return to Hi the period where you were sales supervisor in [5] dielectrics in London. Was that the position that pi you held from the beginning to the end of October pi 1966? Pi A: Yes. [q Q: And you said that it was on November 1st, [id 1966 that you moved into the position of product [in supervisor for dielectric fluids, is that right? [i2] A: That's the date of the assignment change. [i3j It wasn't the date that I actually physically moved m from London to Brussels. Just to make sure [is] we're -- [16] Q: Sure. I understand. So did you actually [17] become product supervisor for dielectric fluids [is] while you were still in London? [io] A: I probably started to pick up information, poj But as I said, you know, it takes several weeks to pi] move internationally, and so there was a period when [zzi I was toing and ffoing between London and Brussels. [23] But in terms of when was I assigned and when did I [24i officially assume the office of product------supervisor, psidielectric fluids, that was November the 1st, 1966. Page 71 [i] Q: So, there was a time period where you were pi operating both out of London and out of Brussels, is pi that right? [4] A: Yes. [si Q: And when did that time period begin when you [6] were operating in both London and Brussels? m A: Probably about September, October of that m year, and finished essentially by the middle of [9] November, I'm pretty sure I was established in [iq Brussels. [in Q: In 1966 was there a time where you learned nqof a study in Sweden relating to accumulation of [i3] chlorinated compounds in wildlife? [i4] A: Yes. [is] Q: And when was that? [16] A: It was late in the year. The exact date -- [17] Q: Do you recall the exact date? [is] A: No, I don't. [i9] Q: Do you recall if you were in London or in [20] Brussels when you first learned of this? pi] A: I'm pretty sure I was in Brussels. [22] Q: And how did you hear about this? [23] A: I received a letter from Ola Palm in m Sweden. 125] Q: Mr. Wood, I'd like to show you what's been Page 72 in previously marked as Plaintiffs Exhibit 200, a copy m of which I have for counsel. pi MR. CHAMBERS: Thank you. M MR. DUFF: Mr. Wood, is this the letter that [5] you were referring to that you received from Ola [6] Palm? [7] A: Yes. P] Q: And what is the date of this letter? Page 68 - Page 72 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11001 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Pi A: November 28th. [ioiQ: 1966? [in A: 1966. [i2i Q: And if you could, please identify this [i3| letter for the record? [mi A: This is a letter from Rising and Strand, [i5] Monsanto Europe's agent in Sweden. It was written [i6j by a general sales representative in the offices of [i7] Rising and Strand, and it was reporting his [isi observation of some media publicity in Sweden [i9] concerning a chemical which he believed might be [20] associated with Monsanto's chlorinated biphenyls. [2uQ: And when you say Monsanto's chlorinated [221 biphenyls, you mean Monsanto's Aroclors, is that [231 right? [24i A: Yes. [25] Q: When Mr. Palm sent you this letter, was he Page 73 Hi following up on a conversation that you and he had [21 had prior to the date of this letter? pi A: He opens the letter with the words "As [4i mentioned", and so I can only make a conjecture, and jsi it's only that, but we must have immediately prior [6] to this had a very brief telephone call when he said pil'm sending you a letter about. [81Q: Do you recall this telephone call with Mr. [9i Palm? [10] A: No, I don't. tin Q: And when Mr. Palm sent you this letter, he [12] told you in this letter that there had been some [isi publicity in Sweden concerning investigations made [141 at the Institution of Analytical Chemistry at the nn Stockholm University, is that right? [iqA: Yes.' ini Q: Were you familiar with this Swedish research [is] at the time that Mr. Palrn sent you this letter? ;, [19] A: To the extent that there obviously had been [20] a very short preliminary telephone conversation, I [21] was familiar that he was sending me a letter about [221 what had been reported in Sweden. Prior to that tzsi telephone cadi, I knew nothing of any work going on [24] in Sweden. [25] Q: Do you recall if in that telephone call Mr. 'Page 74 in Palm indicated to you that he believed that the 121 Swedish research related to Monsanto's Aroclors? pi A: No. [4] Q: You don't recall that? in A: No, I don't. [i Q: Had the Swedish research received any pi publicity in London at this time? is) MR. CHAMBERS: I object to the form. [9i MR. DUFF: Referring to the date of this [io] letter. [in A: Not to my knowledge. [121Q: Had the Swedish research received any Deposition of DAVID WOOD NOVEMBER 9, 1995 [13] publicity in Brussels as of the date of this letter? [14] A: Not to my knowledge. [i5i Q: Had the Swedish research received any [16) publicity in the United States as of the date of [i7i this letter? [i8i A: Not to my knowledge. [i9i Q: Mr. Palm told you that this Swedish taoj research, quote, revealed that a group of products pi] called polychlorinated biphenyls, PCB, accumulated [22] in certain organs of animals, correct? [23] A: That's what he stated in the letter. And [24] specifically he stated that polychlorinated [25] biphenols had been the subject of some Swedish Page 75 in research. [2] Q: And he referred to that chlorinated compound pj as PCB for short, is that correct, in his letter? [4] A: In his letter he so referred. But, I mean, [5i he talked about a paper which was related to a class [q of compounds which he designated as polychlorinated m biphenols. And I want to emphasize that, because it [8] became material in internal discussions at Monsanto. [9i Q: And he spelled that -- he spelled biphenols [io] in the first paragraph of this letter [iub-i-p-h-e-n-o-l-s, is that right? [i2] A: That's correct, yes. [i3i Q: But then he referred to polychlorinated [141 biphenols as PCB, is that right? [i5i A: He referred in that fashion, yes. [16] Q: And he told you that the Swedish research or [17] the Swedish investigations had indicated that this [is] chlorinated compound had been found to accumulate in [191 organs of animals, is that right? [20] A: He states in the letter that an organic [211 chemical is claimed by a Swedish research group to [22i accumulate in the tissue of animals. [23] Q: And did you understand this organic chemical [24] to be Monsanto's Aroclors? [251 A: No. ;Page 76 [i] Q: Did you understand this chemical to be [2i polychlorinated biphenyls? pi A: No. [4] Q: Did you understand that it was possible that [siit was, in fact, polychlorinated biphenyls that Mr. [q Palm was speaking of? pj A: I understood that when lay people are [si reporting technical issues they can sometimes get [9] into problems with nomenclature, so I chose not to [ioi make any assumption at that point in time. [illQ: Were you concerned that Mr. Palm might be [12] speaking of a product that was manufactured by [13] Monsanto? [i4] A: I was concerned that there seemed to be an [is] issue surrounding a newly identified class of [iq chlorinated compounds in the environment that in im reality or in -- through misunderstanding could be [is] associated with Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 72 - Page 76 HARTOLDMONOO11002 Deposition of DAVID WOOD NOVEMBER 9, 1995 the use of polychlorinated biphenyls nq in European industry, be it Monsanto's Aroclor or [20] the products made by our competition and supplied in [zi] Sweden. [22] Q: Elsewhere in Mr. Palm's letter to you on [23] November 28, 1966 he referred to these chlorinated [24] compounds as polychlorinated biphenyls, y-l-s, is [25] that correct? Page 77 [1]A: I'll need to -- [2] MR. CHAMBERS: Can you direct -- [3] A: Can you direct me to a particular point that [4] you - [5] MR. DUFF: Certainly. I'll direct your pi attention to the last page of this document, and [7] specifically the second to the last paragraph, pi A: Are you talking to the paragraph which [9] starts, I quote, I suppose there is no doubt that [icq what has been term polychlorinated . biphenyls is [ii] equal to Aroclor, is that the'~ [i2] Q: Yes, I am. In that sentence Mr. Palm [i3] referred to polychlorinated biphenyls spelled -- [i4] where biphenyls was spelled b-i-p-h-e-n-y-l-s, is pj] that correct?........... [is] A: That's what he -- yes. Mr. Palm makes his p7] personal supposition in that paragraph. [is] Q: And his supposition relates to whether or [19] not there is any doubt, is that correct? [20] A: He supposes, Mr. Palm supposes that there is [zi] no doubt that what has been termed polychlorinated mi biphenols which, in fact, was not referred to as [23] polychlorinated biphenyls, is equal to Aroclor, P4] which is an incorrect assumption as well, because as [25] I told you earlier in testimony, Monsanto was trying ;Page 78 [i] to penetrate the Swedish market, but if, indeed, m firstly the class of organic ' ` compounds was related pj to the biphenyL y-1, molecule, then it's certainly w not a correct supposition on his part to make an [5] ' assumption that it is equal to Aroclor. There is a [6] looseness in language. You're talking about a p] Swedish gentleman who is writing in English, which [8] is not his native language, and so as I read this, I [9] mean, I took that for what it's worth and addressed [icq the question differently to the way that you've [ii] suggested it could be read. [i2] Q: Do you agree that in this sentence Mr. Palm [i3] was telling you that the chlorinated compound which [i4] was the subject of the Swedish research had been [is] termed polychlorinated biphenyls, y-l-s? [i] A: No. [in Q: You don't agree that that's what this [is] sentence says? [i9i A: No, I don't. [20] Q: In this letter of November 28, 1966 Mr. Palm pi] also told you that these chlorinated compounds were mi said to be related to DDT and equally poisonous, [23] correct? TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [24] A: Can you again draw my attention to a [25] particular paragraph? Page 79 [i] Q: Certainly. The first paragraph of the pi letter. In this first paragraph did Mr. Palm tell Pi you, quote, they are said to be related to DDT and [4] equally poisonous, unquote? [5] A: He reported what he had been reading in a [6] sentence, which to quote the letter, Mr. Palm's [7] letter, they are said to be related to DDT and p] equally poisonous. [9]Q: And Mr. Palm also told you that these [io] findings of the Swedish researchers were discussed [ii] at a meeting of scientists at the Wenner-Gren Centre [izj in Stockholm on November 22, 1966, is that correct? [i3l A: That's stated in Mr. Palm's letter. [i4] Q: Did I pronounce that correctly? Is it [i5] Wenner-Gren? [16] A: Strictly not, but -- that's sort of [17] irrelevant. [isi Q: Were you present at that meeting of [i9i scientists on November 22nd? [20] A: No, I certainly wasn't.....- . . .... ...-- pi] Q: Are you aware if anybody from Monsanto, any p2] representative of Monsanto was present at that p3i meeting? [24] A: No. 125] Q: Do you know if Mr. Palm was present at that Page 80 [1] meeting? [2] A: He was not. [3] Q: Do you know that for a fact? [4] A: Yes. [5] Q: In this letter of November 28, 1966 Mr. Palm [q translated for you an article that had appeared in a n Swedish daily paper recounting the findings of the p] Swedish scientists, correct? pi A: Yes. [icq Q: And he told you -- strike that. And he mi translated the article in the Swedish daily paper as iizj saying, quote, it is found in salmon and in pike, it [i3] is found in sea eagles living on fish, it is found [i4] on the surface of needles of the fir trees that is [in in the air, it is found on the hair of a five months [iqbaby, is that correct? [17] A: That is the accurate quotation from the [is] translation that Mr. Palm made and reported in his [19] letter of November 28th. [20] Q: What was your reaction when you saw this pi] letter from Mr. Palm? P2i A: My reaction was one of puzzlement and saying [23] that I needed to seek advice from colleagues within pq the Monsanto technical community to say -- tell me pn a little bit about the relevance of this article in Page 81 [i] Sweden, is there a connection or is there a possible [2] connection between here, are we talking a different pi class of chemicals, are we talking about a media [4] misunderstanding, are Page 76 - Page 81 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11003 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY we talking about a factual ra representation. There's something here that if, a ra very sort of qualifiable if, a product which pi Monsanto, amongst others, makes and supplies to [8] European industry is accumulating in the pi environment, then we need to address the issue. no] Q: In fact, it was a very important issue to [i ii get to the bottom of, is that right? [i2] A: Very important? It was a very-- it was a [i3] significant issue to clarify what was indeed being [i4] talked about. I mean, at this stage I received no [is] scientific paperwork, all I'm receiving is a [iq translation of an article from a Swedish daily [i7] newspaper whose reputation I know nothing of, about usi a situation where certain strangely unscientific [i9] language is used. And, so, is it very important? poi No. As responsible manufacturers of chemicals, if pi] something is happening in an area of chemistry which [22] even by supposition is closely related to something [23] that we are doing, we need to appropriately address pq it and find out from the scientists involved what ps] they've really been doing. Page 82 [i] Q: Whose responsibility was it to clarify pi whether or not polychlorinated biphenyls, the [3] product manufactured by Monsanto, was the subject of [q the Swedish research? [3] A: I assumed an initial responsibility, but [] communicated the rather tenuous report that I pi received from Mr. Palm to my colleagues in the pi United States, and asked for their guidance. [] Q: Who did you contact in the United States to [tor convey this information that was contained in Mr. nij Palm's letter? [12] A: I think I contacted Paul Benignus. I think [i3] that's what my initial step would have been. [i4] Q: And why is that? us] A: Because Paul Benignus was essentially the [i6i product manager for the dielectrics business in a [17] world-wide context at St. Louis headquarters of [isi Monsanto, and if even I had commercial or technical [19] questions, my first contact would be with Mr. pq Benignus to allow him to access the appropriate pi] level of expertise within the headquarter company in [22] America. [23] Q: Did you speak with anyone else in St. Louis [24] at this time? [25] A: I think you need to say at this time. I'd Page 83 [i] like -- the sequence of events, I think, are pi evident from communications that you'll probably be pi walking me through today. Did I speak -- I remember [4] that I contacted Benignus. I cannot remember [3] anything else that would not have been generated by ra that first contact with Benignus. P] Q: How soon after receiving this letter from Deposition of DAVID WOOD NOVEMBER 9, 1995 p] Mr. Palm did you contact Paul Benignus? [9] A: Fairly quickly. I can't remember the date [io] that I wrote to him. But it was fairly rapidly. [in Q: Did you call him or write him a letter? [12] A: I wrote him a letter. [i3i Q: You didn't pick up the telephone and tell [i4] him what you had learned? us] A: No. [161Q: Do you recall if you wrote him a letter on in] the day that you received the correspondence from [is] Mr. Palm or was it a week later? [i9] A: I don't recall. [2D] Q: Do you recall who in St. Louis you spoke pi] with next? [22] A: No. [23] Q: Do you recall any of the individuals that [24] you spoke with at the end of 1966 other than Mr. ps] Benignus who were from the St. Louis office? :Page 84 [i] A: I don't -- I can speculate, but I don't pj think that helps us, I mean, because I think that [3] there are records of who I spoke to. [4] Q: I don't want you to speculate. [3] A: Well, I'm glad. [6i Q: Directing your attention to the third page m of Mr. Palm's letter, and specifically the paragraph pi to which we were referring a moment ago, which pj begins "I suppose" -[10] A: Is that the the penultimate paragraph? cm Q: Yes, it is. [12] Q: He also wrote to you, quote, there is also [i3] no doubt that the published facts will cause [i4] considerable unrest in several comers, . is that [is] correct? [i6i A: That's an accurate reading of the second [i7] sentence of the penultimate paragraph. [isi Q: What was your reaction when you read this [i9] sentence? poi A: One of recognition that at a time when the pi] liberal release of DDT to the European environment 122] was being questioned in a highly public form and p3] that this report that Ola Palm was translating was pq in a Swedish daily newspaper, and Sweden, in its ps] very socially forward thinking, was a country which Page 85 in had a reputation, justly arrived at, of being pi concerned about the environment, that if there was pi publicity about a new chemical class other than DDT ra that was being found in the environment, that this, ra indeed, would cause considerable unrest in several ra quarters. pj Q: Did Monsanto manufacture any phenol products ra at this time? pj A: Monsanto had manufactured chlorinated [io] phenols. And whether we were manufacturing them at [iij that time, I cannot recall. But we were [iq manufacturing chlorinated phenol, not chlorinated [i3] biphenol, [ra Q: So at this time Monsanto was manufacturing [is] chlorinated phenol, is that Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 81 - Page 85 HARTOLDMONOO11004 Deposition of DAVID WOOD NOVEMBER 9,1995 correct? nl A: I just said -- I just said I cannot recall (i7i whether Monsanto was manufacturing chlorinated [is] phenol at this time. [i9] Q: I understand. So there was a time when [to] Monsanto manufactured chlorinated phenol, is that pu right? [22i A: There was a time! And the start of that [23i time and the end of that time -- I was never [24] associated with the chlorinated phenol product line psi in Europe, and the dates that we were involved with Page 86 [i] that business, I don't recall and have no direct pi knowledge of. pi Q: Did Monsanto ever manufacture chlorinated w biphenol? [3] MR. CHAMBERS: I object to the form. He i just said -- . pi A: No. No. No. No. He asked if we [si manufactured -- first he asked if we manufactured pi chlorinated phenol. [io] MR. CHAMBERS: Correct. [in A: And I said we had. [i2i MR. CHAMBERS: Correct. [i3] A: And I couldn't remember the dates between [i4j which we manufactured it. [13] MR. CHAMBERS: Correct. [16] A: He then asked had we ever manufactured (17) chlorinated biphenol. [is] MR. CHAMBERS: Correct. I understood your [i9i testimony from earlier to have -- that you stated [201 sometime a few moments ago that Monsanto had never pu manufactured it. [22| A: We had never manufactured a biphenol [23] chlorinated product. [24j MR. DUFF: Thank you. [23] A: Sony. I misunderstood the level of where Page 87 [1]you were. .- [2] MR. CHAMBERS: As long as we get it clear, pj that's fine with me. ' I4i A: And this, gentlemen, is an area which is [si difficult to get totally clear, I've found in (q previous depositions. pi MR. DUFF: Well, we'll attempt to do so. Pi A: We welcome that. [9] Q: So when Mr. Palm used the phrase in the [io] first paragraph of his letter polychlorinated [ii] biphenol, you did not -- strike that. When Mr. Palm [13 used the term polychlorinated biphenols in the first [i3] paragraph of his letter, you knew at that time that [i4i that Monsanto did not manufacture a product which [151 included polychlorinated biphenols, is that right? [i6] A: I'm going to have to ask you, Mr. Duff, to [17] be very careful as we go through this particular bit [is] in terms of the way you pronounce biphenyls and [13 biphenols. Okay? [201Q: I'll try and put the -- pu A: For the tape, if nothing else. It can get (22ivery confusing and it's rather important. TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [23] Q: Let me restate the question for you. At the [24] time that Mr. Palm wrote you this letter on November [23] 28, 1966 and referred in the first paragraph of his Page 88 in letter to a group of products called polychlorinated [3 biphenols, you knew at that time that Monsanto did pj not manufacture any such product, is that correct? W A: No. I knew that we did not sell any [5] chlorinated biphenols in Europe. I didn't know [6] whether another part of Monsanto in the States might pi ever, or at that time have manufactured a pi chlorinated biphenol. I knew we had been involved p] with phenol, I knew we had been involved with other [io] cyclical compounds. No. But I didn't know -- I [in was just concerned that we had some trouble here in [12] terms of some terminology. I did not know what the [13] article in the Swedish newspaper was really about. [14] Q: So, at the time that you received this [13] letter from Mr. Palm and he referred to ni polychlorinated biphenols in the first ............. paragraph of [17] the letter, you knew that Monsanto did not sell |isi polychlorinated biphenols in Europe at this time, is [13 that right? [20] A: That's correct. [21] Q: And as far as you knew, at that time [22] Monsanto had never sold polychlorinated biphenols in (23] Europe, is that right? [24] A: That's correct. [23] Q: Directing your attention again to the third Page 89 in page of Mr. Palm's letter, he also told you in the ra penultimate paragraph that, quote, we probably will pj have to register -- excuse me. Let me read that [41 again. He told you, _ quote, we probably will have to [51 have Aroclor registered with the Swedish Board of [6] Poisonous Substances and the industry will have to pi be particularly careful in handling the material, [8] correct? (3 A: That is what he wrote. I didn't agree with [io] what he wrote. (in Q: But based on what he wrote, you understood [13 Mr. Palm to be assuming that the subject of the [i3] Swedish research was polychlorinated biphenyls which 04i was manufactured by Monsanto at this time, is that [is] correct? [i6] A: I assumed that he had made a mental leap. I [13 thought he was being very responsible in reporting [is] this event to us, and determined in my own mind that (13 this was something that we had to find out what the (20] Swedish researchers were talking about, was it or pi] was it not associated with a product Monsanto [23 manufactured, along with other manufacturers in [23] Europe at that time, and to determine what would be [241 an appropriate course of action depending on the psi substantive nature and supportability of the Page 85 - Page 89 Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONOO11005 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY work Page 90 in that the Swedish people were reporting, if, indeed, pi it were related to a product that Monsanto [3] manufactured. [4] Q: Are you aware of any other substances that [5i were manufactured by Monsanto at this time that were m registered with the Swedish Board of Poisonous pi Substances? [8] A: No. pi Q: So this would have been a first if Mr. Palm [loi was correct, is that right? [i u A: If Mr. Palm were correct, then -- and if, [12] indeed, the products that were being found in Sweden [13] had been our products or had been chlorinated [i4] biphenyls, at which time they could have been -- [is] and probably, you know, had to have been somebody [iq else's chlorinated biphenyls, then should they be [171 registered with the Swedish Board of Poisonous [is] Substances, because DDT would have been so [i9i registered, but we were not selling material as a [201 pesticide, so this letter was full of suppositions pi) which foundations had to be established around for [221 Monsanto to determine what was the appropriate [23] course of action. 124] Q: Sitting here today with the benefit of pq hindsight, you know now that Mr. Palm's supposition Page 91 [il that Monsanto's Aroclors were-- strike that, pi Sitting here today with the benefit of hindsight, biyou know that Mr. Palm's supposition that [4| polychlorinated biphenyls were the subject of the pi Swedish study was correct, is that right? ra MR. CHAMBERS: I object to the form, ra A: I'd like the question repeated, because I [8i thought you got it wrong the first time and I think [9i you got it wrong the second time. But I'd like to [ioi answer the question. [in MR. DUFF: Could you please repeat the [121 question. [13] (The requested portion of the (i<q record read by the reporter). [i5i MR. CHAMBERS: Same objection. But you may [i<si respond if you're able to. [i7i A: I can't say that his supposition was [i8] correct. [i9] MR. DUFF: And how was he mistaken? poi A: Well, again. I'm trying to wend my way back pij through a very detailed question. I mean, if, pq indeed, chlorinated biphenyls were what Soren Jensen [231 had found, were they of Monsanto or a European iw competitor's manufacture as prime polychlorinated psi biphenyls, had they escaped into the environment or Page 92 in been detected through ineffective sampling in the pj particular series of studies which Soren Jensen pi carried out, a number of, still, hypothetical [4] things. So, no, even in hindsight, I still have to [5] maintain the Deposition of DAVID WOOD NOVEMBER 9, 1995 position that what I gained from here [i was evidence that something had been found in Sweden pi and it was appropriate that Monsanto found out what [8i exactly had been found in Sweden, and on the basis pi of that discovery, talking scientist to scientist, [ioi could we then determine what action, if any, were [innecessarily related to Monsanto's actions in the [121 Swedish marketplace. We certainly couldn't talk to [i3jthe French, Italian or German producers' position. [i4i Q: Are you aware if polychlorinated biphenols [151 were ever discovered as accumulating in the [lq environment in Sweden? [17] A: No. [is] Q: The article that Mr. Palm translates for you [i9i in his letter of November 28, 1966 describes the poi substances that were the subject of the Swedish pi] research, is that right? [22] A: The letter describes some statements that [23] were made in the media, accurately reported or not, m of what was reported to the media, about the psi presence of a class of substances which they used Page 93 in the term PCB, which I want to emphasize was not [2i currently in use at that time anywhere in the world pi related to polychlorinated biphenyls. It uses the [4] term PCS to describe polychlorinated biphenols, a [5i class of chemicals with which I was not familiar, [i and describes some applications of these materials, m which I don't know what the source of that ra information was. So, again, my analysis of the pi report in this letter was, again, as I stated [ioi earlier, that there's something going on here on related to a class of chlorinated compounds which [121 seems to be an industrial use, and as a supplier of 03] a chlorinated material in industrial use it behooves [14] us to find out what it is these people are talking [i5] about as scientists, what they have done, and what [ii they have determined. [i7i Q: In this letter you learned from Mr. Palm [is] that the Swedish paper that he was translating for (i9i you indicated that the substance that was the [20] subject of the Swedish research was not manufactured pij in Sweden, but was used in the industry. What did [221 you understand him to mean by that? [23j A: That the -- whatever chemical it was that [24i they were talking about was not manufactured in [251 Sweden and that it had industrial rather than .Page 94 in agricultural uses. pi Q: How were phenols used in the Swedish timber pi industry at this time? [4i A: I don't know. [5i Q: Do you know that they were? [61 A: I can't answer the question as you asked it, pi because you relate to -- you asked me if phenols cbi were used, you did not say Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 90 - Page 94 HARTOLDMONOO11006 Deposition of DAVID WOOD NOVEMBER 9, 1995 chlorinated phenols. I [9] do not know of applications of phenol in timber, [io] then or now, but, then, I've not really been widely [in exposed to agriculture. Do I know that chlorinated [i2] phenols were used in the timber industry? Yes, they [i3i were extensively. Were they being used in Sweden at [i4] that time? I don't know. [15] Q: Are chlorinated phenols considered to be [16] poisonous? [17] A: They became to be considered as poisonous. [i8] What their consideration was in November of 1966,1 [i9] don't recall. [2D] Q: Are chlorinated phenols closely related to pu DDT, chemically speaking? [22] A: As closely as chlorinated biphenyls are. [23] Q: Would phenols break down considerably slower m than DDT? PS] A: I haven't looked at the biodegradation rates Page 95 in of chlorinated phenols. p] Q: Do you have an understanding? P] A: I would expect them to -- a heavily [4] chlorinated green structure would be normally fairly [5] slow to break down. The fact that chlorinated tq phenols had a wide currency of use as timber pi preservatives with long life said that they would pj break down slowly. So, chlorinated phenols would [9] tend to be fairly slow in breakdown. [io] Q: Would phenols -- strike that. Would [in chlorinated phenols give rise to damage of the liver [i2] and skin? [i3j MR. CHAMBERS: I object to the form. [i4 A: Well, I don't know. I was never heavily [i5] involved with chemistry or the commercialization of [iq chlorinated phenols. [i7] MR. DUFF: Do you know if chlorinated [isi phenols were used as a herbicide? _ [19] MR. CHAMBERS: I object to the form. --- [20] A: I was never involved actively with the pu commercialization of chlorinated phenols, so when p2iyou say was it used as herbicides, no, I said I knew p3i that they were used, as many people know they were paused, in the timber preservation area. [25] MR. DUFF: Do you know how they were used in .___________________ _Page 96 [i] the timber preservation area? PI A: Coated, as a paint, as a type of stain to pi preserve the timber. And that's not just timber in m the forest, I -- [siQ: Do you mean preservation of timber for use [] of wood in products such as iumiture, is that what m you mean? pi A: No, I don't. No. I mean -- I don't know pi where your beautiful home is, but if you have a deck (i<q on it and you had built a deck with pine, then up pu until some years ago I could almost guarantee that [i2]as a prudent house owner your deck would have had [i3] chlorinated phenol protection of your deck, so TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY that [M] your fine home did not fall apart around your ears [i5i after five years. [i6] Q: So, did chlorinated phenol serve as a [i7] sealant or something along those lines or was it -- [is] did the serve some other -- [i9] A: Wood preservative. If you go to your local [20] timber store, I'm sure they'll have cans of stuff pi] today which they will call wood preservatives. Now, [221 I'll pretty well guarantee you that they don't [23] contain a chlorinated phenol, but, I mean, you are [24] using it. And if you are an owner of a home with [25] deck or exposed wood, be it fence work, fence line, Page 97 in that you will normally add a timber preservative. [21 That is not normally as a sealant, it's a sealant, a pi moisture repellent tends to protect against beatle [4] eating and all these sorts of things. [5] Q: But it wasn't -- chlorinated biphenols were [6] not used as a herbicide, is that right? Pi MR. CHAMBERS: I object to the form. Pi A: Which product are we talking about? I------ ----said, [9] you've got to take me -- be patient with me. [io] MR. DUFF: Certainly. Let me try and ask [it] the question again to make it clear for the record. [12] Chlorinated biphenols were not used as a herbicide, psi is that correct? [14 A: I don't know. [15] MR. CHAMBERS: I object to the form, because pq that's been asked and answered and the witness has im said he doesn't know, and let's move on. ns] MR. DUFF: Well, the record will reflect [191 what the record will reflect, pq MR. CHAMBERS: Let's quit repeating what pn we've covered and let's move forward, please. [22] MR. DUFF: You may answer. [23] A: I still, five minutes or so later, still pq don't know whether chlorinated biphenols were ever psi used as a timber preservative or herbicide or -- I ;Page 98 [i] said I'm not familiar with the commercial pi application of chlorinated biphenols. And that's pi what I said some little time ago. w Q: Do you know who manufactured -- strike pi that. Do you know who manufactured polychlorinated [q phenols in 1966? p] A: No. [8] Q: Do you know if chlorinated phenols were m manufactured in Sweden in 1966? no] A: No. [in Q: Do you know if chlorinated phenols were ever 1121 used in the manufacture of heat resistant materials? [is] A: Okay. I'm going to have to -- there is a [14 product called bisphenol. I'm not just trying to [151 obfuscate things here. B-i-s-p-h-e-n-o-l. And pq bisphenol as a central molecule could be in\ chlorinated. Bisphenol is _ -- : . ~ ~ :' ^ . " ' ,. ; si Page 94 - Page 98 Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONOO11007 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY used in making thermally [is] resistant resins. So, this is part of the confusion [i9j that this letter engaged my mind in at the time I po] got it, and it's still clear to me today that we pi) have somebody translating something into English and [221 is using terminology, and I don't know -- I'll go [231 back to a straight forward comment I made earlier, 1124]don't know whether he's talking about something pq which is genuinely related to a product that Page 99 in Monsanto makes or not. All I know is that my pi interest is engaged that we should find out what the pi Swedish researchers are talking about. [4i Q: Do you know if bisphenol was manufactured in [5] 1966? [6] A: Not for a fact, no. I believe it was, pi but - pi Q: Do you know who manufactured bisphenol? [9] A: I believe Monsanto did even at one [101 particular point. I believe General Electric [in manufactured bisphenol. But I said, you know, other 1121 than that broad data, I know that bisphenol existed [13] as a chemical in commerce and so, again, it just -- [14] there is enough vagueness and confusion about the [i5] article, the translation of the article and the [iq suppositions that Mr. Palm chose to place that I [incouldn't draw any concrete conclusions. I only [is] wanted to find out what the generators of the [i9j report, the Swedish scientists had done and what m they had reported and not how how their report had pij then been changed, contaminated or distorted by any [221 sense by the way that it was handled from that point [23] forward. That's where bad science creeps in. [24] Q: Do you know if chlorinated phenols were used pq for electrical insulation at this time? ;" [i] A: No. Page 100 pi Q: Do you know if chlorinated phenols were used p] for fireproof heat transported hydraulic oils? 141 A: No. Pi Q: Do you know if chlorinated phenols were used iq as lubricating oils to be used at a high temperature [7] and pressure? [8] A: No. [9j Q: Do you know if chlorinated phenols were used [ioj as paint, or in paint? [in A: I know that they were. mi Q: Do you know if chlorinated phenols were used [13] as pigments in plastics? [i4] A: No. [is] Q: You don't know, is that what your answer is? [iq As I don't know whether they were or they [i7] weren't. As I was not aware that chlorinated [i8i biphenyls were used in pigments in plastics, [iq Q: Are you familiar with a man named Dr. A.V. [20] Holden of Scotland? Deposition of DAVID WOOD NOVEMBER 9, 1995 pi] A: No. [22] Q: I'd like to direct your attention again to [23] the penultimate paragraph of Mr. Palm's letter. In [24] this paragraph he states, quote, "I understand that psi there hardly exists a convenient method of Page 101 [1] destroying Aroclor and that possibly burying [2] unusable material may be the only answer". [3] Unquote. Is that correct? 14] A: That's what he states in his letter. [5]Q: Was that consistent with your understanding [q regarding disposal of Aroclor at that time? Pi A: At that time, our recommendation for [8] disposing of spilled polychlorinated biphenyls was [9] to stabilize it by absorption on to diatomaceous [101 earth and then containment and then burial. [11] Q: Is that diatomaceous? [12] A: Oh, boy, here we go with my spelling. [13] D-i-a-t-o-m-a-c-e-o-u-s. [14] Q: And what is diatomaceous earth? [iq A: A highly absorbent clay material. [iq Q: Is it also sometimes known as Fullers Earth? [17] A: Fullers Earth is a highly pure form of [iq diatomaceous clay. I would not necessarily use [i9] Fullers Earth as an absorbent for burial purposes, m There are some slightly more economical diatomaceous pu earths available. Fullers Earth was used in [221 processing dielectrics as a purification media, it [23] was a highly pure material. [24] Q: Where would one obtain diatomaceous earth in pq 1966? Page 102 [i]A: Oh, all over the place. It was readily -pj available. p] Q: Would one dig it up on their own property or [4] purchase it from a vendor? iq A: No, you'd purchase it from a vendor, tq Q: In 1966 did you recommend to your dielectric m fluid customers that they use diatomaceous earth in [8] disposal of spilled fluids? p]A: Yes. [ioj Q: Please mark this as Exhibit 274. [ii] ( Plaintiff's Exhibit 274 [12] marked for identification). [13] MR. DUFF: Mr. Wood, I'm handing you a [14] document that's been marked as Plaintiffs Exhibit [tq 274. It bears production number STR 017390. Do you [iq recognize this document? [i7] A: Yes, I do. [iq Q: Could you please identify this document for [19] the record? poi A: Yes. This is a letter that I wrote from pi] Brussels on the 1st of December 1966, and this was [22] addressed to George Buchanan in St. Louis. So, I [23] spoke in error earlier when I said I wrote to Paul 1241 Benignus, I wrote to George Buchanan. Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 98 - Page 102 HARTOLDMONOO11008 Deposition of DAVID WOOD NOVEMBER 9,1995 [25i Q: Do you recall if you called Mr. Benignus ;Page 103 in prior to writing this letter to Mr. Buchanan? pi A: l don't. pi Q: And by this letter on December 1, 1966 you [4i sent Mr. Buchanan a copy of the November 28, 1966 [5] letter that you had received from Ola Palm, is that [6] correct? Pi A: That's what I said. [8] Q: In fact, that's what you did, is that pi correct? (loi A: Yes. [iilQ: Who is Mr. Buchanan at this time? [i2i A: Mr. Buchanan was one of the senior [isj executives in the fluids group, and was a supervisor [i4i of Paul Benignus. [15] Q: Was Mr. Buchanan the director of the lie) functional fluids group at this time? [i7i A: I don't remember what his role was, 8] exactly. There were a couple of changes going on in [i9] the U.S. organization. The precise role that George [201 had at that point in time, I don't recall. ................. --........ ...... pu Q: Was Mr. Buchanan the most senior person with [221 whom you were familiar in the fluids group at this P3i time? BA A; No. [25] Q: Who was senior to Mr. Buchanan? Page 104 in A: I said, you know, this is what -- I think pi Mr. Cunningham was senior to Mr. Buchanan. Mr. pj Buchanan, I seem to recall, had been in Europe that [4] summer, and so since I hadn't sent this to Paul, I [5] sent it to George because he had been in Europe the [<si most recently. pi Q: And in this letter to Mr. Buchanan, pi directing your attention to the second paragraph, [9] you wrote to him, quote, "Based on the [io] recommendations made by our - medical departments we mi shall have to decide whether to arrange for [^publication of data in Sweden or not". Correct? [is] A: I say that in the second paragraph. [Mi Q: What did you mean by that? [15] A: I meant that once we found out exactly what [i6i it is that the Swedish scientific community is [171 talking about, if it were to turn out that it is a [is] polychlorinated biphenyl, then we will have to [i9j consider publishing the appropriate medical [20] background information that we have, so that there pi] is a factual record of what polychlorinated pzi biphenyls do or don't do. But, as I said, but that [23] will be based on the recommendations made by our [241 medical departments, and depending on what we find [25] out about the accuracy of the research work being ;Page 105 in done in Sweden. I mean, I think it makes it quite [21 clear if you -- I would like, in responding to that pi last question, to comment on my ps, where I relate [4] back to the fact TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY that, you know, are we indeed [5j talking about products with which we are associated [6] or are we talking with the outcome of release of pi much larger quantities of pentachlorophenol and [s] sodium pentachlorophenol from the industrial timber pi cultivation in Sweden. Very large industry in [101 Sweden is timber, mi Q: What were the recommendations that were made [121 by the medical department? [13] A: Find out what the people in Sweden are [14] talking about. ns] Q: When were those recommendations made? [i6i A: I, probably at the same time as I was [17] sending this letter to George Buchanan, and after [i8i receiving the November 28th letter from Ola Palm, [19] would have talked to D. V.N. Hardy in London, and as [201 my product safety medical advisor in Europe, and [21]before I had written that letter, because when I'm [223 talking about based on the recommendation by our [23] medical department, I'm talking about die European m medical department. .... [25i Q: Actually, I think you use the plural of Page 106 pi departments, did you mean by that both the medical ezi department in Europe and also the medical department pi in St. Louis? [4] A: No. I meant the medical department in [5] Europe. I had a Belgian secretary who inadvertently [6] did make typing mistakes when she was writing pi English letters. [8i Q: And did there come a time when Monsanto did [9] publish data in Sweden relating to polychlorinated [i<q biphenyls? [in As Not in die period that I was involved with [121 the dielectric fluids in Europe. [i3] Q: Are you aware if Monsanto ever published P4i data in Sweden relating to polychlorinated [i5] biphenyls? [16] A: I'm going to have to ask you to clarify what [i7] you mean by published. us] Q: Well, you used the term in this letter. [i9l A: And I can tell you what I meant -- I can [201 tell you what I mean by the term published, but I [21] asked you, in answering the question, so I don't [22j mislead you, what you were asking in your question. [23] Q: That's fair. And I would repeat to you to [24) ask me to clarify if you don't understand [25i something. __________________ Page 107 [i]A: Yes. pi Q: Maybe we can start by, what did you mean pj when you used the word publication in the second [41 paragraph of this letter to Mr. Buchanan? [5] A: When I talk about publication, it's if we [6] reach a point where there is concern in Sweden about pi a product which is a chlorinated biphenyl, and not isi something else, then we would probably need to talk tsj with the Swedish authorities and say do we Page 102 - Page 107 Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONOO11009 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY need to cioi publish in terms of communicate data to the users of mi chlorinated biphenyl in its various industrial [121 applications, do we need to communicate it more [13] broadly to people who are using their products, do [hi we need to communicate information to the public at ns] large. And we would be guided, to a certain extent, [13 by relevant discussions with the Swedish [17] authorities. But, I mean, this would depend on, [is] again, what was really happening in Sweden. Nothing [19] worse than somebody running into a cinema and poj calling fire. I guess that's a theory which you as a pi] lawyer are familiar with. [22] Q: I move to strike the last sentence as [23] non-responsive. After the date of the letter that [24] you sent to Mr. Buchanan, when was the first p5] publication of data in Sweden related to Page 108 . [i] polychlorinated biphenyls? pi A: Repeat the question, pi (The requested portion of the [4] record read by the reporter). [5] A: We had already published industrial hygiene [i data about polychlorinated biphenyls in Sweden in u\ support of the sale of our polychlorinated biphenyl pj products in Sweden. Our competition, equally, had pj published data in support of the use of their um chlorinated biphenyls in Sweden. When did we [ill publish something additionally? I don't know. I [12] mean, did we or didn't we? I'm not saying that we [13] didn't, but when it happened, I don't know. And in [14] what form it took. I tried to clarify a sequence [i5] and scale of events, and - [13 Q: In the third paragraph you wrote, "In [17] relation to the specific problem mentioned of [is] disposal 'of materials, we would be interested to [19] learn how this problem is handled in America". poj Correct? pi] As Yes. [22] Q: I'm sorry, your answer? [23] A: I said yes. [24i Q: How were you informed that the disposal [25] problem was handled in America? Page 109 in A: That they essentially were dealing with the (2| problem in the way that they recommended it be pi handled in the technical brochures that supported [4] our product, which was absorption into absorbent [5] earth. I see I use the term vermiculite or some [3 similar pourous material. But, essentially, in both n cases we're talking about using earth or a pourous [g] material to stabilize the liquid, then encapsulating pj in a drum and then -- you know, what you were [ioi telling people to do in England is, indeed, in line, [in we've not moved further than that at this point in [12] time. [i3] Q: That's what they told you after you wrote [i4] this letter? [i5]A: You asked a question and this was, right on, [13 that's what we tell people to do. [i7] Q: And what was the response to your Deposition of DAVID WOOD NOVEMBER 9, 1995 question [isihas any entirely safe method been developed for [191 disposal of waste Aroclor? [20] A: They -- as I recall, they responded at that pi] point, sort of saying (hat this was the recommended [22] form of disposal at this point in time. [23] Q: And were you told that absorption into [24] vermiculite or absorbent earth was an entirely safe [25\ method of disposal? Page HO [1] MR. CHAMBERS: I object to the form. [2] A: No. I can respond to that question in the pj spirit in which I asked it in the first place. I [4] sort of say in the U.K. many companies were burying [5] materials in drums, having been absorbed in [3 appropriate pourous material. Has an entirely safe pi method been developed for disposal of waste [8] Aroclor? I meant something which totally destroys pj it. And I think that since there wasn't a method, [ioi they sort of said the recommendation for the U.K. is [11] -- did they sort of classify that method as being [12] unsafe or entirely safe? No, they didn't. They [is] said it's appropriate. [i4] Q: So, in asking the question which you have [i5] set out in the last sentence of your letter -- [13 strike that. In answering -- strike that. In asking [17] the question that you set out in the last sentence [is] of the third paragraph of your letter, you meant has (19] any method been developed pursuant to which waste [20] Aroclor could be totally destroyed, is that correct? pi] A: That's what I meant by entirely safe. I [2?] mean, you break it down to its primary carbons and (23] oxygens and -- [24] Q: And the response to that question was that [25] waste Aroclor should be disposed of by absorption ____________________ _____ Page 111 in into vermiculite or another absorbent earth [2] material, is that right? Pi MR. CHAMBERS: I object to the form. Go [4] ahead. [5] A: Well, again, we can keep on answering this [3 question time and time again, if that's what is pj required to impress it. But I was answered that m that was at that point in time the appropriate (9) method of disposal of waste Aroclor. [io] Q: Who is A. Arpino? (in A: Adolph Arpino was a colleague in Brussels [17] who at that point in time was part of my sales (13] group. He was selling Aroclors. He was an Italian [i4] living in Belgium. [is] Q: Excuse me. Did you finish your answer? (13 A: I believe I did. Just before you -- I don't [i7] know whether you heard it over Kevin's interruption, [is] You did? Good. [i?i Q: Why did you send a copy of this letter to Pol Mr. Aipino? pi] A: Because Mr. Arpino, as I was assuming more [221 of the product management role in Aroclors, was to [23] have a greater involvement Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 Page 107 - Page 111 HARTOLDMONOO11010 Deposition of DAVID WOOD NOVEMBER 9, 1995 in the sales to the [24] Swedish marketplace, and, therefore, it was good psi communication to make sure that he was aware of what Page 112 [i] we had just heard from Sweden. pi Q: And you also sent a copy of this letter to Pi Dr. Emmet Kelly in St. Louis, correct? [4] A: Yes, I did. [3] Q: What was Dr. Emmet Kelly's position at that [q time? [7] A: He was the medical advisor to the Monsanto [si group in St. Louis. Pi Q: Was he also the director of the medical no] department at that time? [ii] A: Yes, he was. I copied him at the suggestion [iziof Dr. Hardy in London. [13] Q: And, in fact, you sent a copy of this as [14] reflected in the top of this letter to Dr. Hardy, is [is] that correct? [mi A: Yes. I think it would have been [i7i inappropriate had I talked to him and then taken [is] action on his suggestion and not let him know what I [i9] had done. [20] Q: So after you spoke - I'd like to just step pi] back a minute here. After you spoke with Ola Palm pn and received the letter from Ola Palm, you then p3] spoke to Dr. Hardy, is that right? [24] A: Yes. Yes, I did. [25i Q: And was that a face-to-face meeting between Page 113 myou and Dr. Hardy? in A: No. He was in London, I was in Brussels. pi Q: So, did you call Dr. Hardy or write him a [4] letter? [5] A: Yes, I did. No, I called him. [61Q: And what did you and Dr. Hardy discuss in p] that phone call? Pi A: The fact that I had received this report.[9] Did he know anything about a Swedish study. No, he [to]didn't. What were the implications. And got his [ii]response, "David, you're doing exactly the right on thing we need to find out what this is all about". [13] Q: What were the implications that you and Dr. [i4] Hardy discussed? [iq A: I asked him for guidance. I was fairly new [i<] to product management in Monsanto, and I sort of [in said look, we've got a report from a country which [is] reports finding a product that we, amongst other [19] European manufacturers, supply to that country, it's po] not clear whether they really are talking about our pi] product or not. If they are, then -- and, indeed, [221 they are finding it, then what's our understanding [23] of how this could have entered the environment. You [24] know, tell me what I should be doing as good psi practice at this point in time to follow up on this ;Page 114 [i] loose and wooly report from Sweden. And his pi recommendation was find out what the TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY scientists are pj talking about. [4] Q: And then he recommended that you send a [5] letter to Mr. Buchanan, is that right? [61 A: No. He recommended that I report this to pi St. Louis, and whoever I chose to send it to in St. p] Louis, that I copy Dr. Emmet Kelly, who was his [9] opposite number, essentially, or senior opposite [ioj number in St. Louis, so that he would have the [uj benefit of saying David talked to me and he kept you [121 informed, also, of what he had heard from Sweden, [i3]and let's discuss this. [i4] Q: You also copied R. A. Steenrod? [is] A: Yes. [16] Q: And who was R. A. Steenrod? [17] A: Dick Steenrod was in a position in the [is] fluids group at that time not unsimilar to that [i9] which I assumed when I went to St. Louis much later, poiin 1974, of having an international type of pi] responsibility, so that -- [22] Q: Was he the international marketing manager p3] for fluids? P4| A: I can't comment whether he was international [25] marketing assistant or international marketing Page 115 [i] supervisor, but he had an international p] responsibility for some international coordinating, pi If I were to want a series of new bulletins or ta something like that, I would probably go to Steenrod [5] to ask him for that, and, therefore, as a courtesy, [6] since he was another of my regular contacts on the [7] business in Europe, as reporting back to the U.S., I pi had no reporting responsibility or alignment to pi Steenrod, but as a courtesy we tried to work as a [ioj team and keep each other communicated with. [in Q: Please marie this as Exhibit 275. [12] ( Plaintiffs Exhibit 275 [13] marked for identification). [14] MR. DUFF: Mr. Wood, this document has been na marked as Plaintiff's Exhibit 275. Please take a [i] moment to review it. For the record, it bears [17] production number TRAN 056624. Have you had a [isi moment to review this document? [i9i A: Yes. pa Q: Can you identify that document for the pi] record? p2] A: This is a letter from Dr. Emmet Kelly in St. p3] Louis, dated December the 12th, in response to his pa copy of my letter to George Buchanan of the 1st of p5] December that we reviewed. Page 116 [i] Q: This is in 1966 as well? pi A: It is in 1966, yes. PiQ: I'd like to direct your attention to the [a third paragraph of this letter. In this paragraph is] Dr. Kelly wrote to you, quote, "There are many (a chlorinated polyphenyls that can be formed during n the manufacture of 2,4,5 T and probably m pentachlorophenol as well", Page 111 - Page 116 Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONOO11011 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY correct? 19) A: Yes. You read well, tio] Q: He went on to say, quote, "Our only problem nu is whether or not we want to bring these facts up [121 and have our herbicide program receive another black [i3j eye. This I will leave to your judgment". Correct? [hi A: That's what the letter states. [is] Q: What did he mean by the last two sentences? [ii MR. CHAMBERS: I object to the form. [i7) MR. DUFF: Were you familiar with how [isi Monsanto's herbicide program had received a black [i9] eye previously? I2oiA: No, I wasn't. pi] Q: So you did not know what Dr. Kelly was pa referring to here, is that right? [23] A: That is correct. [24] Q: But he was telling you that there was [25] something he was going to leave to your judgment, is Page 117 [i] that correct? [2i A: That was obviously an assessment which he (3) made erroneously, because I wasn't in a position to (4imake that judgment. [5] Q: Did you contact him after you received this [6] to tell him that you didn't know what he was talking m about? [8] A: I can't remember what action I took next. [9] It will probably emerge from the record. But I [ioj really can't remember whether I took him up on that [i i] one, because it seemed, again, to be saying, again, inhere -- the most important point in this letter to [i3] me as I read it was -- [i4] Q: Actually, that's not the question I asked, ns] A: Oh, okay. Then we don't want to get what we (ii intended by this. Okay. I'm sorry. Did I answer [i7] your question? I start rambling. I think I did. :_ [is] Q: I believe so. Let me just ask -- let me [i9ijust ask this question and then if -- maybe it's [20] sufficient to move on after this. I guess you said pijyou didn't recall what you did after you received tm this letter from Dr. Kelly, is that right? [23] A: That's correct. No, it's not correct. I'm 124] sorry, I can't allow that to go. Because my [25] previous answer was responsive, because you asked me _Page 118 [i] if I recalled what I did when I got this, and [2j Q: In the context of the third paragraph, pi A: I essentially ignored the third paragraph [4] and concentrated on the fourth paragraph, which [5] suggested we find out what the Swedish scientists [4 were talking about. piQ: Okay. [8] A: So I did what I responsibly previously P] considered I should be doing, discounting the fact [icq that I couldn't help with paragraph three. Deposition of DAVID WOOD NOVEMBER 9, 1995 [in Q: And were you the person in Europe primarily [121 -- strike that. Were you the person within [i3] Monsanto who was primarily responsible for [14] determining what the Swedish study related to? [is] A: No. [16] Q: Who was? [17] A: This was a joint responsibility of myself [is] and Dr. Hardy. [i9i Q: So were you and Dr. Hardy - [20] A: And it would include, in my area of [2ij responsibility, that I include some of our research [221 department. I mean, so, ultimately, as product pn manager, just to make this clear, the product m manager role in a company such as Monsanto, you have psi an overall accountability for the product line. So, Page 119 [ljwas it my responsibility? Yes. Could I do it pi alone? No. Who had to be involved? Myself and pi some of my colleagues. It was my accountability to [4] make sure I got them involved. [5] Q: At the end of 1966, after you had received [6] the correspondence from Mr. Palm, did you undertake pi to research scientific publications to see if there [8] had been anything else published in this area? [9] A: Personally, no, I did not make that [ioj undertaking that I would make that study. I [in undertook that I would have people within Monsanto [121 ask some questions around their networks in this [i3j scientific community and see if there had been other [14] work done of a similar nature. Particularly Dr. [151 Hardy. [16IQ: So, was Dr. Hardy given the responsibility [i7] to see what other scientific publications were [isi saying on the subject of chlorinated compounds (191 accumulating in the environment at this time? pa] A: Was he given the accountability? No, he pi] assumed and undertook that he would. And I think 1221 further correspondence that we may come across will [23] show that he did that. [24] Q: Was it your understanding that that was [25] something that he was going to be responsible for? Page 120 [1]A: Yes. [2] Q: Who was responsible for seeing what play the pi Swedish study received in the press and scientific [4] publications? [5] MR. CHAMBERS: I object to the form. (6i A: I don't think we undertook, in the terms t7] that you're using, to sort of say what play the [8] press will make. I was certainly alert, and I [9] talked to colleagues, I said this is a strange nog article, and I was still categorizing it as this [u] strange article appeared in Sweden and we're trying [121 to get more information about it. If you see [i3j anything in the press elsewhere, please bring it to [14] our attention. But to use the phrase that you used, [i5i what play was being put on this, no. I mean, that's Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 Page 116 - Page 120 HARTOLDMONOO11012 Deposition of DAVID WOOD NOVEMBER 9, 1995 Ii6i not the way we worked. We weren't coming from any [17j position of playing, this was -- li8] Q: Let me use a different word maybe this will {i9] make my question more clear. Was anyone within poi Monsanto monitoring or following the publicity that pi] was given to the Swedish work? [22] A: I was -- I had asked Ola Palm to let me [23] know if there were any follow-up articles or [24] anything else published in Sweden as a result of the ps] article. There was no concerted European-wide ^_________________________ Page 121 in program to monitor the public media channels. I pi know that Dr. Hardy, in terms of his discussions p] within the U.K. technical community, intended to n sort of ask people if they were aware of any other [S] scientific publication which related to the [6] ' Jensen-Widmark work. P] Q: Did you read scientific publications as a [8] regular part of your business at this time? ctA: I'm going to ask you to be a little........... clearer [io] in defining scientific publications. There are a mi range of levels of scientific publication. . [12] Q: Was it your habit to read technical journals [i3j on scientific issues during the period 1966? [14] A: I would routinely read Chemical Week, [15] Chemical Engineering News. I would read trade [i6]journals associated with the electrical industry. I [i7] would read New Scientist. I would read Nature. As [ig] a genuinely interested person who had received an [i9] education and training as a scientist. Did I read [2oi the Monthly Journal of Medicine, transactions of the pi] Cambridge Physics Society? No. So, I'm trying to pzifypify, _ characterize my reading habits in a range of pa] low tech to highly technical professional pq magazines. P5] Q: Let's mark this as Exhibit 276. ;_________________________ Page 122 Hi ( Plaintiff's Exhibit 276 pi marked for identification). PI MR. DUFF: Mr. Wood, this document has been m marked as Plaintiffs Exhibit 276. For the record, p] it bears production number TRAN 056625. [6] A: Yes. P) Q: Do you recognize this publication? [Si Ar I recognize the name of the publication PI noted at the top. I don't recognize this particular [io] page of that publication. [ii]Q: Do you recognize the handwriting at the top [i2] of the page? [13] A: No, I don't. [14] Q: And do you recall this particular article [is] that appeared in New Scientist on December 15, 1966? [iq A: No, I don't. [i7] Q: What was your opinion of New Scientist TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [is] magazine in December 1966? [19] MR. CHAMBERS: I object to the form. [20] A: I believe that it was, in scientific pi] integrity, somewhere middle of the road. They [22]weren't always accurate. Did they do a fairly good [23| screening of other publications, both above them and p4] below them on the technology scale to see if there pq were areas of scientific interest? Yes, they did. Page 123 [i] So, they were not the most impressive magazine in [21 the area, but I found them useful in keeping p] up-to-date with some new and different thinking. [4] Q: And this was one of the publications that [5] you read regularly at this time, is that correct? [6i A: I didn't take -- I was not a subscriber. If [7] I saw a copy around the office, I would tend to [8] browse it. So I'm not a faithful reader, but -- CT Q: Do you know if Monsanto subscribed to this [io] publication? iii) A: No, I don't.---------------------------------- ------- [121Q: I don't mean this to be redundant over the [13] last question, but what type of articles would New [14] Scientist publish in 1966? [i5i MR. CHAMBERS: I object to the form. [i6] A: I didn't read them frequently enough to be [i7] able to categorize types of articles at that period [is] in time. I'd be sort of misleading you if I said I [19] did. [20] Q: Do you disagree with the description of the pi] Swedish research as it's described in this [22] publication? [23] MR. CHAMBERS: I object to the form, pq A: like I said, I've never seen this before, ps] Okay? So, I mean, you want me to spend time now, Page 124 [i] read it and tell you whether today I disagree with p]it? I couldn't have disagreed with it then because [3]I didn't see it then. Where do you want to go with w this? [5] Q: I'11 ask you another question. [6] A: Please. pi Q: Please mark this as Exhibit 277. [8] ( Plaintiff's Exhibit 277 [9] marked for identification). [io] MR. DUFF: Mr. Wood, this document has been [ii] marked as Plaintiffs Exhibit 277 and bears [121 production number TRAN 056035. [13] A: Yes. . [14] Q: Are you familiar with this document? [is] As No. [i6] Q: This document is dated December 29, 1966, [i7] correct? [is] A: That's the way it's dated. [i9i Q: Do you recall if you've seen this document poi before? pi] A: I know I haven't. [221Q: Were you aware that -- is it Gunnar Widmark [23] visited Monsanto in St. Louis in 1965? . Page 120 - Page 124 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11013 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY (24) A: I was not aware of that. (25i Q: Did I pronounce that name correctly, do you dlknow? Page 125 p] A: Gunnar. He would have probably used avid, pi V sound, "Vidmark". W Q: Do you know what the phenolic composition of [5] TCP means? [6i MR. CHAMBERS: I object to the form. Pi A: I know nothing about this letter. I don't pi know what the subject of the meeting with Mr. Ford [9] was. [ioi Q: Do you know who Mr. Ford was? mi A: I don't. I mean, over my career with [121 Monsanto I'm aware of certain gentlemen by the name [131 of Mr. Ford who worked for Monsanto. Which this [i4] particular one was, I don't know for sure. [is] Q: Do you know what TCP is? ` [i6] A: I associate TCP with a phosphate chemistry. [12] Q: And what phosphate chemistry do you [is] associate that with? [is] A: Tricresyl phosphate. [20] Q: Did Monsanto use tricresyl phosphate in any (21] of its functional fluids at this time? [22i A: I don't think we did. And that's why, you [23] know, I'm a bit thrown by this. [24i Q: Do you know if Monsanto used tricresyl [25] phosphate in any of the products it manufactured at HI this time? Page 126 pi A: No, I don't. Pi Q: Were you aware that employees of Monsanto [4] had furnished Widmark with samples of Monsanto [5] material for purposes of conducting analytical iq investigations? m A: And again, I have not had a chance to read pi this and see what samples he claims to have received [9] or asked for or what. [ioi Q: I understand that you earlier testified you [inhadn't seen this document before, so I'm going to [121ask you independent of this document if you were [13] aware that employees of Monsanto furnished Widmark [14] with samples of Monsanto material for the purpose of [i5i conducting analytical investigations? [i6] A: No. " [ioi Q: Who was Gunnar Widmark? [is] A: Gunnar Widmark was either a full professor [191 or an adjunct professor at the Carolinska Institute [201 in Stockholm, and was the person who was supervising bu the work of Soren Jensen, whose name is associated 12% with the report that we've been discussing [23] intermminably. [24i Q: Have you ever spoken with Mr. Widmark? [25] A: Yes, I have. Page 127 in Q: When did you first speak with Mr. Widmark? [21 I'm sorry, is it Doctor or Mr. Deposition of DAVID WOOD NOVEMBER 9,1995 Widmark, do you know? [3] A: I thought he was a Doctor. [4i Q: When did you first speak with Dr. Widmark? [5] A: It was either very late in 1966 or earlyish [6] in 1967. Pi Q: What did you speak with Dr. Widmark [8] regarding? Pi A: About the report that had been published [ioi under the joint authorship of himself as sponsor and [ii] Soren Jensen as researcher. [i2] Q: And do you recall specifically what he said [i3] to you? [i4] A: Specifically, not. I mean, I'm sure I wrote [is] a report of that discussion, but I don't recall [i6i after 30 years specifically the way the conversation [12] went. [i8i Q: Do you recall any of the details of your [19] conversation with him? [20] A: I remember that he -- he was expressing pi] some concern that what he felt had been very good [22] work done by Soren Jensen had been abused for [23] commercial purposes by the people who had helped him [24] with the supply of equipment to the extent that ps\ before they had professionally published the work Page 128 [i] that it had received public review through the pi media, through the newspaper, with Soren Jensen as a [3] less than totally mature scientist making comments [4] in response to questions from the press which lay [5] outside his area of expertise. He was very proud of m Jensen's analytical work and less than proud of his pi publicity. [8] Q: Do you recall anything else that was said in [9] your conversation with Widmark? do] A: I think he made some requests for some [ii] additional samples of isomeric materials which he [12] felt would be helpful in furthering their research [13] efforts. And he asked us if he ultimately would [i4j present -- give us copies of the papers, the [15] scientific background papers, that we not -- that [i] we not publish them, that they be strictly sort of [12] confidential between -- you know, this isn't a [is] question -- as an academic scientist, we could [19] understand where he was coming from. You don't want [20] to do three years of work and then have it pi] pre-published in some sense by another party. [22] Q: And did you make arrangements for him to p3] receive the isomeric materials that he requested? [24] A: No, I requested them, and was advised that [25] these were not readily available materials. And, Page 129 [i] again, I think it needs to be mentioned that when [2] you manufacture chlorinated biphenyls commercially, pjyou take the -- you take benzene and you stick two m benzene rings together to make biphenyl, and then [5] you chlorinate the biphenyl and you get a mixture Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 124 - Page 129 HARTOLDMONOO11014 Deposition of DAVID WOOD NOVEMBER 9, 1995 () that comes out, depending on the temperature and the pi time for which you chlorinate. And that mixture is pi a mixture of a lot of different materials which are [] the two benzene rings stuck together with chlorines [io] attached in various places. What Widmark was [ill looking for was a biphenyl core with chlorines in (121 specific places in specific numbers around that [131 biphenyl core. So Monsanto's commercial production [i4] would never produce such an animal, and you'd have [is] to get into a very sophisticated and special [i6] synthesis to make each and every one differently. [in Q: Was he looking for for pure isomers? [is] A: Yes, he was looking for pure isomers. [is] Q: And Monsanto produced -- [to] A: Isomeric mixtures, pi] Q: Isomeric mixtures, which were characterized [22] by a percentage of chlorination by weight, is that [23] correct? [24] A: Yes. [25] Q: Where there might be variations on the .... ... Page 130 [i] number of chlorine attached to the benzene rings, is m that right? Pi A: A mixture which was categorized as being 54 [4] percent chlorine by weight, which we within Monsanto [3] would designate as Aroclor 1254, would have a [6] mixture of biphenyl with two chlorines on the ring, p] three chlorines on the ring, four chlorines on the [8] ring. Most of it would peak around about five [9] chlorines on the ring. You would then have six [iaq chlorines on the ring, seven chlorines, eight [inchlorines. It wouldn't have much of that percentage [12] that was getting up to sort of the complete [13] chlorination. But there would be a mixture. And if [i4] you consider the number of combinations of putting [is] three chlorines on the double ring, you- know, within ni that mixture there would probably be 10 or 15 [in various forms of the three chlorine on the two [is] rings. So, it was a veiy complex mixture. [i9] Q: Are you familiar with the names that are [to] handwritten on the left -- upper left margin of this pi] document? I'm referring to Exhibit 277. [22] A: I know the -- you're talking -- the first [73] one on this list appears to be J.R. Darby, the [24] second one appears to be F.M. Parks, and the third [23] one I can't make out. Page 131 [i] Qs Are you familiar with these individuals? pi A: I knew of Joe Darby. I never worked with pi Joe. W Q: Who was Joe Darby? [3] A: Joe Darby was for many years involved with (6| Monsanto's plasticizer program, and that's -- when I pi was looking at this letter and I saw they were ra talking about TCP, because the tricresyl phosphate [9] had some currency at that point in time as (ioj plasticizer TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY products, and so that's why -- this is (111 a _ whole different department within Monsanto ' and, (i2| boy, I mean, here we seem to have a r classic left (i3]hand not talking to the right hand. [i4] Q: Are you surprised that you did not see this [i3] letter at about the time it was -- [i6] A: Chagrined, perhaps. Surprised, no. I mean, \yn you get a large company like a Monsanto or duPont, a [is] Ford, General Motors, and, you know, these are veiy [19] large organizations, and you wish you could claim [20] that your communications were so strong that you pi] would always sort of be involved in what you need to [22] be involved in. But, am I surprised? No. [23] Q: When you met with Widmark in December of '66 [241 or January of '67, did he mention to you that he had 125] met with Monsanto people previously? ____________ ;________ Page 132 [1]A: No, he didn't. [2] Q: Did he mention that he had spoken with ~ Pi anybody at Monsanto previously? WA: No. .......... ' ....... ............~ [3] Q: When you met with Widmark at that time, did [6] anybody else attend that meeting? pi A: Ola Palm. I didn't know how well Professor pj Widmark spoke English. I assumed that as a well [9] educated Swede that he did speak English. But I, [ioj therefore, did not want to not have Ola Palm there [it] to make sure that we were able to appropriately [12] communicate. [13] Q: Did you meet in Stockholm? [14] A: Yes, we did. [is]MR. DUFF: Why don't we take a break. [i6i (Recess). [in MR. DUFF: Please mark this document as [is]Exhibit 278,1 believe. [19] ( Plaintiffs Exhibit 278 no] marked for identification). pi] MR. DUFF: Mr. Wood, this document ~ has been [221 marked as Plaintiffs Exhibit 278 and bears [23] production number TRAN " 007566. Do you recognize p4j this document? s [25] A: Yes. , Page 133 in Q: Please identify this document for the pi record? ... pi A: This is a memo written by Dr. Doug Hardy of m Monsanto's London office, dated 12th of January [5] 1967, and circulated to a fairly long circulation [6] list, including a copy to David Wood in Brussels. pi Q: You received a copy of this document? pi A: Yes, I did. [9] Q: You received this document on or about ~ no] January 12, 1967, is that right? Let me retract (in that. You would have received this '" document on or [121 about January 16th, is that ' right? " [13] A: I'm not sure whose copy this was, but normal [14] mail from London to Brussels, it ' would -- dated [is] 12th of January, yes, I would have probably received [i6] this about Page 129 - Page 133 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11015 iuii^iujociXi uju rinSUINE DU. VS. MONSANTO COMPANY January the 16th. [i7] Q: Within a few days after it was sent? [181 A: Yes. [i9] Q: By this memo Dr. Hardy told you that a Mr. [2oi Richardson of Shell Chemicals had been working for [2ij some years on a similar problem to the work pj] undertaken by this Swedish study of Soren Jensen, is p3] that correct? [24i A: This reports that Richardson was working for (25) some years on analytical problems related to DDT. ;Page 134 [1] Q: And Dr. Hardy referred to this as a similar [21 problem? pi A: With insecticides such as DDT. The problem w being identification of trace contaminants in (Si species tissues. [i Q: And Dr. Hardy told you in this letter that (7i Richardson had obtained spectrographic evidence that [8] the substances that were the subject of Jensen's pi work were very similar, if not identical, to tiai Aroclors, correct? mi A: He reports that in his work the chlorine [i2] containing residues which he had extracted contained ii3] substances more stable than DDT and that his [i4] experience these materials are similar, if not [is] identical, with Aroclors. ni Q: And Dr. Hardy told you in the second ini paragraph of this letter that Mr. Richardson was [is] quite sure that the compounds reported to be, quote usi polychlorinated biphenols, unquote, are really meant [2oito be polychlorinated biphenyls, correct? PU A: That is the state of mind of Mr. Richardson [221 as reported by Dr. Hardy in this memo. P3] Q: And in this letter Dr. Hardy also told you [24] that he discussed with Richardson the soundness of pj] Jensen's claims and he was assured that Jensen's ^_ _________________ Page 135' in work and findings were sound, correct? [2] A: It is Richardson's view that Jensen's work pi is sound, yes. [4] Q: And Dr. Hardy was assured of that fact, [5] correct? [i A: Dr. Hardy, in this memo, reports what pi Richardson told him. He doesn't -- I didn't see a ra point in here where Dr. Hardy discusses whether he ra is in agreement with Richardson's conclusions. I [101 mean, he states that he discussed with Richardson [in the Soundness of Jensen's claims and was assured by [i2] Richardson that Richardson felt that the work and (131 findings of Jensen were sound. [i4]Q: Were you familiar with Mr. Richardson? [is] A: No. Only -- I was exposed to Mr. ni Richardson's name by Dr. Hardy. [i7] Q: Was this the first time that you had heard [is] Mr. Richardson's name? [Hi A: Yes. poj Q: Who was G.R. Graham in New York? pi] A: Oh, that is Randy Graham, I'm 95 Deposition of DAVID WOOD NOVEMBER 9, 1995 percent pzi sure, who was a salesman in Monsanto's New York [23] office. That's the person that I associate with [24i that set of initials and that name. [25] Q: Who is J.A. Evans in London? ______________________ Page 136 [i] A: That would have been John Evans, one of our [2] research technicians, research scientists. pi Q: Do you know what work John Evans was doing w with respect to the Swedish research? [5i MR. CHAMBERS: I object to the form. But go [6] ahead. m A: I don't believe John was doing any work with pi respect to the Swedish study. (9i MR. DUFF: Who was R.A. Baxter? [io] A: Dr. Baxter was the head of the dielectrics mi research group that was centered in the Ruabon, [in North Wales plant, which did not make [nj polychlorinated biphenyls. [i4] Q: Please mark this as Exhibit 279. [isj ( Plaintiffs Exhibit 279 [iq marked for identification). [17] MR. DUFF: Mr. Wood, this document has been nsj marked as Plaintiffs Exhibit 279 and bears 119) production numbers TRAN 085947 through 53. And for [201 the record, another version of this document was pi] previously marked as Exhibit 75. Do you recognize pq this document, Mr. Wood? p3] A: I recognize this as a letter which, for p4) identification purposes, I'll state was prepared by [25] me, mailed from Brussels, prepared on the 26th of Page 137 [i] January 1967, on the subject of Aroclor and Sweden, in It was addressed, as I had addressed my earlier pj letter, to G.L. Buchanan, and I had copied Paul [4i Benignus, my main contact in St. Louis, Don Cameron, [5] who was my supervisor in Brussels, Dr. Hardy, our [13 medical group head in London, Dr. Emmet Kelly, that [7]I had previously been advised by Dr. Hardy to copy p] in St. Louis and R.A. Steenrod, who was our m international contact. In fact, it's the same [ioj circulation list, I believe, as the earlier memo [in that we discussed. [12] Q: And you attached a three page document to (i3iyour -- I'm sorry, a four page document to your [14] three page memorandum, correct? [in A: I'm sorry, which -- what are you asking me [iej to identify here? [i7i Q: I'm asking if you attached a four page usi document which appears at TRAN 085950 through 53? [i9] A: 085950? poj Q: Yes. pn A: Yes, I did. This is a document which is [22]headed "LKB Press Release". Is that the one we're (23] talking about? [24] Q: Yes. You attached this press release to Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 Page 133 - Page 137 HARTOLDMONOO11016 Deposition of DAVID WOOD NOVEMBER 9, 1995 [23] your memo of Januaiy 26, 1967, is that right? _____________________ Page 138 (U A: Let me just make sure that I did state in [2| this letter that I was attaching that one. [3| Q: Please take as much time as you need to (A review this document. It may help to direct your [3] attention, just to expedite things, to the last [] paragraph of your letter. Pi A: Okay. "As you will see from the press pi release", yes. I just wanted to make sure that I pi could confirm to you that I did, 30 years ago, (ioj attach a four page press release to this particular [in memorandum. [i2] Q: In this memorandum you told Mr. Buchanan [i3j that because some of the uses of the materials in [i4] Jensen's study were consistent with uses of [i3] Aroclors, you made a point of visiting Jensen in [i] Sweden, is that correct? ' [i7i A: Yes. [18] Q: Did you meet with Jensen before or after you [isq met with Widmark? [20] A: I don't recall. I can't remember------------ whether I pi] met them sequentially, separately. I just don't [22) recall the sequence. P3] Q: Do you recall if you met with them at the [24] same time? [23] A: It would have been on the same visit to Page 139 in Stockholm, let me categorize it that way. But I pi don't recall whether it was a joint meeting, whether pj it was a separate meeting, and if it was separate w meetings, what the sequence was. [5i Q: Do you recall who else attended the meeting pg with Dr. Jensen? P]A: Ola Palm. pi Q: And what did you discuss with Jensen in that pj meeting? _ [io] A: I discussed how had he got into the^ii] - particular research program that he was in. Tried [121 to find out from his perspective as the actual [i3] researcher what he felt he had found and on what [141 basis the people who had published his work ahead of [isj him having scientifically published it made some [i] assertions about the toxicology of the chlorinated im residues that he was finding. [isj Q: And how did he tell you that he got into the [19] research? [201 A: That he was looking at DDT. He started from pi] the point that his work was associated from the pzi outset with DDT, that in finding some residues that P3] did not appear to be DDT he had put together a work [24] plan which he hoped would help him identify what was [23] interfering with his DDT analysis. And the work Page 140 in that he had done led him to the conclusion that he [23 was looking at a double benzene ring nucleus type pi chemical with variable amounts of chlorine scattered m around that nucleus, TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY and that in terms of, [3] therefore, going out and trying to find what sort of [q chemicals were in commerce that had that sort of p] configuration, one of the classes of chemicals that [8] he had come across were polychlorinated biphenyls, p] and that in terms of having acquired some samples of [ioj commercially available mixtures there were [nj similarities between the peaks that those materials (iq produced to the peaks that he was observing in [13] residues, which led him to the hypothesis that what [uihe was seeing was, or was similar to polychlorinated [i3j biphenyls, and then he went out to try to gain some [i] data with how were polychlorinated biphenyls used, [i7]just as backdrop to trying to begin the theorization [isj of how they might have appeared in the environment. [19] Q: And you made clear in this memo after your poi meeting with Jensen, quote, "To eliminate any pi] earlier confusion that there may have been, I should pzi like to emphasize that there is no doubt that the [23] chemical which is the subject of the investigation [241 and the news release is chlorinated biphenyl, i.e., [23] Aroclor", correct? Page 141 ui A: That's what I wrote. In hindsight, I should pi have expressed it slightly differently, but -- Pi Q: You also told the recipients of this m memorandum that the company that supplied the mass [si spectrometer described the research program -- [] described in the press release which you attached, m and which research was carried out by Jensen, and pi you described in clear terms how chlorinated [9] biphenyls were identified, correct? [io] A: I'm sorry, take me to a paragraph, you've [ii] confused me. I'm not sure what you're asking me [121 right now. mi MR. CHAMBERS: I think he's just asking you [14) to read the document, unless I'm misunderstanding. [i3] MR. DUFF: Let me ask the question again. [i6] In this memorandum did you state that the research [17] program -- strike that. The press release [18] describes in clear terms how chlorinated biphenyls [i9] were identified by Jensen, correct? [20] MR. CHAMBERS: I object to the form of the pu question. m A: No, I don't believe it does. P3iMR. DUFF: Well, I direct your attention to [24] the third paragraph of your memorandum. [25] A: Yes. ________ _________________ Page 142 [1] Q: Did you say with respect to the press pi release attached to this memorandum that it, quote, pi does basically describe the research program carried [4] out in Sweden and describes in clear terms how [5] chlorinated biphenyls were identified? [6]A: That's what I wrote in this memo to pi Page 137 - Page 142 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11017 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY exemplify that I think part of the press release, [1 which says this was the procedure which this (9i researcher followed with the LKB Productor [loi equipment, which they were trying to promote the new [ui equipment as able to do these things. So it fairly [121 clearly lays out the steps that they led Jensen to [131 follow, which led him to identify what he was seeing [141 as chlorinated biphenyls. [is] Q: Thank you. When you met with Jensen, did he [ii show you the instrumentation that he had used in his [17] work? [is) A: No. I don't believe he did, anyway. I [i9] mean, I don't think a lab tour was part of it, not [201 that I recall. But it would have been fairly -- I pn mean, I knew that it was LKB Productor, that they [22] described it as a mass spectrometer. That was not [231 equipment I was familiar with, nothing would have pq been gained from me staring in any level Of awe at [25] this particular black box. I need to be able to Page 143 in report back to my professional practicing chemist 121 colleagues what equipment had been used and for them pj to talk to LKB Productor to sort of see did they [4] rate this equipment as being effective in what they [si claimed it to be able to do. [i Q: When you met with Jensen, the point that you m made to him was the need for care in any further ra publication of his work, is that right? [9i A: I tried to emphasize that we respected good [io] science, and there was an element of danger if good [nj science was badly submitted for publication in that (i2| it didn't get appropriate peer review or that the [13] media drew conclusions beyond what the actual p*i research work itself could support, that that was in [lq nobody's best interest. : net Q: Were you suggesting to Jensen that he had ini badly published his earlier work? [i8i A: No. I was suggesting that LKB Productor, in [191 trying to maximize the exploitation of his excellent ixn study to promote their equipment, had put together a pi] forum where misleading views were drawn and extended [221 from the professional report that Jensen had put p3] together. That's why I used the term earlier that I m thought that his professional work had been abused [25] by LKB Productor. ;Page 144 in Q: When you met with Jensen he told you that he [21 had been approached by several Swedish workers who pi were concerned about the effect of PCBs on their w health, is that right? [si A: I don't recall it. If I read the memo and I (i report it in the memo, it is likely that we had that pi part of the conversation. Is there a particular pi paragraph that you can help me refresh my memory? . Deposition of DAVID WOOD NOVEMBER 9, 1995 Pi Q: Yes. I'll direct your attention to the top [10] of the second page of your memo, the first mi paragraph. [i2i A: And, so, can you ask the question again? I [13] can probably respond better now. [ui Q: Certainly. Please repeat the question. [is] (The requested portion of the [i<si record read by the reporter). [i7] A: Yes, he did tell me that. But to be [isj correct, the way I reported it, that he had been [i9] approached by several workers associated with [201 chlorinated biphenyls for non-electrical uses. I [21}just want to be clear that -- what we're talking [221 about here. [23] Q: So we weren't talking about dielectric [24] fluids, is that right, or any -- [25i A: That's right. These were not workers from _Page 145 [11 capacitor plants or transformer plants. I mean, he [21 was very specific that these were people who had [3j relationship with chlorinated biphenyl products in [4] other applications. [5] Q: Did he tell you what those applications [l were? tn A: If he did, I don't recall. [si Q: You also told Buchanan and the other [91 recipients of this memo that if any technical [101 journal takes up the press release from the LKB [in Productor Company, there is little Monsanto could or [121 should do in the way of publishing rebuttals, [13) correct? [i4] A: My personal recommendation contained in this [is] memo is contained in that statement. I mean, if any [16] technical journal sort of wants to look at the LKB tm Productor press release and say we'll review this in [lq our journal, little or nothing could be gained at [>9| this point in time of January 1967 of our trying to tag state this is bad equipment or good equipment. We pn didn't know very much about their equipment. Again, [221 professionalism sort of says you don't take out (23] after people until you know what you're doing. [24i Q: Directing your attention to the bottom of [25i the second page. ____________________ Page 146 in A: The second page. [2j Q: Which is where that last language came Pi from. You then stated, quote, "We do not want [4) personally as Monsanto to get too involved in this [sj question". Correct? [q A: I wrote that, yes. [71Q: At that time Monsanto was a major producer m of PCBs in Europe, correct? [9i As We were one of the producers of PCBs in [ioi Europe. [11] Q: Is it accurate to say there were three major [121 producers of PCBs in Europe at that time? [13] A: Yes. [14] Q: Monsanto, Bayer and Prodelec? [is] A: That's correct. (161Q: And at that time Monsanto was the sole Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 142 - Page 146 HARTOLDMONOO11018 Deposition of DAVID WOOD NOVEMBER 9, 1995 [i7] producer of PCBs in the United States, correct? list A: I believe that is so. . [i9i Q: Do you know what was novel about the LKB [2oi Productor gas ~ the combined gas chromatograph and [2i] mass spectrometer? [22i MR. CHAMBERS: I object to the form. But if [23] you're able to answer, you can. [24] A: I didn't then. I have a better realization [25i now. ;Page 147 [i] MR. DUFF: What is your understanding -- [2i what is your realization now? [3] A: That the equipment combined two different [4i and analytical techniques and allowed certain isi organic species to be detected and categorized in [q smaller concentrations than had previously been a pi possibility. . [8i Q: Were you familiar with gas ' chromatography in pj 1967? [ioi A: Very obliquely. It had not been an area of [in concentration in my own undergraduate chemistry tizi work.--- ----- ----------------- --------- --' [13] Qs Were you familiar with mass spectrometry? [i4i A: Very obliquely. To the extent, in both, [15] that I recognize when -- to know that I didn't know pq and I needed to refer it to people in Monsanto who [i7] had fuller knowledge of that type of analytical (isi procedure. [i?i Q: Who in Monsanto would you refer to for such [20] knowledge? pi] A: At that particular point I would have gone |22] back to my main commercial contacts and the medical [23] department and have allowed them to identify who in [24] the Monsanto technical community they felt were best [25] able to address that issue. Page 148 [ii Q: Do you know who at this time? I .... ra A: Dr. Baxter in England would be the person, pj in Europe, that would be best able to bring hj resolution to that issue. And, I say, I depended on [5] Buchanan, Benignus and Kelly to determine who they tq wanted to talk to this issue from Monsanto's m professional scientist group in North America. Pi Q: Did you speak with -- strike that. Where p] did you get this LKB press release? [icq A: I seem to think -- I seem to think I was mi given it by Jensen, but I don't state in the memo [121 where I actually -- I just say attach it, without [i3] sort of saying who gave it to me. [14] Q: Did Jensen give you any other documents? [15] A: Did he give me separately the gas pq chromatograph? If he did, it will be in here [17] somewhere. No, Jensen said he would forward to me [isi copies of his mass spectrographs. [19] Q: And do you recall that he did so? [20] A: I believe he did. [21] Q: Was it shortly after you met with him that [22] he did so? TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [23] A: I believe it was. But, again, I don't [24] recall with any certainty when it would have [25] happened or whether he sent it to me or whether we ;Page 149 [i] arranged for him to send it directly to somebody to pi whom it would make more intelligent sense. 13] Q: Did you contact anybody at LKB Productor [4] after seeing this press release that's attached to [5]your memorandum? [61 A: No. [7] Q: Did anybody at Monsanto conduct LKB, as far [8] as you are aware? [91 MR. CHAMBERS: I object to the form. Go [ioi ahead. [in A: I don't know. [12] MR. DUFF: Did you tell anybody at Monsanto [131 to conduct LKB Productor? [14] A: I did not. [is] Q: Did you recommend to anybody at Monsanto [ii that they purchase an LKB Productor -- I'm sorry. [17] That -- did you recommend to anybody at Monsanto [is] that----they purchase the combined gas chromatograph, (19] mass spectrometer from LKB Productor? [201 A: Not in my plaice to do so, so I didn't. I pi] mean, it's like saying that if I wanted somebody to m comment on a road review of a Rolls Royce that they [23] necessarily needed to buy a Rolls Royce to m accomplish that. [25] Q: I move to strike the last sentence of the Page 150 in witness's answer as non-responsive. If Jensen's C2jwork was correct, then the news for Monsanto' s pi Aroclor business was devastating, correct? [4] MR. CHAMBERS: I object to the form, isi A: If Jensen's work was correct, the iq consequences to Monsanto's chlorinated biphenyl pj business were not devastating. [8] MR. DUFF: If Jensen's work was correct, [9i Monsanto stood to lose millions of dollars in -- [io] strike that. If Jensen's work was correct, then -- [ii] strike that. Do you know if Monsanto subsequently pq purchased a combined gas chromatograph, mass [i3] spectrometer? [i4] A: Just for clarification, you're talking about [i5] did they buy an LKB Productor version of the pq equipment or did we buy a combined piece of [i7] equipment? LKB Productor were not the only people psiwho made these. P9l Q: Who else made this type of equipment? [20] A: I mean, there were -- as time went by, the [2i] technique of using those two combined pieces of pq equipment became a more recognized procedure for [23] determining presence of materials in small [24] quantities in a number of residue sample situations, [25] and Monsanto, in common with the chemical industry, Page 146 - Page 150 Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONOO11019 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY _____________ Page 151 Hi ultimately became owners of a fair number of such pi pieces of equipment in conducting their professional [3] businesses. [4j Q: Do you know when Monsanto first acquired a [3] combined gas chromatograph mass spectrometer? []A: No, I don't. t7i Q: Why didn't you go to LKB Productor and give [8] them samples of Monsanto's PCBs and ask them to run [9] it through their equipment? no] MR. CHAMBERS: I object to the form. [in MR. DUFF: You can answer. [12] A: LKB Productor had to our mind at that stage [i3] unprofessionally used Jensen's work, and we were [i4] addressing the issue of what were the implications [isj of Jensen's work, nothing was to be gained by at [i] that stage involving LKB Productor in any series of im tests on their equipment and our materials unless [is] such research were thought to be something which the [i9j Monsanto technical community felt would give them a [201 better understanding of the situation. So, 1 was [21] not about, from my position as being the commercial [22] product manager, to start ordering people to go off [23] and do this or do that with LKB Productor. I [24i brought the research programs that had been [23] conducted in Sweden to their attention with a Page 152 [it description of the protocols that had been used and [2] expected them and asked them to come to some pj conclusions about the validity of that work. Now, w for me to dictate how they should go about doing [3] their jobs in that technical sense would have been [6] highly unprofessional. [7] Q: Please mark this as Exhibit 280. ra ( Plaintiffs Exhibit 280 ra marked for. identification). [io] MR. DUFF: Mr. Wood, this document has been [in marked as Plaintiffs Exhibit 280 and bears [12] production numbers TRAN 056036 through 61. [13] A: Sorry, I find that on the side? [14] Q: That's on the right margin. [i3] A: Yes. [i6] Q: Please take a moment to peruse this [nj document. [isj A: Yes. [io] Q: Do you recognize this document? [20] A: This was a copy of the typed script of the [2i] paper which Soren Jensen delivered to the conference 1221 at the Wenner-Gren Institute that we alluded to mi earlier that I confirmed that I had not attended, [24] and nobody from Monsanto attended, and this was a [23] result of my talking to Jensen that this ultimately Page 153 [1] came to Monsanto. [2] Q: This was the presentation that Mr. Jensen pigave on November 22, 1966, is that Deposition of DAVID WOOD NOVEMBER 9, 1995 right? [4] A: That's my understanding, yes. [3] Q: And is this the copies of Jensen's mass [6] spectrographs and the details of his sample [7j preparation that you referred to in your memorandum (S) of January 26, 1967? [9] A: I believe so, yes. Yes. [io] Q: And when you received this document from [in Jensen, what did you do with it? [i2] A: I sent it to my faithful list of readers [13] that we talked about before. [i4] Q: You sent this, then, to Mr. Buchanan, is us] that right? * [16] A: There's no cover memo attached to this [m specific exhibit, but my recollection is that I had [is] established that previous list as people who needed [19] to be kept up-to-date and, therefore, certainly all [20] of the people on that previous list would have been 121] sent a copy of this particular paper. [22] Q: And that list you're talking about is the [23] people who are listed at the top of Exhibit 279? [24] A: 279 is that earlier memo of mine to -- yes. [25] Q: Do you recognize the handwriting on the Page 154 in left-hand margin of this? [2] A: The script looks like that of a twenty pi something year old British person called David Wood. M Q: Is that your handwriting that says - [3] A: I believe so. [iQ: --November22, '66? pi A: Yes. [8]Q: That's your handwriting that says "Dr. [9j Kelly, please comment"? [10] A: Yes. [11] Q: Next to the word toxicologic? [12] A: Yes. [13] Q: And do you recall if Dr. Kelly commented on [mi that section or on this document in general? [is] A: I'm sure he did. But I surely can't recall [ij chapter and verse of what he told me. [17] Q: Were you asking him to comment on the [isj history of the toxicology of PCBs? [i9| A: I was asking him, as our chief medical [20] officer, to comment on the section of this report [211 which was headed toxicology. I mean, he could choose [22] to comment on whichever part or all of it he chose [23] to comment on, but it was appropriate that he [24] comment on it. [25] Q: When you received this document from Jensen, Page 155 [ljyou realized that Jensen's findings related to pj polychlorinated biphenyls, correct? pi A: No. I believe at that time that I had hi reached a personal conclusion that I felt that it [5] was pretty likely that what he was seeing was [6j related to polychlorinated biphenyls. But as I read m this article and as I talked to Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 151 - Page 155 HARTOLDMONOO11020 Deposition of DAVID WOOD NOVEMBER 9, 1995 my colleagues about ra this new technology of mass spectrometry, that the pijury was still out. I mean, I say, I was beginning poi to feel myself that probably what we were talking pu about here was polychlorinated biphenyls, but after pq all, I was a fairly young, fairly newly graduated p3] with only an undergraduate degree in chemistry, I pq was not about to second guess my more qualified psi professional peers, so I was still sending the more pq technical aspects of these reports to the p-7] appropriate people to tell me, David, you know, we pq agree or we disagree or whatever. [19] Q: So when you received this document from [i Jensen, you knew that Jensen thought that he was pu finding PCBs? [22] A: Oh, yes. [23] Q: Correct? [24] A: No question. Jensen felt that he was pq finding -- I'm sorry. I'm going to have to ' take you ' Page 156 [i] back one removed. Jensen felt that he was finding pi chlorinated biphenyl mixtures. This | term PCBs is pi sort of a Swedish invention, almost. We were not [4j using -- PCBs became -- achieved a level of [5] notoriety later. But just so we're careful, Jensen [q was sure that he was dealing with a family of pi chlorinated biphenyls, put PCBs on one side for a pi moment. CT Q: And that was a family of chlorinated poi biphenyls of which Aroclor was one, correct? pu A: Aroclor was Monsanto's trademark for a range p2) of chlorinated biphenyls that we were one of the (t3i world's manufacturers. [i4] Q: So if Jensen was correct in this document pj] which has been marked as Exhibit 280, then the pq implication was that Aroclors were being found in [i7i the environment, correct? - [is] MR. CHAMBERS: I object to the form. [19] A: No. No. ' [20] MR. DUFF: Let me ask the question again, pi] If Jensen was correct, then, substances which had pq the same chemical composition as Aroclors were being [23] found in the environment, correct? [24] A: No. ps] MR. CHAMBERS: I object to the form. ______________ Page 157 Pi MR. DUFF: Why is that not correct? pi A: If you read this paper with understanding pj -- and I don't know what your scientific hj background is, and, you know, mine being somewhat [q constrained, I can still review in this document [q some problems and issues that Jensen has with pi retention times and different chemical entities m having similar retention times so that they appear (9i in the same spot on the -- they peak at the same [lq point in the curve, and this depends as much on the [ii]substrate from which you're extracting the residue pqas it does -- I mean. TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY this was good fundamental new p3] leading edge work. Jensen, I think, had done a very p4] credible job and believed that he was finding pq famililes of chlorinated biphenyls, of which pq Monsanto's family was called Aroclor. But he didn't [i7] know what he was -- if what he was seeing was pq chlorinated biphenyls manufactured by Bayer, p9i Prodelec or Monsanto, who had sold various amounts poi for various reasons, us the smallest provider to pi] Sweden, so Aroclor per se was not being implicated. [221 When you say were chlorinated biphenyls per se being [23] implicated, no, because people at that stage didn't [24] know what happened to other chlorinated organic pq materials as they were biodegraded in nature, did Page 158 in they break down and go through product stages which [21 were very similar to where those peaks would have [q occurred for chlorinated biphenyls. We were trying m to be totally objective at that point in time. So, [q the evidence was growing that said somebody's [q chlorinated biphenyls seem to be appearing in pj Sweden. But the way that you were framing the [s] question, which was trying to get me to sort of say w that Aroclor was in deep trouble in Sweden, no. I po] mean, the jury was still out at that point in time, p ij but we were still doing a lot of the right things to pq find out what the hell was going on in Sweden. Does pq that clarify where you wanted to take me? [i4] Q: I think so. In this document Jensen sets pqout the characteristics of what he calls PCB, [iq correct? pq A: Can you again -- it's a long time, and I psi was not totally familiar with this document even 30 pq years ago, so where are you taking me specifically? [20] Q: On the first page of the document, pi] A: Paragraph two? [22] Q: The second paragraph. The paragraph [23] that -- [24] A: That starts "The main characteristics"? [2q Q: Yes. And in this paragraph Jensen sets out Page 159 pj the characteristics of PCB, correct? pi A: He makes some statements about some personal pi beliefs about PCBs. And the reason I state it that [q way is because under item two he says they are tq hardly metabolized in living organisms. I'm not [q aware -- I wasn't aware then and I'm not aware now pi of any major scientific studies which had looked in tq detail at the metabolism of PCBs in living [9] organisms. The very research techniques that he was poi busily evolving were an essential component of pi]people even getting being able to design such pq metabolism studies. So, for him to make this broad pq general statement of they are hardly metabolized in pq living Page 155 - Page 159 Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONOO11021 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY organisms is conjecture on his part, pq unsupportable by any scientific evidence at that {tel point in time. ii7] Q: Hadn't he stated that he found that [is] polychlorinated biphenyls had accumulated in fish [i9i and in birds? [20] A: He talks about enrichment and other such pi] strange terminology, which later in time, with p2i biorefractory materials, became better qualified as [23] bioaccumulations and this sort of thing. But, [24] again, here you've got a young man doing excellent pq analytical work, but stretching out and using Page 160 [i] hypotheses outside -- metabolism and that sort of pi thing. Unless he could reach out and produce pi supporting technology to be able to sort of say I've [4j done the front end of this, which is the analytical [q work, and that is supported by these studies in [q animals, in ecosystems and the like, he makes these n sweeping generalizations to characterize PCBs where p] there's no supporting evidence. He says if more -- pi under item three, he says if more than four chlorine [ioj are present they are non-inflammable. I'll excuse [inbecause of language deficiencies the double [izi negative, he means non-flammable, I think. But I [131 can make a pentachlorobiphenyl bum. I can make a [i4] hexachlorobiphenyl bum. You know, so he goes pq beyond his area of research expertise and starts pq making a lot of sweeping generalizations which just [nj aren't true. Now, that takes away, unfortunately, pq and it was one of the problems that Widmark, his m professor had, you know, a little from his m credibility in the good solid research processes and pu procedures and protocols that he was working on. P2i Q: There was validity to some Of the p3] conclusions that Jensen reached, is that right? [24] A: Which conclusions would you like for me to [23] respond to? ' Page 161 in (Discussion off the record). P] MR. DUFF: Would you please mark this [3] document as Exhibit 281. [4] ( Plaintiffs Exhibit 281 [q marked for identification). [] MR. DUFF: Mr. Wood, this document has been m marked as Plaintiffs Exhibit 281 and bears pi production numbers TRAN 056034. Do you recognize pi this document? [ioj A: No. [i u Q: Do you recognize any of the handwriting on [121 this document? [13] A; No. [14] Q: Do you agree that this is a page from a [is]publication called Chemical Engineering, dated pq January 30, 1967? [17] MR. CHAMBERS: I object to the form. [18] A: Down the bottom right-hand comer of this [i9i exhibit I see January 30, 1967, Chemical po] Engineering. I can't say that that for sure pi) designates this as being a page from the Deposition of DAVID WOOD NOVEMBER 9, 1995 magazine [221 Chemical Engineering, no. I could speculate that it [23] is, but I've never seen it before and -- [24] Q: You don't recall having seen this document [251 before, is that right? Page 162 [i] MR. CHAMBERS: I object to the form, pi A: I don't. pi MR. DUFF: Please mark this document as w Exhibit 282. ra (Plaintiffs Exhibit 282 (q marked for identification), pi MR. DUFF: Mr. Woqd, this document has been [8] marked as Plaintiffs Exhibit 282 and bears pi production numbers TRAN 056619 through 20. Do you [ioj recognize this document? [u] A: Yes. im Q: Will you please identify this document for [i3] the record? [14] A: This appears to be a memo from Dr. Emmet [isi Kelly of Monsanto in St. Louis to the addressee, pq myself, David Wood, with copies to Buchanan, Filer, [17] Hardy and Wilde, [is] Q: Who was J. Filer? [i9| A: Jim Filer was an American expatriot working po] in Brussels for Monsanto and I believe involved at pi] that time with -- I'm not sure what Jim's assignment was at that point in time. [23] Q: Did he report to you? P4j A: No. pq Q: Did you report to him? Page 163 [i]A: No. pi Q: Who was Eugene Wilde? pi A: Eugene Wilde was a long-term marketing hi employee of Monsanto in St. Louis who was involved [5] with various product lines, to my knowledge, over (q his long career with Monsanto. He's also a retired pi gentleman. What his assignment was in February of [si 1967,1 don't recall. [9] Q: Dr. Kelly told you in this memorandum that [ioj an extensive meeting was conducted in St. Louis [in relating to the memorandum that you had sent them, pq correct? [i3] A: That's not what it says. Because when it [i4] says there was an exstensive meeting, which would pq include those individuals receiving copies of this [iq memorandum, this very memorandum we're reviewing, [17] not my memorandum. That's the way I read that. [is] Q: Dr. Kelly told you in this memorandum that's [i9]been marked as Exhibit 282 that an extensive meeting pq had been held in St. Louis on the subject of Aroclor pi] in the air and various fish and other living [22] reservoirs, correct? [23i A: That is correct, yes. pq Q: And one of the things he told you in this pq memorandum, directing your attention to the third Page 164 [i] paragraph, is, quote, "We are very worried Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 159 - Page 164 HARTOLDMONOO11022 Deposition of DAVID WOOD NOVEMBER 9, 1995 about |2] what is liable to happen in the States when the (3] various technical and lay news media pick up the hi subject", correct? [5) A: That he states. [l Q: And he told you that, quote, "This is m especially critical at this time because air pi pollution is getting a tremendous amount of pi publicity in the United States", correct? [ioi A: That is the next sentence in that third [in paragraph. [i2i Q: And that is something he told you in this ini memorandum, correct? [mi A: Yes, he did. [i5) Q: He also told you that Monsanto had been [ii receiving quite a few communications from its [i7] customers, including one which he called the most [iai critical one from NCR, which customers were very [i9j much involved -- strike that question. He also [201 told you that - Monsanto had been receiving quite a [211 few communications from its customers at this point [22] in time, correct? P3] A: Yes, he did. [24] Q: And he told you that the most critical psj customer who had communicated with Monsanto at this Page 165 [1] time was NCR, correct? [2] MR. CHAMBERS: I object to the form. [3] A: No, that's not what that fourth paragraph, w if that's where we're reading, states. I read that [5] differently to your interpretation of the text. We [6] have been receiving quite a few communications from n our customers. The most critical one I read is the [g] communication from NCR. Not that NCR is the most pi critical customer. That may be a minor -- [i<q Q: Were you aware of any communications from ni] Monsanto's customers at this time? - [12] A: Monsanto's customers in the United States to [i3[ Monsanto in St. Louis or Monsanto's customers [14]anywhere? [i5i Q: Anywhere. [i] A: Specifically, no, I was not receiving [in reports of individual customer communications to nsi Monsanto, either as to content or the number of [i9j them. [20] Q: Were you aware of the communication that pi] Monsanto received from NCR in particular? [22] A: Until I received this particular memo, I P3] didn't know that NCR were one of the -- a customer [241 who had communicated with Monsanto about chlorinated (2S) biphenyls. . Page 166 in Q: Just so I'm clear, were you aware of any [2] communications from any customers to Monsanto about pi polychlorinated biphenyls at that time? [4| A: Well, the trouble I have, and that's why, [5iagain, I'm trying to be clear here, Monsanto was in [eg the business of selling TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY chlorinated biphenyls, and, m therefore, there were daily communications with many [8] of our customers about the business of supplying, pi using chlorinated biphenyls. Now, you chose to use [ioi we've been receiving quite a few communications from [njour customers, I had to read between lines and say [12] that they were receiving communications about the [13] -- what people were reading about what the press [i4] was saying had happened in Sweden. Now, I was not [is] aware of any individual communications from any [ii customer, NCR or otherwise, that were amongst that [i7j category of quite a few communications, which I was [is] making an individual assumption that they meant [19] communications about chlorinated biphenyls and [201 Sweden. Does that clear it up for you? [21] Q: I think so. [22] A: Good. [23] Q: Was it critical at this point in time for [24] Monsanto's customers to have all the information [25] available to them that Monsanto ... ..had available to it---------------------------- ----------- Page 167 [i] with respect to the findings of Jensen? ta MR. CHAMBERS: I object to the form, pi A: I'd like you to repeat the question, I'm not [4] sure that I -- [5] Q: Certainly. Please repeat the question for [si the witness, pi (The requested portion of the pi record read by file reporter). [9] MR. CHAMBERS: Same objection. [101 A: Well, I can respond to it. No, it wasn't. [i 11 MR. DUFF: Why not? [12] A: Because, without intellectual arrogance, [13] Monsanto had decided to by to establish a factual [i4] basis of what was happening in Sweden, and so [is] included in the "all" which would be encompassed [i] within your last question would be things that we im felt were inaccurate, irrelevant, and so it would [isj only increase the circle of people who were being [i9] confused at that point in time. We had a (201 responsibility to our customers to solicit pi] clarification of what was happening in Sweden. But p2i to try to respond to your specific question, was it psj critical at that date that our customers heard all [241 that Monsanto had been notified about, no, it pq wasn't. But I don't want to sort of put that in any Page 168 ni context where you say that Monsanto was acting in [21 any way irresponsibly or hiding anything; no, we pj weren't. But Monsanto, indeed, was acting very [4] responsibly. [5] Q: Was there any factual basis to Jensen's [0 findings? pi A: That we were aware of at February 1967? p]Q: Yes. pi A: We believed there were some factual bases. [101 We didn't know where factual crossed into minon-factual hypothesis, Page 164 - Page 168 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11023 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY unsupported. There's no (121 question we believed that there was some parts of [i3] this work which were very valuable and factual and fi4] needed to be explored, investigated, clarified and [is] communicated. lii Q: Why didn't Monsanto convey the factual basis [17] of Jensen's work to its customers? [is] MR. CHAMBERS: I object to the form. [i9] A: Because at that point in time Monsanto could [an not completely identify which bits our technical pi 1 experts really did believe were factual and which [221 bits they believed were speculative, which I think [23] is indicated by the very opening statement in [24] paragraph two of this memo, which talked about the 12q outcome of the extensive meeting, which the decision Page 169 [i] was that more information had to be gained and that pi this could likely necessitate a trip so that we pi could get our experts alongside their experts to [4] begin to sort out fact and fiction. [5] Q: Monsanto had certain information available kg to it already as of February 10, 1967, correct? Pi MR. CHAMBERS: I object to the form. [8] A: Monsanto had available to it at February [9] 1967 a set of information which were a blend of [io] potential fact and potential errors on Jensen's impart, potential inaccuracies in reporting Jensen's [12] work, in potential inaccuracies in interpretations [13] put upon and conclusions drawn from Jensen's work by [i4] others with unsupported qualifications to make such [is] statements, and so we had a mass of data which very [iq inconclusively could be designated as fact or [171 fiction. [is] Q: Would it have been a mistake for Monsanto to nqtell its customers about Jensen's work as of pm February 1967? I .. . pi] MR. CHAMBERS: I object to the form. [22] A: I don't know. [23] Q: In February 1967 were you qualified to make [24] that determination? [23] A: I probably wasn't. And I would not Page 170 [i] necessarily have been invited to make that decision. PI Q: Who at Monsanto would have been qualified in pi February 1967 to decide whether or not to tell [4j Monsanto's customers about Jensen's findings? [3]MR. CHAMBERS: I object to the form. [q A: I was not privy at that time to all the pi debate going on about that issue. I don't know who [8] attended meetings or, indeed, how many meetings [q there were in St. Louis to discuss that. But [ioj there's no question in my mind that for us to set [ii] off on some pilgrimage in Europe to get into any [iq broad scale customer or public communication with [i3] the level of data that we had would have been [iq totally a mistake. Deposition of DAVID WOOD NOVEMBER 9, 1995 [i3] Q: Was there an individual that you considered [iq to be the authority on toxicological issues in im Monsanto in February 1967? [is] A: I was led to understand that Dr. Emmet Kelly [i9] was the person who would, in consultation with po] appropriate experts that he wished to consult with pi] to fill in gaps in his own expertise, be the person [22] who would have a very large voice in deciding what [23] safety related information should be given to our [24] client base and/or the public and/or users of [23] equipment containing our products at that point in Page 171 [1] time. You know, I still believe that I got the [2] question to the right person at the right time. Pi Q: Was Dr. Kelly the person who was best suited [4] to convey Jensen's findings to customers in February [5] 1967? [q MR. CHAMBERS: I object to the form, pi A: No. [8]Q: Who was? [9] A: I don't think there was any one individual [io] who you could say was best able to communicate [11] Jensen's work to the world at large at that point in [12] time. There were a number of people who had various [13] functions within Monsanto's corporate and product [14] line organization who were qualified to contribute [iq to the decision about what Monsanto's [iq responsibilities were at that point in time to [171 support the use of our products with data, be it [is] analytical data, industrial hygiene data, safety [iq data, toxicological data, and they all played a role pq in establishing policy. pi] Q: By this memorandum which has been marked as [22] Plaintiff's Exhibit 282 Dr. Kelly told you that, [23] quote, "The consensus in St. Louis is that while (24] Monsanto would like to keep" -- PS] A: I'm sorry, are we still on this Exhibit Page 172 [i] 282? pa Q: Yes, we are. P] A: If you're leading from that, then can you [4] tell me where -- which paragraph you're working [q from. iq Q: Yes. I'll direct your attention to the last [7] paragraph of this memorandum. [8] A: On the second page? [qQs Yes. no] A: It starts "The consensus in St. Louis". [ii]Q: Yes. By this memorandum which has been [12] marked as Plaintiff's Exhibit 282 Dr. Kelly told you [13] that, quote, "The consensus in St. Louis is that [iq while Monsanto would like to keep in the background (iq in this problem we don't see how we will be able to (iq in the United States". [iq A: That's what he wrote and told me in that [is] memo of February 10th. Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 168 - Page 172 HARTOLDMONOO11024 Deposition of DAVID WOOD NOVEMBER 9, 1995 [19] Q: He also told you that, quote, "We feel our i?oi customers, especially NCR, may ask us for some sort pi] of data concerning the safety of these residues in 1221 humans". [23] A: Yes, he states that, too. 124] Q: And he had told you that -- 125] A: Can we just -- I mean, there's another Page 173 [i] sentence which is fairly vital to the response to pg the last question, so let me just add and read that p] next sentence. "This might open the door to an w extensive and quite expensive toxicological and pi phamacological investigation", which says they will [] ask us for information which we don't have. Okay? pi If you read those two - we're going to be asked [q for data that we'll need to investigate. Now, pi reading the middle part of that, therefore, it says no] we're going to be asked for data that they don't (in have. And I don't mind him sort of saying that U3j we're concerned, that we're going to be asked for (iaj some data that we don't have and that's troublesome.------ ------------ -- [i4] Q: And by this memorandum Dr. Kelly listed a [iq number of points that he asked you to gather (iq information on, is that right? [in A: I seem to recall, but let me refresh my [is] memory, ns] Q: Certainly. [20] A: There were seven points that he alluded to, pu and essentially, since I was the addressee of this [22i memo, he was asking me, if not necessarily to get p3] all that information myself, it would be to pq coordinate and use my authority in Europe to gather ps] that information. _Page 174 [i] Q: And did he ask you because at this time you pi were the person in Monsanto in the.best position to pj gather this information? - [4] A: No. He asked me because in my role of -- [5] I'm going to go back to my original exhibit here [q and, was I product supervisor or product management pi of manager in '67? (8]Q: You're referring now-- pj A: I was product supervisor, dielectric fluids. [io] Q: You're referring to Exhibit 273 now? [ill A: I'm referring to Exhibit 273. In that [121 position, and having got myself involved with this [i3] issue, he knew he could depend on me to work within [iq our organizational resources to develop this [i5] information. I had shown some ownership of the [ii problem in Europe. [i7] Q: Please mark this as Exhibit 283. pq ( Plaintiffs Exhibit 283 [19] marked for identification). [2d] MR. DUFF: Mr. Wood, this document has been pij marked as Plaintiffs Exhibit 283 and bears [221 production numbers TRAN 056616 through 18. Do you P3j recognize this document? pq A: Not until I've reviewed it. TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [25] Q: Please take as much time as you need. __________________________ Page 175 [11 A: Yes, I recognize it. pj Q: Can you please identify this document for pi the record? [4] A: This is a memo from Rising and Strand, our pj agents in Sweden, to myself, David Wood, in [] Brussels, dated February 17th, responding to my p] request for generating the data that had previously [q been requested by Dr. Kelly in his last reviewed p] memo, Exhibit Number 282. no] Q: Do you recall exactly what you asked Mr. [ii] Palm to obtain for you? [12] A: Yes. Those bits of the action points one [13] through seven in Exhibit 282 which pertained to the [iq Swedish part of the questions. I gave him the (isi complete list of items one through seven in case he [iq were able, from his contact with Jensen, to elicit any data about OECD, although OECD was broader than [iq Sweden, and, indeed, he did comment to that issue as (unwell. So, again, very practically, I got the pq question to the right person rather quickly and he pi] very rapidly responded and gave us the answers that P2I Dr. Kelly had sought. [23] Q: Mr. Palm also related to you that Jensen [2q wanted isomer samples, is that right? [25] A: Yes. Page 176 in Q: And you already knew that, because Jensen pi had mentioned that when you met with him? pi A: Jensen had alluded to these when we were in [q -- and, again, when he met with Palm, he also said pi remember, I talked to Mr. Wood about samples, and I [] had raised the issue inside Monsanto about pure p] isomers and you will see -- I'm sure we will come (q across a some documents in a few minutes, if not [91 tomorrow, which talk that issue and the time at [io] which we addressed that issue. In fact, we may [iij already have had a Baxter memo that we didn't touch [121 on that point, but I don't recall. [i3] Q: Do you recall a letter that you sent to [iq Soren Jensen on February 8, 1967? [iq A: No. I sometimes have to remember those who [iq I sent Christmas cards last year. No, I don't [i7] remember a letter that I sent to Jensen on February pq 7th -- February 8th. [i9] Q: One of the things that Mr. Palm told you in pq this letter of February 17, 1967 was that there were pij plans for future toxicological studies in Sweden, 1221 correct? [23] A: No. pq Q: That's not correct? psi A: That's not correct. _Page 177 pj Q: Why is that not correct? Pi MR. CHAMBERS: I object to the form, pj A: If we look to the paragraph one, two, three (q on the second page of this exhibit Page 172 - Page 177 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11025 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY number 283, we [si see that the work done by Mr. Jensen was paid for by [q the Committee for Conservation of Natural Resources, m the further studies planned for a toxicology have [8j not been started since there is no money available, pi So there is hope of toxicological work, there is no] concepts of toxicological work, there's no report pi] that toxicological work is going to be funded or [121 carried out. Ii3j Q: Do you know if such work was, in fact, ]i4] carried out? ]i5] A: Very limited work, because of the funding. [iq If you want to sort of say -- ask the question, was im money spent on toxicological work around psi polychlorinated biphenyls, a emporor's ransom was (isispent on toxicological work surrounding chlorinated po] biphenyls. How much of that was spent at the [2i] Carolinska Institute in Sweden? I would think (22] almost nothing. [23] Q: Were you concerned that -- strike that. 124] Were you concerned about the potential that [25] Monsanto's dielectric customers' polychlorinated Page 178 (i] biphenyls were escaping into the environment? pi MR. CHAMBERS: I object to the form, pi A: I think I can answer that, but since you [4] threw me a little bit, I'd like to - is] MR. CHAMBERS: Absolutely. And you should [q answer, if you're able, regardless of my objections, pj that's fine. I'm sorry that distracted you. pi MR. DUFF: Please read the question back to [9] the witness. [iq (The requested portion of the [ii] record read by the reporter). (i2j A: I'm going to ask you to qualify or rephrase ti3i the question around the word concern, because [i4] concern, in the context which I felt you used it [i$i determines, you know, a deep worry. Did I feel that tiqthe type of recommendations that we were already [17] making about the application of chlorinated [18] biphenyls in the manufacture of electrical [191 equipment -- [20] Q: No, that's not exactly what I'm asking, pi] A: -- if properly executed, would not lead to [22] any major burden on the environment? [23] Q: That's not what I'm asking. Let me see if I [24] can rephrase it for you. [25] A: Sorry, I just shifted the chair, can you Page 179 injust check that I'm still in your picture? Thank m you. pi Q: Were you aware that there was a potential (4] that Monsanto's dielectric customers' [q polychlorinated biphenyls were escaping into die iq environment? pi A: No. If they were manufacturing following [8] the procedures that we reviewed at their plants, if [9] there were any releases to the environment they [ioj would be so small they could not possibly lead to [in levels in the Deposition of DAVID WOOD NOVEMBER 9, 1995 environment which would be capable of [121 detection in the framework and limits that were [13] being hypothesized by Jensen. [14] Q: Is that because dielectric fluids are [15] intended for closed systems? [iq A: Dielectric fluids are designed into closed [i7] systems. The very stability says that that piece of [isi equipment then remains in useful service for many [i9] years. Its failure mode through the design of the pojequipment is such that you detect the unit has pi] failed while the fluid is still inside the pzi equipment, so that when you replace the equipment, [23] in most cases you recover almost one hundred percent [24] of the fluid that was in the failed piece of [251 equipment. So, answering specifically the question _______________ __________ Page 180 HI that you asked me, did I have any awareness that our pi dielectric customers were releasing or could pi potentially be releasing PCB into the environment, I [4] had an awareness that this is not a major problem. [5]Q: Were you aware that Monsanto's customers who [q used polychlorinated biphenyls in open systems may . n have their polychlorinated biphenyls escape into the [s] environment? (9) MR. CHAMBERS: I object to the form. [ioj A: From reading the Soren Jensen article, he [it]had theorized some transportation systems, and I'm [musing transportation systems in the ecological sense [i3jof how does a material move from one part of the [iq ecosystem to another part of the ecosystem to [15] another part of the ecosystem. The particular pq hypotheses that he had drawn did not seem, given the uti physical characteristics of chlorinated biphenyls, psi to be ones that would have resulted again in levels [19] of chlorinated biphenyls if that, indeed, was what [20] he was seeing, in the areas that he was seeing pi] them. So, an open system could potentially -- an [221 industrial open system use of chlorinated biphenyls (23) could release some chlorinated biphenyls to the [24] environment, but here you're talking about studies [25] which are examining and finding similar levels of Page 181 [i] concentrations of two chlorinated substances, one m being DDT, which people are liberally and (3) intentionally spraying into the environment, if you pq consider what DDT is used for and how it is used. I [5] mean, there society was intentionally spraying DDT iq into the environment. Now, sales of chlorinated pi biphenyls for industrial use were very much smaller (sj than the sales of DDT and the open applications were [9] only part of the situation, and their physical [icq characteristics were such that most of the open pu systems would still not be frequently releasing 112] substantial parts of their volume to the p3] environment. So, to answer your question -- see, pql'm getting to Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 177 - Page 181 HARTOLDMONOO11026 Deposition of DAVID WOOD NOVEMBER 9, 1995 an answer ultimately. Yes, you're p51 aware of an obvious release in the environment where pq you're intentionally spraying DDT into the \\i\ environment. You are aware of a potential move into cisi the environment, but at a very much lower level of [i9i frequency of an open industrial system. You are po] aware of almost zero potential for the involvement pu of substantial volumes of chlorinated biphenyls from [22] dielectric applications, closed by nature, giving [23] potential for environmental load. [24] Q: Why didn't Monsanto tell its customers who [25] were using fluids that contain polychlorinated ____________________ _____ Page 182 pi biphenyls in open systems at this time in February pi of 1967 that there was a potential for PCBs to get pi into the environment? [<q MR. CHAMBERS: I object to the form. [5] A: I don't know. I was accountable for [q dielectric fluids in Europe, and there was certainly p] no need to my mind to heavily publicize the Swedish pi work, which had little relevance to the dielectric [9] applications at that point in time. As we've seen (icq already today, there's some memos and other [iddiscussions going on. How that related to decisions (izj of non-electrical customers, I don't know. [i3] Q: Please mark this as Exhibit 284. pq ( Plaintiffs Exhibit 284 ps] marked for identification). [lq MR. DUFF: Mr. Wood, this document has been m marked as Plaintiff's Exhibit 284 and bears us] production number TRAN 085966. Do you recognize [ti this document? poiA: No. pu Q: Do you recognize the handwriting in the P2i upper right-hand comer of this document? [23] A: No. [24i Q: This document is dated February 21, 1967, [25] and is authored by R. Emmet Kelly*. , do you see that? _Page 183 Pi A: Yes, I do. pi Q: In the first sentence of this document Dr. p] Kelly refers to talking to you on the morning of w February 21, 1967. Do you recall that conversation? [5] A: I trust Emmet, and if he reported that he [q and I had a conversation on the morning of February m 21, 1967, I'm prepared to stipulate that we had such pi a conversation. - [9]Q: Do you recall what you discussed with Dr. po] Kelly on that morning? [in A: No. But this would likely -- again, I trust pq his -- [i3i Q; Was it typical for you to have telephone pq conversations with Dr. Kelly at this time? [is] MR. CHAMBERS: I object to the form, pq A: No. Again, the I want you to understand p7] that while the situation in Sweden was evolving, I pq was responsible for the European-wide market for pq dielectrics, and Sweden was a very small part of poi that TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY market. I had lots of wonderful experiences pi] keeping me busy day by day. But conscientiously, as p2]I received requests from Dr. Kelly such as the one I [23] sought the information on the seven points from pq Exhibit 282,1 reached Out and made sure that they [251 were effectively and rapidly handled. And when I Page 184 til got the response from Ola Palm, I would have called m Dr. Kelly. So, as he reports, he has 90 percent of p] the information asked for. That is totally [4] consistent with the way I ran my business. So - [5] Q: So as of this date you had given him 90 [q percent of the information he had asked you for? p] A: No. He said I have 90 percent. I . believe I pj may have sent it on to him by mail, pi Q: That is what this says. It says that you do] told him that you had 90 percent of the information pi]he asked for on February 10th? (12) A: And I will forward the bundle when I get the [i3] rest. ""...... - [i4] Q: And you told him that you would have that [lq information to him by the end of February, correct, pq 1967? (i7) A: I told him that it should be forwarded to [is] him and should arrive within a week of February the p9]21st, which would have been the end of February. [20] Q: You also told Dr. Kelly that your customers pi] were less concerned at this time than they had been pq since the publicity surrounding Widmark and Jensen's p3) findings had died down, correct? [24] A: No. I didn't say that. [25] Q: What did you say? Page 185 p) A: I said his customers -- he reports -- pi again, he tended to report fairly factually, that my [3] customers in Europe were less concerned than they [q were since there has been no particular government [5] activity. The government does not seem to have [q engaged itself on a particular witch hunt on an pi emergency timetable about this issue, and there's pi been no increase in newspaper articles. Didn't say [9] newspaper articles were still not appearing, but pq people seemed to be not pannicking, people seemed to pi]be willing to let good science work at the pace of pq good science. We didn't have a crisis situation p3] where people could be reacting to and pannicking to pqhalf truths, there seemed to be an environment where pq common sense and good science could work pq effectively. So -- but let's not sort of say I was [17] saying hooray, the problem's gone away. That's not [is] what I was saying. [i9i Q: You also told Dr. Kelly in this conversation pqon February 21, 1967 that your customers wanted pu reassurance on the toxicity of Aroclor, correct? > i Page 181 - Page 185 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11027 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 1221 A: Yes, I did. And, again, I don't know [zsi whether I used the word reassurance. He chose to [24] express my comments to Gene Wilde in that sort of 125] context. I guess I asked him that we had received Page 186 [i] some questions of people saying do you have any pi information about the effect of very small p] quantities of Aroclor on human health over extended m periods of time, and as he echos to Gene Wilde in [5] this memo, told me that information about the action (<q of nanograms of Aroclor in the human body over a p] life time isn't available. [8] Q: So he told that you there wasn't any p] experimental data on the effect of Aroclor on do] humans, is that right? [in A: No, he didn't say that. [12] MR. CHAMBERS: I object to the form. [13] A: He didn't report as saying that. There's no [i4] evidence available on the effect of Aroclor in nsj nanogram quantities in the human body over a nq lifetime of exposure. And that's different. [171Q: Did Dr. Kelly tell you anything with respect [is] to experimental data on the effect of Aroclor on [is] plant life? [20) A: No. pi) Q: Did he tell you anything about experimental m data on die effect of Aroclor on aquatic life? [23] A: Let me see if I can cut through this a m little bit. The industrial hygiene recommendations psi that Monsanto made to clients who used chlorinated Page 187 [i] biphenyls was based on not just sticking our ringers m in the air and saying do this, do that, do the p] other. There was some very industry accepted range m of fundamental toxicological testing of an acute csfnature, of skin contact type situations that had psjbeen done well, thoroughly and appropriately and p] were reported as a basis for the recommendations pi that we made about the use of our material. Now, at pi the time this work was developed, nobody knew there [io] were nanograms of anything. Lots of things in the (in environment, the methods to detect them didn't [12] exist. So, it's like if a tree falls in the forest [is] and nobody hears it, did it really fall. So the [i4] statement that Kelly is making at this period of [isi time is that the type of work that people would like [lq to see evidence of if they believe for the first [17] time that they may have identified the presence of [is] PCBs in veiy small volumes in the environment isn't [i?i there because the work has not been done to test pa] it. Does that mean Monsanto has done no responsible [211 toxicological testing in support of its product? [22] Damn, no. ' [23i Q: You're saying that Monsanto had done Deposition of DAVID WOOD NOVEMBER 9,1995 [24] A: We were leaders. We were leaders in psj industry in doing safety testing of the products ;_________________________ Page 18 [i] that we sold to our customers. [2iQ: Was that because Monsanto's customers [3] approached Monsanto with questions about the [4] toxicological effects of Monsanto's products or was [S] it because Monsanto was a responsible corporate [q citizen? P] MR. CHAMBERS: I object to the form, isi A: I'm sorry? [9] MR. CHAMBERS: I'm just noting an objection [icq to the form of that question. You should respond. [it] A: I'm going to respond, because I'm damn proud [121 of Monsanto. [13] MR. DUFF: Will you repeat the question? [14] A: No, I don't need to repeat the question, I [is] heard what you said, and I resent the suggestion. pq And I'll have that on file record. Monsanto had a very fine corporate reputation from the time I [i8]joined Monsanto. One of the reasons I joined [i9] Monsanto was because I found that they were a [20] company who took its responsibilities seriously in pt] delivering the benefits of chemistry to the [22] population. [23] Q: I'm not suggesting anything. [24] A: No, you asked me fairly forcefully a [25] question, I'm giving you a damn forceful answer, Page 189 [i] because I happen to respect what Monsanto has done, [21 not only in the PCB area, but in a lot of other pi areas of becoming a leader in responsible use of w chemicals. [5] Q: So, just because - I just want to make [] sure -- I understand your answer, p] A: Okay. Good. pi Qs And I appreciate your answer. Just so the (9] answer follows the question appropriately, I asked, [iojI guess, two things. The fist -- and it sounds [in like it's a pretty simple answer. But the first im question is, Monsanto conducted these toxicological (i3j tests over the years because Monsanto's customers [i4] had at times raised questions on these issues, is [i5] that right? [icq MR. CHAMBERS: I object to the form. [17] A: No. I'll answer it. I agree with you, it's [is] a lousy question, but I'll answer it. Monsanto, [19] from the outset, was and continued to be a leader in [20] furnishing safety data in support of its products, pi] If a customer in a specific area of application had [221 a question that the toxicological testing that we [23] had hitherto done did not provide an answer, we would normally sit down with them and sort of see (231 did we understand why they were asking the question __________________________ Pag in and what was involved in appropriately answering (2) them or allaying their fears, not burying their pi fears, appropriately allaying Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 185 - Page 190 HARTOLDMONOO11028 Deposition of DAVID WOOD NOVEMBER 9, 1995 their fears or [4] agreeing what would be an appropriate methodology to [5] get such test work concluded. If we were a sole [6] provider, we might say we need to, over the next pi couple of years, do this test. And when we say over m a couple of years, that was not to delay anything or pj reduce the cost of doing it, but if you want to do a no] one year feeding study, I can assure you as a [ii] non-technical person you need to understand that a [i2] one year feeding study takes two years to do. [13] Q: So Monsanto is -- [14] A: Monsanto was responsive from its own [is] volition to a very strong leadership role in product [i6] stewardship as early as 30 years ago, let alone [i7j where the corporation is today in that leadership, [is] And in terms of responsiveness to its customers [19] request for additional specific data related to tao] their specific applications, we were responsive. pi] Q: And just getting back ~ [22] A: Does that answer the question? pa] Q: Yes, I think it does. So getting back to my pt] original question, Monsanto was responsive like that [231 both because -- and this is what my original Page 191 [ii question was -- Monsanto was responsive in the way pi that you just described, both because Monsanto's [3] customers raised such questions and because Monsanto [4] was a responsible corporate citizen, correct? [3] A: I still object to the form of your question. (<l MR. CHAMBERS: Thank you. You saved me from pi having to do so. Go ahead, if you're able to. pi A: I mean, you sequence that sort of saying we pi were responsive when somebody asked us and no] additionally we did some sort of testing. I told [liiyou, the one -- reverse that in your question and[i2] I'll say yes. We did fine product stewardship and [13] if beyond that customers asked some specific [mi questions, we got involved and were responsive to [13] their needs. [161 MR. DUFF: Thank you. Off the record. [i7] (Recess), [is] [isn [201 [211 [221 [23] [24] [23] Page 192 in COMES NOW THE WITNESS, DAVID WOOD, and pi having read the foregoing transcript of the [3] deposition taken on the 9th day of November, 1995, m acknowledges by signature hereto that it is a true [3] and accurate transcript of the testimony given On pi the date hereinabove mentioned, p] pj pi______ [io] DAVID WOOD [in [12] Subscribed and sworn to me before this [13] day of , 1995. [i4] My Commission expires:______ [13] [16] [17]___________________________________ [is] Notary Public [is] po] pi] [22] rg P3] [24] PS] TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Page 193 in State of Missouri pi SS. pj City of St. Louis M I, Ronald A. Gore, a Notary Public in and for [3] the State of Missouri, duly commissioned, qualified [6] and authorized to administer oaths and to certify to pi depositions, do hereby certify that pursuant to pi Notice in the civil cause now pending and p] undetermined in the Commonwealth of Kentucky, Rowan [io] Circuit Court, Civil Branch, to be used in the trial [ii] of said cause in said court, I was attended at the [12] offices of Gore & Perry Reporting Company, 100 North [13] Broadway, in the City of St. Louis, State of [14] Missouri, by the aforesaid witness; and by the [i3] aforesaid attorneys; on the 9th day of November, [i6] 1995. [n]The said witness, being of sound mind and being [is] by me first carefully examined and duly cautioned [19] and sworn to testify the truth, die whole truth, and [20] nothing but the truth in the case aforesaid, pi] thereupon testified as is shown in the foregoing [22] transcript, said testimony being by me reported in p3] shorthand and caused to be.... transcribed into m typewriting, and that the foregoing pages correctly psi set forth the testimony of the aforementioned Page 194 [i] witness, together with the questions propounded by pj counsel and remarks and objections of counsel pi thereto, and is in. all respects a Ml, true, w correct and complete transcript of the questions [31 propounded to and the answers given by said witness; [6] that signature of the deponent was not waived by p] agreement of counsel, pi I further certify that I am not of counsel or [q attorney for either of the parties to said suit, not [ioj related to nor interested in any of the parties or [in their attorneys. [izi Witness my hand and notarial seal at St. Louis, [i3] Missouri, this______ day of [i4], 1995. [131 My Commission expires June 20, 1998. [i<s]____ [i7] Notaiy Public in and for the tis] State of Missouri [i9| poj m mpi] 123] [23] Page 190 - Page 194 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11029 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 0- 007566 132:23; 017390 102:15; 056034 161:8; 056035 124:12; 056036 152:12; 056616 174:22; 056619 162:9; 056624 115:17; 056625 122:5; 085947 136:19; 085950 137:18;137:19; 085966 182:18; -1 100 193:12; 10th 172:18; 184:11; 1254 130:5; 12th 115:23;133:4;133:15; 15414 5:21; 16th 133:12;133:16; 17th 175:6; 1960 10:18;10:21;10:24; 13:13; 1961 10:23;13:14;14:1; 14:18;19:24;21:4; 21:5;21:17;22:2; 23:12; 1963 37:11; 1965 14:18;18:25;19:24; 21:6;124:23; 1966 21:17;22:3;22:21; 23:12;23:16;27:9; 27:13;28:10;28:10; 33:21;35:3;35:18; 37:4^37:6^37:23; 45:4;45:5 ;70:7;70:10; 70:25;71:11 ;72:10; 72:11 ;76:23 ;78:20; 79:12;80:5;83:24; 87:25;92:19;94:18; 98:6;98:9;99:5;101:25; 102:6;102:21;103:3; 103:4;116:1 ;116:2; 119:5;121:13;122:15; 122:18;123:14;124:16; 127:5;153:3; 1967 127:6; 133:5 ;133:10; 137:I;137:25;145:19; 147:9;153:8;161:16; 161:19; 163:8; 168:7; 169:6;169:9;169:20; 169:23 ;170:3;170:17; 171:5;176:14;176:20; 182:2;182:24;183:4; 183:7;184:16;185:20; 1968 48:17; 1972 49:1; 1974 48:17;114:20; 1975 57:9; 1976 58:2; 1982 20:19;20:25;21:13; 67:9; 1988 67:9; 1993 68:9; 1995 192:3 ;192:13;193:16; 194:14; 1998 194:15; 1st 20:19;21:3;21:13; 35:14;58:2;70:9; 70:25;102:21;115:24; 2- 2,4,5 116:7; 200 72:1; 21st 184:19; 22nd 79:19; 26th 136:25; 273 20:7;20:10;35:7; 49:3;174:10;174:11; 274 l02:10;i02:Tl;102:15; 275 115:11;115:12;115:15; 276 121:25;122:1;122:4; 277 124:7;124:8;124:11; 130:21; 278 132:18;132:19;132:22; 279 136:14;136:15;136:18; 153:23;153:24; 280 152:7;152:8;152:11; 156:15; 281 161:3;161:4;161:7; 282 162:4;162:5;162:8; 163:19;171:22;172:1; 172:12;175:9;175:13; 183:24; 283 174:17;174:18;174:21; 177:4; 284 182:13;182:14;182:17; 28th 72:9;80:19;105:18; 4- 497-70-7571 5:24; 6- 60s 18:14; 63017 5:22; 7- 7th 176:18; 8- 8th 176:18; 9- 9th 192:3 ;193:15; -A- a-n-h-y-d-r-i-d 63:8; A-r-o-c-l-o 14:25; A _e.a 19:20;43:11; abaniscio 33:24; able 6:23;30:19;31:18; 46:13;48:7;50:6; 57:15;57:22;91:16; 123:17;132:11;142:11; 142:25;143:5;146:23; 147:25;148:3;159:11; 160:3;171:10;172:15; 175:16;178:6;191:7; about" 113:12; above 122:23; Absolutely 178:5; absorbed 110:5; absorbent 101:15;101:19;109:4; 109:24;111:1; absorption 101:9;109:4;109:23; 110:25; abused 127:22;143:24; academic 128:18; accepted 187:3; access 64:15;82:20; accommodate 7:23; accomodate 33:7; accomplish 149:24; accountability 29:18;118:25;119:3; 119:20; accountable 182:5; Deposition of DAVID WOOD NOVEMBER 9, 1995 accumulated 74:21;159:18;75:18; 75:22; accumulating 81:8;92:15;119:19; accumulation 71:12; accuracy 35:14;37:20;104:25; accurately 20:23;24:16;35:1; 35:5;49:5;92:23; 21:14;29:22;50:6; 80:17;84:16;122:22; 146:11;192:5; achieved 156:4; acknowledges 192:4; acquired 66:18;140:9;151:4; acquisition 40:13; across 26:16;63:25;119:22; 140:8;176:8; acting 26:25;168:1;168:3; actions 92:11;89:24;90:23; 92:10;112:18;117:8; 175:12;186:5; actively 95:20;12:19;63:12; activities 20:23; activity 185:5; Actually 105:25;117:14; actually 70:13;70:16;148:12; 139:12;143:13;24:21; acute 187:4; added 17:14;25:21;27:2; additionally 108:11;191:10;22:14; 24:25;25:2i;27:2; 28:22;28:25;128:11; 190:19; additives 17:8;17:9;17:11; addressed 78:9;102:22;137:2; 137:2;176:10; addressee 162:15;173:21; addressing 52:2;151:14;5:20; 81:9;81:23 ;147:25; 97:1;173:2; adequate 29:21; adhere 63:12; adhesives 67:14; adjunct 126:19; administer 193:6; Adolph 111:11; advertising 34:6; advice 80:23; advised 128:24;137:7; advisor 105:20;112:7; aerospace 51:25; affiliates 53:10; aforementioned 193:25; aforesaid 5:4;193:14;193:15; 193:20; Africa 28:2; African 28:4; Again 26:3;145:21;183:16; against 97:3;31:17;38:2; 44:23;45:18 ;48:25; 60:3;78:24;88:25; 89:4;91:20;93:8; 93:9;97:11;99:13; 100:22;107:18;111:5; 111:6;117:11;117:11; 126:7;129:1 ;141:15; 144:12;148:23;156:20; 158:17;159:24;166:5; 175:19;176:4;180:18; 183:11;185:2;185:22; Agencies 27:24; agencies 26:14;26:25;27:1; 27:19;27:24;28:2; 28:7;34:7; agency 28:14;37:1 ;40:22; 41:12;42:15;44:12; agents 26:20;27:10;27:12; 28:1 ;28:1 ;35:22; 175:5 ;35:25;40:10; 42:13;44:14;72:15; 5:2; aggressive 39:18; ago 22:18;26:6;45:18; 51:10;84:8;86:20; 96:11;98:3;138:9; 158:19;190:16; agreed 64:13; agreeing 190:4; agreement 64:2;135:9;194:7; 31:12;32:17;78:12; 78:17;89:9;155:18; 161:14;189:17; agricultural 66:17;66:22;94:1; agriculture 94:11; ahead 111 :4;136:6;139:14; 149:10;191:7; aircraft 49:18; airline Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 007566 - airline HARTOLDMONOO11030 Deposition of DAVID WOOD NOVEMBER 9, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 52:7;43:15;54:22; 54:25;55:4;59:6; 80:15;163:21; 164:7; 187:2; alert 120:8; alignment 115:8; all" 31:6; allaying 190:2;190:3; allowed 147:4;147:23;7:5; 23:4;82:20;117:24; alloy 14:9; alluded 68:8;152:22; 173:20; 176:3; almost 61:8;61:24;96:11; 156:3; 177:22; 179:23; 181:20; alone 119:2;190:16; alongside 169:3 ;7:2;89:22; ... .... 96:17; already 50:17;59:17;66:25; 108:5;169:6;176:1; 176:11;178:16;182:10; alternatives 60:7;58:9; although 175:17; always 16:21;122:22;131:21; America 23:7;23:8;42:1;53:2; 64:5;66:24;69:13; 82:22;108:25;148:7; America" 108:19; America's 64:16; American 9:22;23:2;69:15; 162:19; Americans 42:3; Americas 68:5; amongst 40:7;81:7;113:18; 166:16; amounts 17:15;65:4;140:3; 157:19;164:8; amplification 18:4; analysis 93:8;139:25; Analytical 73:14; analytical 8:22;9:7;126:5;126:15; 128:6;133:25;147:4; 147:17;159:25;160:4; 171:18; and/or 170:24;170:24; Anhydride 63:8; anhydride 63:5; animals 74:22;75:19;75:22; 160:6;129:14; announcement 35:15; annualized 45:17; answer" 101:2; answered 97:16;111:7; answering 106:21 ;110:16;111:5; 179:25;190:1; anybody 23:25;53:16;53:21; 68:18;79:21;132:3; 132:6;149:3;149:7; 149:12;149:15;149:17; anyone 21:21 ;22:4;82:23; . 120:19; anyway 142:18; Anywhere 165:15; anywhere-------------------- 93:2;165:14; apart 96:14; apparent 16:8; appeared 80:6;120:11;122:15; 140:18; appearing 158:6;185:9; appears 130:23 ;130:24;137:18; 162:14;139:23;157:8; applications 34:8;58:10;62:12; 93:6;94:9;107:12; 145:4;145:5;181:8; 181:22;182:9;190:20; 14:4;14:6;29:2;29:5; 31:22;47:22;55:I3; . 98:2;178:17;189:21; appointed 22:11;24:20; appreciate 6:25;7:5;189:8; approached 13:21;144:2;144:19; 188:3 ;58:19; appropriately 58:8;58:19;81:23; 132:11 ;187:6;189:9; 190:1 ;190:3 ;29:11; 30:12;35:12;40:14; 40:16;82:20;89:24; 90:22;92:7;104:19; 110:6;110:13;111:8; 143:12;154:23;155:17; 170:20;190:4; approximately 13:2;67:9; aquatic 186:22; architectural 34:7;60:20; areas 14:12;32:11;64:9; 122:25;180:20;189:3; 11:21 ;56:12;62:12; 63:14;66:11 ;81:21; 87:4;95:24;96:1; 118:20;119:8;123:2; 128:5;147:10;160:15; 189:2;189:21; arena 49:1; Aroclor 12:12;14:25;15:4; 15:6;15:9;15:16; 15:20;16:1;16:17; 16:20;16:22;17:3; 17:4;17:6;18:11; 19:6;32:5;32:6;32:12; 32:19;43:2;76:19; 77:11;77:23;78:5; 89:5;101:1;101:6; 109:19;110:8;110:20; 110:25;111:9;130:5; 137:1;150:3;156:10; 156:11;157:16;157:21; 158:9;163:20;185:21; 186:3;186:6;186:9; 186;14;186:18; 186:22; Aroclor" 140:25; Aroclors 16:25;46:23;72:22; ----74:2;75:24;91:1; 111:13;111:22;134:10; 134:15;138:15;156:16; 156:22; around 29:4;30:6;49:18; 54:10;56:9;57:13; 63:21 ;90:21;96:14; 119:12;123:7;129:12; 130:8;140:4;177:17; 178:13; Arpino 111:10;111:11;111:20; 111:21; arranged 149:1; arrangements 128:22;40:16;104:11; arrived 85:1;184:18; arrogance 167:12; articles 120:23;123:13;123:17; 185:8;185:9;80:6; 80:11;80:25;81:16; 88:13 ;92:18;99:15; 99:15; 120:10; 120:11; 120:25;122:14;155:7; 180:10; Asea 19:19;19:19;43:11; Asia 69:13; Askarel 60:16; askarels 60:10;60:22;61:8; 6:14;60:12;60:16; 60:23 ;61:3;61:4; 61:7;61:9; aspects 155:16;69:9; aspirations 69:12; aspirin 12:10;47:25;48:1; 48:2; assertions 139:16; assessment 117:2; assigned 11:19;13:6;13:13; 13:20;14:1;28:21; 48:8;70:23; assignment 50:10;52:12;62:24; 70:12;162:22;163:7; assistant 10:23;11:19;13:7; 13:17;14:11;19:23; 19:25;21:2;21:16; 22:11;114:25; associated 72:20;76:18;85:24; 89:21 ;105:5;121:16; 126:21 ;139:21 ;144:19; Associates 68:20;68:22;68:24; associate 125:16;125:18;135:23; Association 46:1; assumed 21:3;22:14;50:16;........ - 82:5;89:16;114:19; 119:21 ;132:8;70:24; assuming 89:12;111:21; assumption 76:10;77:24;78:5; 166:18; assured 134:25;135:4;135:11; 190:10; attached 129:10;130:1;137:12; 137:17;137:24;141:6; 142:2;149:4;153:16; attaching 138:2;138:10;148:12; attempt 7:14;87:7; attended 8:8;139:5;152:23; 152:24;170:8;193:11; 132:6; attention 42:8;77:6;78:24; 84:6;88:25;100:22; 104:8;116:3;120:14; 138:5;141:23;144:9; 145:24; 151:25;163:25; 172:6; attorneys 193:15;194:11;194:9; Australia 50:2;50:2;50:6;50:7; authored 182:25; authorities 32:23;107:9;107:17; authority 170:16;173:24; authorized 193:6; authorship 127:10; available 101:21;102:2;128:25; 140:10;166:25;166:25; 169:5;169:8;177:8; 186:7;186:14; Aviation 49:16;56:13; aviation 12:12;18:15;50:4; 50:11;51:20;51:21; 52:8;54:16;56:13; avionics 49:23;51:25; * I . '' avoid 33:12; ; awareness 180:1;180:4;56:19; 1 79:21;90:4;92:14; 100:17;106:13;111:25; 121:4;124:22;124:24; 125:12;126:3;126:13; i ! 149:8;159:6;159:6; 159:6; 165:10;165:20; 166:1 ;166:15;168:7; 179:3;180:5;181:15; 181:17;181:20; | 1 away 57:2;57:23;160:17; 185:17; awe 142:24; .......-B-............. -.....- | B-a-y-e 44:22; ^] b-i-p-h-e-n-o-l 75:11; b-i-p-h-e-n-y-l 77:14; B-i-s-p-h-e-n-o 98:15; baby 80:16; backdrop 140:17; ) 1 .( background 8:5;44:23;104:20; 128:15;157:4;172:14; 21:22;23:9;31:1; - .! '' 34:23;35:12;44:1; 45:19;64:5;67:12; 68:4;91:20;98:23; 105:4;112:21;115:7; 143:1;147:22;156:1; 174:5;178:8;190:21; 190:23; badly 143:11;143:17;99:23; 145:20; balance 57:18; based 10:24;15:10;22:8; -- 22:17;28:3 ;43:6; 43:20;45:3;50:22; 56:8;65:23;89:11; 104:9;104:23;105:22; 187:1; bases 168:9;19:15;29:8; 40:25;170:24; basically 142:3 ;9:6;9:6;9:11; basis 38:17;45:17;58:20; 92:8;139:14;167:14; 168:5;168:16;187:7; Baxter 136:9;136:10;148:2; 176:11; Bayer * airline - Bayer Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONOO11031 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 43:20;44:21 ;44:22; 146:14;157:18; 102:15;115:16;122:5; 124:11 ;132:22;136:18; 152:11;161:7;162:8; 174:21;182:17; beatle 97:3; beautiful 96:9; became 11:19;13:6;13:15; 13:17;20:1;21:5; 24:18;25:8;28:23; 28:25;29:18;33:15; 33:20 ;34:16;57:5; 58:1;68:5;75:8;94:17; 150:22;151:1;156:4; 159:22; become 11:11;29:12;34:21; 35:17;35:20;46:13; 48:12;48:18;48:19; 57:7;62:9;66:9;70:17; becoming 28:15;69:8;189:3; began 10:4;10:10;10:21; 18:24;20:24;37:12; 37:22; beginning 8:5;12:14;45:14; 58:15;67:24;70:6; 155:9; begins 84:9;9:18;10:19; 14:16;37:9;71:5; 140:17;169:4; begun 37:18; behooves 93:13; Belgian 106:5; Belgium 23:16;23:24;37:16; 46:15;46:17;111:14; beliefs 159:3; believed 30:16;72:19;74:1; 157:14;168:9;168:12; 168:22;23:23;25:5; 26:9;35:4;35:16; 35:19;44:25;51:3; 99:6;99:9;99:10; 111:16;117:1S;122:20; 132:18;136:7;137:10; 141:22;142:18;146:18; 148:20;148:23;153:9; 154:5;155:3;162:20; 168:21 ;171:1;184:7; 187:16; below 122:24; benefits 31:21;34:7;46:7; 188:21 ;51:13;52:14; 90:24;91:2;114:11; Benelux 27:21;46:17; Benignus 82:12;82:15;82:20; 83:4;83:6;83:8;83:25; 102:24;102:25;103:14; 137:4;148:5; benzene 129:3;129:4;129:9; 130:1;140:2; best 32:2;143:15;147:24; 148:3;171:3;171:10; 174:2; better 64:13 ;144:13;146:24; 15l:20;159:22; beyond 11:13;22:22;143:13; 160:15 ;191:13; Bicc 19:3; billion 66:2; binder 12:13; bioaccumulations 159:23; biodegradation 94:25; biodegraded 157:25; biorefractory 159:22; biphenols 74:25;75:7;75:9; 75:14;77:22;87:12; 87:15;87:19;88:2; 88:5 ;88:16;88:18; 88:22;92:14;93:4; 97:5;97:12;97:24; 98:2;134:19;85:13; 86:4;86:17;86:22; 87:11;88:8; biphenyl-based 59:11; biphenyl-containi ng 61:5; biphenyls 15:13;15:21;18:19; 36:14;38:5;38:8; 38:10;38:12;39:17; 39:22;43:14j43:21; 45:11 ;46:10;50:19; 51:5 ;72:20;72:22; 74:21;76:2;76:5; 76:18;76:24;77:10; 77:13 ;77:14;77:23; 78:15;82:2;87:18; 89:13;90:14;90:16; 91:4;91:22;91:25; 93:3;94:22;100:18; 101:8; 104:22; 106:10; 106:15;108:1;108:6; 108:10;129:2;134:20; 136:13;140:8;140:15; 140:16;141:9;141:18; 142:5;142:14;144:20; 155:2;155:6;155:11; 156:7;156:10;156:12; 157:15;157:18;157:22; 158:3;158:6;159:18; 165:25;166:3;166:6; 166:9;166:19;177:18; 177:20;178:1;178:18; 179:5;180:6;180:7; 180:17;180:19;180:22; 180:23;181:7;181:21; 182:1;187:1;15:10; 15:i5;15:16;15:23; 17:2;43:6;43:17; 45:3 ;47:8;60:21; 61:7;78:3;104:18; 107:7;107:11 ;108:7; 129:4;129:5;129:11; 129:13;130:6;140:24; 145:3;150:6;156:2; birds 159:19; Bisphenol 98:17; bisphenol 98:14;98:16;99:4; 99:8;99:11 ;99:12; bits 168:20;168:22;175:12; 31:7;34:3;80:25; 87:17;125:23;178:4; 186:24; 116:12;116:18;142:25; blades 14:9; blend 15:15;16:15;16:17; 16:21;17:4;17:6; 169:9; Board 89:5;90:6;90:17; board 35:6; body 186:6;186:15; Both 38:25;69:15; both 22:16;57:21;71:2; 71:6;106:1;109:6; 122:23 ;147:14;190:25; 191:2; bottom 81:11 ;145:24;161:18; bought 65:2;65:2;65:12; 65:12;65:13;65:14; 65:23 ;66:1;66:2; box 142:25; boy 19:3;101:12;131:12; Branch 193:10; Brazil 53:2;66:9;66:21; 66:24;67:1;67:5; 67:12; Brazilian 66:12;67:1;67:2; breakdown 95:9;7:22;52:11; 94:23 ;95:5;95:8; 110:22;132:15;158:1; brief 73:6; bring 42:7;116:11;120:13; 148:3; Britain 19:6;19:13;24:8; 46:11; Britian 46:9;46:20; British 9:22;19:4;19:12; 24:22;154:3; broader 175:17; Deposition of DAVID WOOD NOVEMBER 9, 1995 broadly 107:13; Broadway 193:13; broad 12:18;65:13;99:12; 159:12;170:12; brochures 109:3; broken 66:16; brought 151:24; browse 123:8; Brush 19:13; Brussels 24:9;24:12;24:17; 24:20;26:11;39:24; 40:1;40:3;40:7;46:15; 70:14;70:22;71:2; 71:6;71:10;71:20; 71:21;74:13;102:21; 111:11 ;113:2;133:6; 133:14;136:25;137:5; 162:20;175:6; Buchanan 102:22;102:24;103:1; 103:4;103:11;103:12; 103:15;103:21;103:25; 104:2;104:3;104:7; 105:17;107:4;107:24; 114:5;115:24;137:3; 138:12;145:8;148:5; 153:14;162:16; built 66:25;96:10; bulletins 115:3; bundle 184:12; burden 178:22; burial 101:10;101:19; burn 160:13;160:14; burying 101:1 ;110:4;190:2; busily 159:10; businesses 12:7;21:24;64:12; 66:25;151:3;9:25; 12:6; 18:18;23:2; 23:3;23:23;24:1; 24:14;37:14;42:6; 42:18;43:16;45:22; 47:20;48:4;48:7; 48:9;48:14;48:25; 50:3;50:4;50:9;51:18; 51:20;51:21 ;51:22; 51:24;52:5;52:7; 53:19;56:10;57:2; 57:23 ;60:11;62:10; 62:15;63:14;63:15; 63:18;67:14;67:14; 67:15 ;67:15;67:21; 67:25;68:2;68:4; 68:6;68:15;68:19; 68:21 ;68:23;68:25; 69:17;69:18;69:23; 82:16;86:1;115:7; 121:8;150:3;150:7; 166:6;166:8;184:4; busy 58:22;183:21; buying 64:22;65:4 ;65:21; 149:23;150:15;150:16; -c- C-a-f-f-a-r 44:25; C-a-m-e-r-o 23:19; c-o-p-o-l-y-m-e-r 63:9; c-r-a-c-k-e 64:25; Cables 19:4; Caffaro 44:25; Calendar 19:4; California 6:9; called 14:25;15:2;22:13; 36:2;43:7;43:11; 44:23 ;44:25;45:25; 47:19;49:16;59:14; 68:19;74:21;88:1; 98:14;102:25;113:5; 154:3;157:16;161:15; 164:17;184:1; calling 23:23;107:20; calls 158:15;44:21;73:6; 73:8;73:23 ;73:25; 83:11 ;96:21 ;113:3; 113:7; Cambridge 8:8;8:11;8:20;121:21; Cameron 23:18;24:2;25:4; 34:20;137:4; Cameron's 23:20; came 16:20;59:2;60:1; 67:12;146:2;153:1; Campbell 22:16;23:14;23:17; 23:18;23:25;25:3; 25:6;34:17; cans 96:20; capability 14:22; capable 41:12;179:11; capacitors 14:24;19:8;19:10; 43:10;59:22;59:25; 14:25;19:2;19:5; 32:3;32:4;60:3;60:5; 145:1; capacity 24:25; capital 67:3; caps 54:6; carbonless 62:16;63:13;63:15; carbons 110:22;63:18; cards Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Bayer - cards HARTOLDMONOO11032 Deposition of DAVID WOOD NOVEMBER 9, 1995 176:16; career 20:19;20:20;25:15; 47:4;53:14;63:25; 64:8;64:10;65:10; 68:10;68:18;125:11; 163:6; carefully 193:18;87:17;89:7; 156:5;143:7; cargoes 40:16; Carolinska 126:19;177:21; carried 92:3;141:7;142:3; 177:12;177:14; carrier 50:6; carrying 26:24; cases 52:2;109:7;179:23; 5:4;6:9;6:10;6:13; 17:19;32:3;34:8; 175:15;193:20; castings 14:8;14:7;_____________ categories 63:1; categorized 130:3;147:5;123:17; 139:1; categorizing 120:10; category 52:1;166:17; catylists 65:13; caused 193:23; cautioned 193:18; cease 59:19; centered 136:11; centers 27:20; centrally 29:14;24:10;24:15; 98:16; Centre 79:11; Certainly 77:5;79:1;97:10; 144:14;167:5;173:19; certainly 41:15;54:24;56:9; 78:3;79:20;92:12; 120:8;153:19;182:6; certainty 148:24;12:8;41:2; 74:22;81:18;107:15; 125:12;147:4;169:5; certify 193:6;193:7;194:8; Chagrined 131:16; chair 178:25; Chambers 5:11;5:11;10:5;20:12; 30:17;30:19;30:22; 31:17^5:23^6:2; 63:6;72:3;74:8;77:2; 86:5;86:10;86:12; 86:15;86:18;87:2; 91:6;91:15;95:13; 95:19;97:7;97:15; 97:20;110:1 ;111:3; 116:16;120:5;122:19; 123:15;123:23;125:6; 136:5;141:13;141:20; 146:22; 149:9;150:4; 151:10;156:18; 156:25; 161:17;162:1 ;165:2; 167:2; 167:9;168:18; 169:7;169:21;170:5; 171:6;177:2;178:2; 178:5 ;180:9;182:4; 183:15;186:12;188:7; 188:9;189:16;191:6; chance 126:7; changed 22:20;24:14;24:17; 28:17;28:18;28:18; . 50:17;99:21; ' changes 29:15;103:18;24:5; 24:13;25:10;28:11; 33:23;47:17;59:19; 64:3;70:12; changing 26:12;28:6; channels 121:1; chapter 154:16; characteristics'' 158:24;16:12;59:24; 158:15;159:1;180:17; 181:10;16:11;59:12; characterized 129:21;121:22;160:7; charge 44:4; Charlie 19:3 ;19:3; check 42:10;49:6;179:1; Chemical 121:14;121:15;16l:15; 161:19;161:22; chemically 94:21; Chemicals 9:16;9:19;10:3;10:9; 133:20; chemicals 12:9;12:11;30:9; 31:22;40:17;48:12; 48:14;49:9;61:24; 62:3 ;62:5;62:9;62:13; 62:19 ;63:3 ;63:23; 64:19;64:20;66:17; 66:22;67:4;81:3; 81:20;93:5;140:6; 140:7;189:4;8:23; 9:20;9:22;44:20; 47:20;47:25;62:10; 62:14;64:7;64:9; 64:10;64:12;64:16; 65:11;65:15;65:23; 66:4;66:10;66:11; 66:16;66:20;72:19; 75:21;75:23;76:1; 85:3;93:23;99:13; 140:3;140:23;150:25; 156:22;157:7; Chemistry TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 73:14; chemistry 8:10;8:12;8:17;8:19; 8:21;8:21;8:22;8:22; 9:1;9:5;9:6;9:7; 9:10;18:22;81:21; 95:15;125:16;125:17; 147:11 ;155:13;188:21; 143:1; Chesterfield 5:19;5:21; Chicago 6:10; chief 154:19; chloride 17:16; Chlorinated 97:12; chlorinated 15:10;15:12;15:15; 15:16;15:21;15:23; 17:2;18:19;36:14; 38:5;38:8;38:10; 38:12;39:17;39:22; 43:6;43:13;43:17; 43:20;45:3;45:11; 46:10;47:8;50:18;---------55:17;55:22;59:10; 60:21;61:4;61:7; 71:13 ;72:20;72:21; 75:2;75:18;76:16; 76:23;78:13;78:21; 85:9;85:12;85:12; 85:15;85:17;85:20; 85:24;86:3 ;86:9; 86:17;86:23;88:5; 88:8;90:13;90:16; 91:22;93:11;93:13; 94:8;94:11;94:15; 94:20;94:22;95:1; 95:4;95:5;95:8;95:11; 95:16;95:17;95:21; 96:13 ;96:16;96:23; 97:5;97:24;98:2; 98:8;98:11;98:17; 99:24;100:2;100:5; 100:9;100:12;100:17; 107:7;107:11;108:10; 116:6;119:18;129:2; 139:16;140:24;141:8; 141:18;142:5;142:14; 144:20;145:3;150:6; 156:2;156:7;156:9; 156:12;157:15;157:18; 157:22;157:24;158:3; 158:6;165:24;166:6; 166:9;166:19;177:19; 178:17;180:17;180:19; 180:22;180:23;181:1; 181:6;181:21;186:25; 129:5; 129:7; chlorination 15:23;16:4;16:10; 16:13;129:22;130:13; chlorines 129:9;129:11;130:6; 130:7;130:7;130:9; 130:10;130:10;130:11; 130:15;130:1;130:4; 130:17;134:11;140:3; 160:9; choose 154:21; chose 9:18;10:2;40:19; 76:9;99:16;114:7; 154:22;166:9;185:23; Christmas 176:16; chromatography 147:8;146:20;148:16; 149:18;150:12;151:5; cinema 107:19; circle 167:18; Circuit 193:10; circulated 133:5; circulation 133:5;137:10; citizen 188:6;191:4; City 193:3 ;193:13; Civil 193:10; civil 193:8; claimed 75:21;143:5; claims .................... ...... 126:8;134:25;135:11; 131:19; clamp 54:6; clarification 150:14;167:21; clarified 168:14; clarify 7:13;10:8;13:4;15:17; 26:4;27:4;31:4;81:13; 82:1;106:16;106:24; 108:14;158:13; classes 140:7; classic 131:12; classified 13:10; classify 8:14;110:11;60:22; 75:5;76:15;78:2; 81:3 ;85:3;92:25; 93:5;93:11; clay 101:15;101:18; clearance 42:21; clearer 121:9; clearly 142:12;10:16;36:22; 87:2;87:5;97:11; 98:20;105:2;113:20; 118:23;120:19;140:19; 141:8;141:18;142:4; 144:21;166:1;166:5; 166:20; clients 186:25;29:8;170:24; closed 179:15;179:16;181:22; closely 81:22;94:20;94:22; coast 65:8; Coated 96:2; coatings 63:12; cold 56:16; colleagues 69:15;80:23;82:7; 119:3;120:9;143:2; 155:7;lll:li; ' collecting 17:15; collection 62:8; collective 65:5; Cologne 43:20; coloring 63:11; combinations 130:14; combined 146:20;147:3;149:18; 150:12;150:16;150:21; 151:5; coming 120:16;128:19; comment" 154:9; . commented 154:13; comments 128:3; 185:24;98:23; 105:3;114:24;149:22; 154:17;154:20;154:22; 154:23 ;154:24;175:18; commerce 99:13;140:6; commercialization 95:15;95:21; commercially 39:18;129:2;140:10; 14:23 ;27:25;39:10; 49:18;66:9;69:8; 82:18;98:1;127:23; 129:13;147:22;151:21; Commission 192:14;194:15; commissioned 193:5; commitment 59:18; Committee 177:6; Commonwealth 193:9; common 24:9;150:25;185:15; communicated 82:6;115:10;164:25; 165:24;168:15;57:16; 107:10;107:12;107:14; 132:12;171:10; communications 83:2;131:20;164:16; 164:21;165:6;165:10; 165:17;166:2;166:7; 166:10;166:12;166:15; 166:17;166:19;36:8; 37:19;111:25;165:8; 165:20;170:12; Community 46:6; community 46:19;80:24;104:16; 119:13;121:3;147:24; 151:19; cards - community Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11033 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY companies 9:22;19:7;19:9;19:18; 43:18;44:4;44:5; 52:22;53:8;53:9; 54:10;54:14;69:7; 110:4; Company 5:10;19:12;145:11; 193:12; company 36:2;43:7;44:16; 44:23;44:25;59:14; 69:11 ;69:14;82:21; 118:24;131:17;141:4; 188:20; competed 44:18; competition 45:11;76:20;108:8; competitive 38:6;39:12;39:15; 39:16;39:21; competitor's 91:24; competitors 42:25; completed 8:5;8:9; completely 168:20;34:3 ;66:19; 130:12;175:15;194:4; complex 130:18; components 15:15;16:22;62:10; 52:4;55:1;63:16; 159:10; composition 125:4;156:22; compounding 63:17; compounds 17:13 ;55:18;71:13; 75:6;76:16;76:24; 78:2;78:21;88:10; 93:11;119:18;134:18; 17:19;17:22;18:1; 18:5 ;75:2 ;75:18; 78:13; compress er 54:25; compressors 54:22;55:4; concentrated 118:4; concentrations 32:25;147:6;181:1; 147:11; concepts 177:10; concerned 76:11;76:14;85:2; 88:11;144:3;173:12; 177:23;177:24;184:21; 185:3; concerning 72:19;73:13;172:21; 107:6;127:21;178:13; 178:14; concerted 120:25; concluded 68:10;190:5; conclusions 99:17;135:9;143:13; 152:3;160:23;160:24; 169:13;65:20;140:1; 155:4; concrete 99:17; conditions 60:20; conducted 58:19;151:25;163:10; 189:12; conducting 42:7;126:5;126:15; 151:2;57:23;149:7; 149:13; conference 152:21; confidential 128:17; configuration 26:13;140:7; confirmed 152:23;138:9; confused 141:11;167:19; confusing 87:22; confusion 98:18;99:14;140:21; conjecture 73:4;159:14; connection 81:1;81:2; Conoco 65:1;65:2; conscientiously 183:21; consensus 171:23;172:10;172:13; consequences 150:6; Conservation 177:6; considerable 84:14;85:5; considerably 94:23; considerations 39:11;94:18; considered 61:2;94:15;94:17; 118:9;170:15;104:19; 130:14;181:4; consistent 101:5;138:14;184:4; constants 15:9; constituents 17:5; constrained 157:5; consultation 170:19; consulting 69:23 ;69:24;170:20; contacted ' 82:12;83:4; contacting 23:1; contacts 115:6;147:22;24:21; 27:22;32:12;40:11; 53:13;82:9;82:19; 83:6;83:8;117:5; 137:4;137:9;149:3; 175:16;187:5; contained 16:17;18:5;36:13; 55:22;56:14;58:25; 82:10;134:12;145:14; 145:15; containing 58:10;134:12;170:25; containment 101:10;15:12;18:19; 50:14;56:6;56:21 ; 96:23;181:25; contaminants 134:4; contaminated ' 99:21; content 165:18; context 15:19;26:5;26:10; 53:19;82:17;118:2; 168:1 ;178:14;185:25; continental 39:19;45:15; continued 189:19; contracts 45:12; contribute 171:14; convenient 100:25; conversations 56:7;183:14;73:1; 73:20;127:16;127:19; 128:9;144:7;183:4; 183:6;183:8;185:19; conversion 58:12; convey 30:15;31:13;31:20; 32:18;82:10;168:16; 171:4; coolants 18:16;59:3;61:1; 15:2;18:10; cooled 43:15;59:6; coordinate 33:16;40:13;173:24; coordinating 115:2; coordination 29:9; copied 112:11;114:14; 137:3; copies 128:14;148:18;153:5; 162:16;163:15; Copolymers 63:9; copolymers 63:5;63:9; copper 63:20;63:20; copy 20:11;72:1;103:4; 111:19;112:2;112:13; 114:8;115:24;123:7; 133:6;133:7;133:13; 137:7;152:20; 153:21; core 129:11;129:13; corners 84:14;161:18;182:22; corporate 171:13;188:5;188:17; 191:4; Corporation Deposition of DAVID WOOD NOVEMBER 9, 1995 59:14; corporations 69:19 ;30:7 ;65:24; 190:17; correctly 79:14;124:25;193:24; corresponded 27:13;36:6;37:3; 37:7;38:14;38:23; correspondence 36:10;83:17;119:6; 119:22; corresponding 35:22;37:9 ;37:23; 27:10;37:21; cost 190:9; cotton 63:11; couldn't 86:13;92:12;99:17; 118:10;124:2; counsel 7:16;20:11;72:2; 194:2;194:2;194:7; 194:8; countries 19:18 ;25:22;26:1; 26:9;26:14;26:16; 26:25;27:1;27:10; 27:12;27:16;27:24; 28:4;28:7;35:23; 41:10;41:14;44:11; 45:24;46:2;53:1; Country 5:21; country 28:3;28:9;42:5;44:14; 52:6;52:9;54:13; 84:25;113:17;113:19; coupled 59:5;6:20;43:25; 59:7;103:18;190:7; 190:8; courses 8:19;8:23;8:24;9:1; 9:12;69:4;89:24; 90:23; Court 193:10; courtesy 7:7;115:5;115:9; 6:23;193:11; covered 97:21 ;61:21;153:16; cracker 64:24; created 68:1; credibility 160:20; credible 157:14; credit 40:15; creeps 99:23; crisis 185:12; critical 164:7;164:18;164:24; 165:7;165:9;166:23; 167:23; crossed 168:10; cultivation 105:9; Cumming 69:21; Cunningham 104:2; currency 95:6;131:9; currently 93:2;16:19;16:19; curriculum 20:18; curve 157:10; customers 13:21 ;18:23 ;19:16; 23:5 ;24:22;29:23; 30:1;30:15;31:14; 31:20;32:18 ;33:11; 34:8;40:12;40:13; 40:19;42:24;42:24; 51:14;52:15;52:19; 52:24;53:25;54:1; 54:18;54:19;54:21; 55:3;55:17;55:21; 57:16^57:21 ;57:22; 102:7;164:17;164:18; 164:21;165:7;165:11; 165:12;165:13;166:2; 166:8;166:11;166:24; 167:20;167:23;168:17; 169:19;170:4;171:4; 172:20;177:25;179:4; 180:2;180:5;181:24; 182:12;184:20;185:1; 185:3;185:20;188:1; 188:2;189:13;190:18; 191:3;191:13;19:6; 19:15;29:13;30:11; 40:25;57:13;164:25; 165:9;165:17;165:23; 166:16;170:12;189:21; customs 42:20; cut 186:23; cyclical 88:10; -D- D-i-a-t-o-m-a-c-e-o-u 101:13; D.v 105:19; daily 80:7;80:11;81:16; 84:24;166:7; damage 6:13;6:14;95:11; Damn 187:22; damn 188:11;188:25; danger 143:10; Darby 130:23;131:2;131:4; 131:5; data 99:12;104:12;106:9; 106:14;107:10;107:25; 108:6;108:9;140:16; 169:15;170:13;171:17; 171:18;171:18;171:19; 171:19;172:21;173:8; 173:10;173:13;175:7; 175:17;186:9;186:18; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 companies - data HARTOLDMONOO11034 Deposition of DAVID WOOD NOVEMBER 9, 1995 186:22;189:20;190:19; dated 115:23 ;124:16;124:18; 133:4;133:14;161:15; 175:6;182:24; dates 35:13;49:4;49:7; 85:25;86:13;20:3; 35:5;70:12;70:13; 71:16;71:17;72:8; 73:2;74:9;74:13; 74:16;83:9;107:23; 167:23;184:5;192:6; David 5:1;5:14;5:17;68:19; 114:11;133:6;154:3; 155:17;162:16; 175:5; 192:1;192:10; david 113:11; day-to-day 24:21 ;40:11;40:25; days 133:17;33:1;34:1; 34:1;83:17;183:21; 183:21;192:3;192:13; 193:15;194:13; Ddt ............... 78:22;79:3 ;79:7; 84:21;85:3;90:18; 94:21;94:24;133:25; 134:3;134:13;139:20; 139:22;139:23;139:25; 181:2;181:4;181:5; 181:8;181:16; dealing 109:1;156:6; debate 170:7; December 62:1;102:21;103:3; 115:23 ;115:25;122:15; 122:18;124:16;131:23; decided 24:7;48:5;59:4;64:4; 68:15;68:17;167:13; 68:13;104:11;170:3; deciding 170:22; decisions 182:11;168:25;170:1; 171:15; deck 96:9;96:10;96:12; 96:13;96:25; deep 158:9;178:15; deficiencies 160:11; defined 16:21;17:24;67:2; defining 121:10; definition 60:18;60:23;61:10; degrees 15:24;8:9;8:10;8:11; 9:10;16:4;16:9;155:13; delay 190:8; delighted 45:10; delineate 33:25; delivered 15:1;152:21; a CD oo (A CD delivering 30:9;188:21; demanded 39:11 ;41:1; Denmark 27:21; Dennis 22:13; departments 42:20;104:10;104:24; 106:1;31:15;32:20; 41:11;65:22;105:12; 105:23 ;105:24;106:2; 106:2;106:4;112:10; 118:22;131:11; 147:23; depended 16:1;148:4; Depending 36:8;37:24; depending 16:12;52:8;89:24; 104:24;129:6; depends ' 157:10;41:19;107:17; 174:13; deponent 194:6; 5:4; depositions 6:6;87:6;193:7;5:25; 6:18;6:19;8:1;192:3; derivatives 12:8; described 123:21;141:5;141:6; 141:8;142:22;191:2; describes 92:19;92:22;93:6; 141:18;142:4;47:20; 93:4;142:3; description 12:18;123:20; 152:1; designated 17:13;18:10;61:3; 75:6;169:16; designates . 161:21;130:5; : .... designation 8:12;9:8;16:20; designed 179:16;159:11; 179:19; desire 57:19;68:17; desk 64:1; destroyed 110:20; destroying 101:1; destroys 110:8; detailed 91:21; details 127:18;153:6;6:16; 159:8; detected 92:1;147:5; detection 179:12;179:20;187:11; determination 169:24; determined 31:15;32:20;89:18; 93:16; determines 178:15;58:23;89:23; 90:22;92:10;148:5; determining 118:14;150:23; devastating 150:3;150:7; developed 26:17;57:17;59:8; 109:18;110:7;110:19; 187:9; developing 11:8;11:15;69:17; development 18:8;48:6;54:4;62:23; 65:10;69:1;69:4; 174:14; dialogue 56:22;56:24;64:15; diatomaceous 101:9;101:11 ;101:14; 101:18;101:20;101:24; 102:7; Dick 114:17; dictate 152:4; died ...... ~.. 184:23; Dielectric 14:21 ;179:16; dielectrics 36:10;42:23;43:7; 45:3;50:11;52:6; 54:16;56:2;56:8; 56:11;56:12;57:6; 57:8;57:11;58:1; 58:5;58:10;59:23; 60:10;60:21;61:5; 61:8;61:12;61:14; 61:14;61:16;61:19; 70:5;82:16;101:22; 136:10;183:19;14:19; 14:20;14:25;15:2; 15:8;18:12;18:16; 18:24;22:15;24:23; 27:8;28:19;33:21; 34:13^5:17^6:14; 36:17;36:19;37:12; 37:17;37:25;40:5; 42:17;42:18;43:4; 43:19;43:22;44:18; 45:9;45:21;46:8; 46:21;47:14;49:14; 50:3 ;51:14;51:19; 52:5;52:15;52:24; 56:5^7:12^7:14; 58:25;60:13;70:11; 70:17;70:25;102:6; 106:12;144:23;174:9; 177:25;179:4;179:14; 180:2;181:22;182:6; 182:8; differences 16:7;15:7;15:25; differently 78:10;129:16;141:2; 165:5;15:23;15:25; 16:11;17:24;18:17; 18:18;18:22;27:25; 41:14;41:14;41:15; 59:22;60:2;60:2; 81:2;120:18;123:3; 129:8;131:11;147:3; 157:7;186:16; difficulty TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 31:7;34:3;87:5; dig 102:3; Directing 84:6;88:25;145:24; directing 104:8;163:25; directly 34:20;149:1; Director 68:5; director 66:10;67:16;103:15; 112:9;22:22;23:10; 26:15 ;27:4;27:22; 77:2;77:3;77:5;86:1; 100:22;116:3; 138:4; 141:23;144:9;172:6; disagreed 124:2;123:20;124:1; 155:18; discontinued 27:2; . discounting 118:9; discovered 92:15; discovery 92:9; discrepancies 21:11; discussed 79:10;113:14;134:24; 135:10;137:11;139:10; 183:9; discusses 135:8; discussing 126:22; discussions 32:8;56:9;75:8;107:16; 121:2;182:11 ;20:6; 44:4;52:10;127:15; 161:1;55:16;55:20; 113:6;114:13;139:8; 170:9; disengage 57:19; dismantling 58:16; disposal 58:16;101:6;102:8; 108:18;108:24;109:19; 109:22;109:25;110:7; 111:9; disposed 110:25; disposing 101:8; distinction 13:4; distinguished 15:7; distorted 99:21; distracted 178:7; distribution 19:14; divided 63:18; division 62:5;62:7;67:13; 67:21 ;67:22;67:23; 67:23 ;68:1;68:4; Doctor 127:2;127:3; documentation 40:14; documents 40:15;148:14;176:8; 20:14;20:16;77:6; 102:14;102:16;102:18; 115:14;115:18;115:20; 122:3;i24:10;124:14; 124:16;124:19;126:11; 126:12;130:21;132:17; 132:21 ;132:24;133:1; 133:7;133:9;133:11; 136:17;136:20;136:22; 137:12;137:13;137:18; 137:21 ;138:4;141:14; 152:10;152:17;152:19; 153:10;154:14;154:25; 155:19;156:14;157:5; 158:14;158:18;158:20; 161:3;161:6;161:9; 161:12;161:24;162:3; 162:7;162:10;162:12; 174:20;174:23;175:2; 182:16;182:19;182:22; 182:24;183:2; dollars 66:2;150:9;-------------- --Donald 23:18;25:3; done 48:6;93:15;99:19; 105:1;112:19;119:14; 127:22;140:1;157:13; 160:4;177:5;187:6; 187:19;187:20;187:23; 189:1;189:23; door 173:3; double 130:15;140:2;160:11; doubt 77:9;77:19;77:21; 84:13; 140:22; Doug 133:3; Down 161:18; down 35:13 ;52:11;54:6; 54:7;64:25;66:9; 66:17;94:23;95:5; 95:8;110:22;158:1; 184:23;189:24; drawn 143:21;169:13;180:16; 78:24;99:17; drew 143:13; drilled 54:7; drilling 54:3^4:6^4:11; 54:13;54:14;55:7; 55:9; Drive 5:21; dropped 60:16; drums 110:5;109:9; dry 59:6; duPont 131:17; Duff data - Duff Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11035 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 5:8;5:9;5:9;5:15; 10:8;20:9;20:13; 30:21 ;30:25;47:10; 47:12;56:1;56:4; 70:1 ;70:3 ;72:4;74:9; 77:5;86:24;87:7; 87:16;91:11;91:19; 95:17;95:25;97:10; 97:18;97:22;102:13; 115:14;116:17;122:3; 124:10;132:15; 132:17; 132:21 ;136:9;136:17; 141:15;141:23 ;147:1; 149:12;150:8;151:11; 152:10;156:20;157:1; 161:2;161:6;162:3; 162:7;167:11;174:20; 178:8;182:16;188:13; 191:16; duly 5:2;193:5;'l93:18; Dupont 65:1; During 22:21 ;50:12; during 7:21 ;11:2;21:20; 22:2;22:19;26:1; 37:22;39:12;48:22; 53:14;116:6;121:13; duty-free 46:1; -E- e-t-h-y-l-e-n 63:7; each 115:10;129:16; eagles 80:13; earlier 33:22;62:6;68:8; 77:25;86:19;93:10; 98:23;102:23;126:10; 137:2;137:10;140:21; 143:17;143:23;152:23; 153:24; earlyish 127:5;18:13;22:5; 47:15;68:8;190:16; ears 96:14; Earth 101:16;101:17;101:19; 101:21; OArfhc 101:21;101:10;101:14; 101:24;102:7;109:5; 109:7;109:24;1U:1; easier 27:15;27:18; eastern 27:22;45:2; eating 97:4; echos 186:4; ecological 180:12; Economic 46:5; economical 101:20; economics 60:5;27:20; economy 46:14; ecosystems 160:6;180:14; 180:14; 180:15; edge 157:13; educated 41:25;132:9; educational 8:4;121:19; 46-5;46:ll; effectively 183:25;185:16;29:15; 143:4; effects 188:4;144:3;186:2; 186:9;186:14;186:18; 186:22; efficient 29:15; efforts 128:13;35:11;52:4; 52:11; Efta 45:25;46:2;46:11; 46:16; eight 33:1;130:10; either 21:15;126:18;127:5; 165:18;194:9; Electric 19:13;19:13;53:3; 53:5;99:10; electrical 14:23;19:11;19:16; 43:9;44:10;57:20; 58:13;58:13;58:17; 99:25;121:16;178:18; element 69:18;143:10; elevated 32:5;32:7;32:13; elicit 175:16; eliminate 140:20; ' else's ' 90:16; Elsewhere 76:22; elsewhere 120:13;15:20;54:17; 68:14;68:18 ;82:23; 83:5;87:21;107:8; 119:8;120:24;128:8; 132:6;139:5;150:19; Elt 55:13; Ema 63:9; emerged 46:11; emergency 185:7;117:9; emerging 45:11;46:5; Emmet U2:3;112:5;114:8; 115:22;137:6;162:14; 170:18;182:25;183:5; emphasis 29:16;56:12; emphasize 75:7;93:1; 140:22; 143:9; employees 10:6;10:9;26:23; 126:3;126:13;163:4; emporor's 177:18; enable 31:21; encapsulating 109:8; encompassed 51:18;167:15; end 28:10;70:6;83:24; 85:23;119:5;160:4; 184:15;184:19; engaged 34:14;98:19;99:2; 185:6; Engineering 121:15;161:15;161:20; 161:22; engines 14:10; England 8:9;19:1;19:5;24:19; 24:21 ;25:21;25:23; 37:13;37:17;46:3; 109:10;148:2; English 8:11;19:13;37:14; 78:7;98:21;106:7; 132:8;132:9; enhancing 14:22;69:2; enjoy 27:17;45:7; enough 99:14;123:16; enrichment 159:20; ensure 29:21 ;32:11; entered 113:23; entering 24:8; entirely 21:1;109:18;109:24; 110:6;110:12;110:21; entities 157:7; entity 28:5;47:25; entrant 10:21;10:24;11:3; 12:1;13:10;21:8; entry 13:5;46:1; environmental 69:24; 181:23 ;76:16; 81:9;84:21;85:2; 85:4;91:25;92:16; 113:23;119:19;140:18; 156:17;156:23;178:1; 178:22;179:6;179:9; 179:11;180:3;180:8; 180:24;181:3;181:6; 181:13;181:15;181:17; 181:18;182:3;185:14; 187:1 l;187rl8; Epa 58:14; Equally 59:21; equally Deposition of DAVID WOOD NOVEMBER 9, 1995 78:22;79:4;79:8; 108:8;77:11;77:23; 78:5; equipment 14:23 ;19:17;44:10; 58:13;58:14;58:17; 127:24;142:10;142:11; 142:23;143:2;143:4; 143:20;145:20;145:20; 145:21 ;147:3; 150:16; 150:17;150:19;150:22; 151:2;151:9;151:17; 170:25;178:19;179:18; 179:20;179:22;179:22; 179:25; equivalent 38:12; erroneously 117:3; errors 169:10;102:23; escaped 91:25;180:7; escaping 178:1;179:5; escorting 23:2; especially 164:7;172:20; Essentially 11:4; essentially 15:10;19:1;43:18; 66:19;71:8;82:15; 109:1;109:6;114:9; 118:3;173:21;63:16; 159:10; established 71:9;90:21;153:18; establishing 26:15;26:21;171:20; 167:13; ester-based 54:5;55:14;50:21; Ethylene 63:7; ethylene 63:5;64:23;65:6; 12:13;14:1;14:4; 14:13; Eugene 163:2;163:3; Europe 10:14;11:7;11:8; 12:14;12:17;12:24; 15:2;18:2;18:7;19:15; 23:7 ;25:22;26:17; 26:22;27:4;27:16; 27:20;27:22;34:14; 35:18;36:20;36:21; 38:13;39:16;39:19; 39:21 ;39:22;45:2; 45:15;47:14;48:4; 49:15;64:5;69:12; 85:25;88:5;88:18; 88:23;89:23;104:3; 104:5;105:20;106:2; 106:5;106:12;115:7; 118:11;146:8;146:10; 146:12;148:3;170:11; 173:24;174:16;182:6; 185:3; Europe's 72:15; European 9:17;9:22;9:25;10:1; 19:17;22:7;22:17; 23:3 ;23:5 ;23:9 ;24:8; 24:10;24:15;27:10; 28:7;29:7;35:23; 36:23 ;37:16;38:7; 41:9;41:14;44:22; 45:25;45:25;46:3; 46:5;46:10;46:18; 49:1;69:14;76:19; . 81:8;84:21;91:23; 105:23;113:19; European-wide 120:25;183:18; Europeans 42:2; evaluated 58:8; evaluation 60:6; Evans 135:25;136:1;136:3; Even 30:5; events 83:1;108:15;89:18; 9:10;22:22;59:9; 61:6;81:22;82:18; 92:4;99:9;158:18; 159:11; every 33:25;129:16; evidence 92:6;134:7;158:5; 159:15;160:8;186:14; 187:16; evident 83:2; evolve 12:17; evolving 28:15;159:10;183:17; ex-colleague 68:21; exactly 20:2;34:21;92:8; 103:18;104:15;113:11; 175:10;178:20;71:16; 71:17; Examination 5:7; examined 193:18; examining 180:25; example 32:3;32:16;41:16; 50:2;50:8;69:11; exceeded 32:25; excellent 143:19;159:24; exchange 23:5; Excuse 111:15; excuse 45:5;46:15;48:18; 55:7;89:3;160:10; executed 178:21; executives 103:13; exemplify 32:15;142:7; Exhibit 20:7;20:10;35:7; Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 Duff-Exhibit HARTOLDMONOO11036 Deposition of DAVID WOOD NOVEMBER 9, 1995 49:3;72:1;102:10; 102:11;102:14;115:11; 115:12;115:15;121:25; 122:1 ;122:4;124:7; 124:8; 124:11;130:21; 132:18;132:19;132:22; 136:14; 136:15; 136:18; 136:21; 152:7;152:8; 152:11;153:23;156:15; 161:3;161:4;161:7; 162:4;162:5;162:8; 163:19;171:22; 171:25; 172:12; 174:10;174:11; 174:17;174:18; 174:21; 175:9;175:13;182:13; 182:14;182:17;183:24; exhibit 20:5;153:17;161:19; 174:5; 177:4; existed 99:12; exists 100:25;187:12; exited 58:7;60:10; expanding 23:8;28:5;69:19; 25:25;26:4;67:3; expansion 27:3 ;45:21; expatriot 162:19; expected 41:1;152:2;95:3; expedite 138:5; expensive 173:4; experiences 69:16;183:20;9:4; 49:15;134:14; experimental 186:9; 186:18;186:21; expertise 41:21 ;82:21; 128:5; 160:15;170:21; experts 168:21;169:3;169:3; 170:20; expires 192:14;194:15; exploitation 143:19; explored 168:14; export 67:2; exposed 32:6;94:11 ;96:25; 135:15; exposure ~ 186:16; expressed 141:2; expressing 127:20;185:24; exstensive 163:14; extended 14:19;143:21; 186:3; 7:7;50:9; extension 33:23; extensively 94:13;163:10;163:19; 168:25;173:4; extent 56:6;56:16;73:19; 107:15;127:24;147:14; external 41:11; extracted 134:12; extracting 157:11; eye 116:13;116:19; ."rr fabrics 63:11; face-to-face 112:25; facets 33:25;34:12; facilities 46:23 ;53:10; facility 47:1;47:2;47:7; facts 84:13;116:11; factually 185:2;81:4;104:21; 167:13;168:5;168:9; 168:10;168:13;168:16; 168:21 ;21:12;27:18; 55:21 ;76:5;77:22; 80:3;81:10;95:5; 99:6;103:8;105:4; 112:13;113:8;118:9; 135:4;137:9;169:4; 169:10;169:16;176:10; 177:13; failed 59:15;59:17;179:21; 179:24; failure 179:19; Fairly 83:9; fairly 83:10;95:4;95:9; 113:15;122:22;133:5; 142:11 ;142:20;155:12; 155:12;173:1;185:2; 188:24;34:11;38:14; 106:23;151:1; faithful 123:8;153:12; falls 187:12;60:23 ;68:9; 96:14;187:13; familiarizing 52:23;61:6;73:17; 73:21;93:5;98:1; 100:19;103:22;107:21; 116:17;124:14;130:19; 131:1;135:14;142:23; 147:8; 147:13 ;158:18; famililes 157:15; family 156:6;156:9;157:16; far 14:6;21:13;44:1; 88:21;149:7; fashion 11:18;75:15; fears 190:2;190:3;190:3; 69:18; features TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 34:9;30:11; February 163:7;168:7;169:6; 169:8; 169:20;169:23; 170:3 ;170:17; 171:4; 172:18;175:6;176:14; 176:17;176:18; 176:20; 182:1;182:24; 183:4; 183:6;184:11;184:15; 184:18;184:19;185:20; feedback 41:1; feeding 190:10;190:12; feel 7:13;7:21;7:22;34:24; 35:1;53:3;155:10; 172:19,178:15; felt 33:1;39:19;42:6; 127:21 ;128:12;135:12; 139:13;147:24;151:19; 155:4;155:24;156:1; 167:17;178:14; fence 96:25;96:25; few 38:21 ;86:20;133:17; ____ 164:16;164:21;165:6; 166:10;166:17;176:8; fibers 12:7; fiction 169:4;169:17; figure 43:13; Filer 162:16;162:18;162:19; filled 43:15;170:21; film 63:17; finally 63:18; Find 105:13; findings 79:10;80:7;135:1; 135:13 ;155:1 ;167:1; 168:6;170:4;171:4; 184:23;113:18;113:22; 139:17;139:22;155:21; 155:25; 156:1;157:14; 180:25;34:2;47:21; 64:6;81:24;89:19; 93:14;99:2;99:18; 104:24;113:12;114:2; 118:5;139:12;140:5; 152:13;158:12; fine 12:9;47:19;47:20; 48:9;48:11;48:14; 49:9;87:3;96:14; 178:7;188:17;191:12; fingers 187:1; finished 71:8;7:6;111:15; fire-resistant 59:16; fireproof 100:3 ;6:13;60:18; 60:19;107:20; firstly 78:2;5:2;10:22;20:1; 21:4;22:11;25:11; 25:15;25:23;37:9; 46:6;71:20;75:10; 79:1;79:2;82:19; 83:6;86:8;87:10; 87:12;87:25;88:16; 90:9;91:8;107:24; 110:3;127:1;127:4; 130:22;135:17;144:10; 151:4;158:20;183:2; 187:16;189:10;189:11; 193:18;80:14; fish 80:13;159:18;163:21; five 6:4;80:15;96:15; 97:23;130:8; flash 59:13; fledged 20:1; floating 54:8; Fluids 49:14; fluids 11:24;12:12;12:12; 12:13;12:21; 12:23; 14:19;14:20;14:21;---15:8;15:9;16:24; 18:12; 18:24;22:15; 23:22;23:25;24:23; 27:8;28:20;29:3; 30:13;33:21;35:18; 36:14;36:17;36:19; 37:12;37:17;37:25; 40:5;43:4;43:19; 43:23;44:18;45:9; 46:8;46:21;47:14; 49:11;49:13;49:14; 49:16;49:22;49:25; 50:3;50:4;50:11; 50:13;50:14;50:14; 50:21;50:25;51:18; 51:19;51:20;51:21; 51:23;52:1 ^52:8; 52:10;52:14;54:5; 54:16;54:22;55:1; 55:1;55:4;55:6;55:9; 55:18;55:21;55:24; 56:5;56:13;56:13; 56:19 ;56:20;57:2; 57:13;57:14;57:16; 57:18;58:25;58:25; 59:11;60:4;60:13; 60:22;62:7;62:11; 70:11 ;70:17;70:25; 102:8;103:13;103:16; 103:22;106:12;114:18; 114:23;125:21;144:24; 174:9;179:14;179:16; 181:25;182:6;15:14; 42:17;42:18;49:17; 50:1;55:12;55:14; 56:18;58:9;59:8; 59:21;60:18;102:7; 179:21 ;179:24; fluorescent 19:10; foci 68:25; focused 11:14;13:15;29:13; 29:18;33:23;52:4; follow-up 120:23; followed 142:9; following 68:11;73:1;120:20; 179:7; follows 5:5;189:9;113:25; 142:13; ............. food 6:11;47:19;48:8; 48:11,48:14; forcefully 188:24;188:25;28:14; Ford 125:8; 125:10; 125:13; 131:18; forecasts 29:10;33:16; foregoing 192:2; 193:21;193:24; forest 96:4;187:12; forgotten 61:24; formal 10:22;22:25;42:8; formed 19:15;68:19;116:6; forms ----- ---------- 15:7;130:17; formulated 58:15; formulations 50:17;10:5;30:17; 31:4;31:17;55:23; 68:22;74:8;84:22; 86:5;91:6;95:13; 95:19;97:7;97:15; 101:17;108:14;109:22; 110:1;111:3;116:16; 120:5;122:19;123:15; 123:23;125:6;136:5; 141:20;146:22;149:9; 150:4;15l:10;156:18; 156:25;161:17;162:1; 165:2;167:2;168:18; 169:7;169:21;170:5; 171:6;177:2;178:2; 180:9;182:4;183:15; 186:12;188:7;188:10; 189:16;191:5; forth 193:25; forum 143:21; forwarded 184:17;18:3;84:25; 97:21 ;98:23 ;99:23; 148:17;184:12; foundations 90:21 ;59:22;75:18; 80:12;80:13;80:13; 80:15;85:4;87:5; 90:12;91:23;92:6; 92:7;92:8;104:15; 123:2;139:13;156:16; 156:23;159:17;188:19; fourth 51:23;118:4;165:3; 49:21 ;65:25;130:7; 137:13;137:17;138:10; 160:9; framework 179:12; framing 158:7; France Exhibit - France Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONOO11037 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 27:20;44:23;46:4; 46:17; Francisco 6:12; Free 45:25;46:4; free 7:13;7:22;34:24; French 39:17;45:13;92:13; frequency 38:4;181:19; frequently 37:21 ;39:13;123:16; 181:11; froing 70:22; front 160:4; Fullers 101:16;101:17;101:19; 101:21; fuller 147:17; fully 20:1;51:13;J:16; 90:20;126:18;194:3; functional 11:24;23:22;23:25; 51:18;55:18;55:21; 55:24;57:1;62:6; 103:16;125:21; functions 11:7;171:13;18:18; 34:1; fundamental 157:12;187:4; funded 177:11; funding 177:15; furnished 126:4;126:13; furnishing 189:20; furniture 96:6; furthering 128:12;109:11 ;119:22; 143:7;177:7;194:8; future 58:18;176:21; -G- gained 20:1;21:4;46:7;92:5; 142:24;145:18;151:15; 169:1 ;31:21;39:20; 140:15; gaps 170:21; Gas 5:10;53:14;53:17; 53:22; gases 60:20;61:1;146:20; 146:20;147:8;148:15; 149:18;150:12;151:5; gathering 53:20;173:15;173:24; 174:3; gave 6:5; 12:18 ;37:2;64:15; 148:13;153:3;175:14; 175:21; Gene 185:24;186:4; General 53:3 ;53:4;99:10; 131:18; generalizations 160:7;160:16; generally 11:10;11:18;12:18; 18:9;36:25;40:6; 43:1 ;72:16;154:14; 159:13; generated 12:15;17:16;83:5; generating 175:7; generators 99:18; generic 12:9; gentleman 78:7;163:7; gentlemen 87:4;125:12; genuinely 98:25;121:18; geology 8:25; George 102:22;102:24;103:19; 104:5;105:17;115:24; German 44:20;44:20;45:13; 92:13; Germans 39:19; Germany 19:19;27:20;46:4; 46:18; gesture 7:1; given 11:20; 11:23 ;29:23; 49:5;119:16;119:20; 120:21 ;148:11;170:23; 180:16;184:5;192:5; 194:5; giving 11:10;28:9;28:13; 181:22;188i25; glad 84:5; glass 68:7; global 69:8; goes 21:13 ;34:1;160:14; Good 27:7;111:18;166:22; 189:7; good 33:5;33:5;40:22; 42:13;42:15;111:24; 113:24;122:22;127:21; 143:9;143:10;145:20; 157:12;160:20;185:11; 185:12;185:15; Gore 193:4;193:12; governing 8:2; government 185:4;185:5; gradually 26:14;26:17; graduated 9:14;155:12;10:17; graduating 8:11; Graham 135:20;135:21; Great 19:6;19:13;46:9; 46:11;46:20; greater 29:9;59:4;111:23; 66:3 ;68:16; green 95:4; groundrules 6:17;6:21;8:1; groups 23:3;35:9;45:25; 50:5;65:23;66:16; 66:17;66:18;66:20; 67:13;74:20;75:21; 88:1;103:13;103:16; 103:22;111:13;112:8; 114:18;136:11;137:6; 148:7; growing 9:24;28:5;41:2;69:17; 158:5; growth 10:1;66:25;69:12; 69:12;69:13; guarantee 96:11;96:22; guess 19:24;107:20;117:20; 155:14;185:25;189:10; guidance 82:8;113:15; guided 107:15; guidelines 33:5; Gulf 64:25;65:3;65:8; Gunnar 124:22;125:2;126:17; 126:18; -H- habits 121:22;60:15;121:12; Hadn't 159:17; hadn't 29:16;104:4;126:11; hair 80:15; half 185:14; handing 20:9;102:13; handled 28:2;40:4;41:5;42:17; 47:4;66:19;67:13; 99:22;108:19;108:25; 109:3;183:25;11:22; 28:3;40:11;41:3; 48:7; handling 30:2;30:8;30:12; 37:12;37:16;42:21; 89:7; hands-on 69:16; handwriting 122:11; 153:25; 154:4; 154:8;161:11;182:21; Deposition of DAVID WOOD NOVEMBER 9, 1995 handwritten 130:20; 131:13;131:13; 194:12; happened 20:3 ;26:16;35:19; 56:23;57:1;108:13; 148:25;157:24;166:14; happening 81:21;107:18;167:14; 167:21 ;41:19;164:2; 189:1; hardly 100:25;159:5;159:13; Hardy 105:19;112:12;112:14; 112:23;113:1;113:3; 113:6;113:14;118:18; 118:19;119:15;119:16; - 121:2;133:3;133:19; 134:1;134:6;134:16; 134:22;134:23;135:4; 135:6;135:8;135:16; 137:5;137:7;162:17; harm 31:23 ;31:25`32:15; 33:12; haven't 13:3;94:25;124:21; headed 137:22;154:21; heading 48:25; headquartered 9:17;21:23;21:25; 22:7;24:11; headquarters 24:8;40:3;82:17; 82:21;136:10;137:6; health 144:4;186:3; heard 111:17;112;1;114:12; 135:17;167:23;188:15; hears 187:13 ;25:12;71:22; heating 62:12;51:21;52:10; 56:3;61:23;62:3; 62:18;63:2;63:23; 98:12;100:3; heavily 95:3;95:14;182:7; held 20:24;49:10;66:6; 67:19;67:23;68:16; 70:6;163:20; hell 158:12; helped 127:23; helpful 34:10;128:12; helps 34:24;84:2;33:10; 118:10;138:4;139:24; 144:8; herbicides 95:22;95:18;97:6; 97:12;97:25;116:12; 116:18; hereby 193:7; hereinabove 192:6; hereto 192:4; hesitate 67:18; ` hexachlorobiphenyl 160:14; hexafluoride 61:2; hiding 168:2; highly 18:15;51:25;84:22; 101:15;101:17;101:23; 121:23;152:6;8:6; 8:7;14:9;51:25;54:13; 59:12;59:13;100:6; himself 127:10; hindsight 90:25;91:2;92:4; 141:1; historically 45:23;69:9;55:17; histories 34:8; history 154:18; hitherto 189:23; Holden 100:20; holding 17:15;40:18;47:13; 49:8;57:4;57:25; 61:12;61:22;61:25; 63:24;66:7;67:6; 67:11 ;67:17; home 96:9;96:14;96:24; honors 8:9;8:16;9:10; hooray 185:17; Hope 22:13; hoped 139:24;177:9; hour 33:1; house 96:12; humans" 172:22;186:10;186:3; 186:6;186:15; hundred 10:12;10:13; 179:23; hunt 185:6; hydraulic 49:1731:23 ;52:14; 55:1;55:1;56:18; 100:3; hydrocarbons 55:22; hydrogen 17:15; hygiene 32:23;33:6; 108:5; 171:18;186:24; hypotheses 160:1;180:16; hypothesis 140:13;168:11; hypothesized 179:13; hypothetical 92:3; -I- Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 France - hypothetical HARTOLDMONOO11038 Deposition of DAVID WOOD NOVEMBER 9, 1995 i.e. 140:24; ideas 23:5; identical 134:9;134:15; identification) . 20:8;102:12;115:13; 122:2;124:9; 132:20; 136:16;152:9;161:5; 162:6;174:19;182:15; 58:16;134:4;136:24; identified 76:15;141:9;141:19; 142:5;187:17; identify 20:16;72:12;102:18; 115:20;133:1 ;137:16; 139:24;142:13 ;147:23; 162:12;168:20;175:2; ignored 118:3; immediately 26:16;73:5;57:21; implementation 69:1;69:3; implicated 157:21;157:23; implications 113:10;113:13;151:14; 156:16; important 24:22;29:25;30:4; 30:10;30:14;31:13; 31:19;32:17;33:2; 33:10^54:3 ;81:10; 81:12;81:19;87:22; 117:12; importing 46:8;40:14; impregnate 32:4; impressive 123:1;111:7; inaccuracies 169:11 ;169:12; inaccurate 167:17; inadvertently 106:5; inappropriate 112:17; included 16:15;56:2;63:14; 87:15;167:15;9:2; 14:19;20:20;32:8; 48:15;118:20; 118:21; 163:15; including 133:6;164:17; inconclusively 169:16; incorporated 68:21; incorrect 77:24; Increased 59:6;167:18;185:8; incurring 32:15 ;31:23;31:25; indeed 78:1 ;81:13 ;85:5; 90:1;90:12;91:22; 105:4;109:10;113:21; 168:3;170:8;175:18; 180:19; independent 26:18;26:19;126:12; indian 19:3; indicated 74:1 ;75:17;93:19; 168:23; indirect 62:12; individuals 22:9;22:16;41:25; 83:23;131:1;163:15; 25:16;25:23;36:4; 36:5;165:17;166:15; 166:18;170:15; 171:9; Industrial 19:4; industrial 32:22;33:6;53:20; 62:11 ;93:12;93:13; 93:25;105:8;107:11; 108:5;171:18;180:22; 181:7;181:19;186:24; industry 6:12;9:21;23:6;54:6; 55:7;55:9;57:20; 58:1;58:4;58:9;59:4; 59:18 ;59:25;60:17; .... 61:6;61:14;61:15; 61:19;64:7;64:10; 65:11 ;66:5 ;76:19; 81:8;89:6;93:21; 94:3;94:12;105:9; 121:16;150:25;187:3; 187:25; ineffective 92:1; inferior 59:10;60:7; inflammable 60:20; information 23:4;29:22;30:15; 31:14^31:20 ;32:18; 52:14;70:19;82:10; 93:8;104:20;107:14; 120:12;166;24;169:1; 169:5;i69:9;170:23; 173:6;173:16;173:23'; 173:25;174:3;174:15; 183:23;184:3;184:6; 184:10;184:15;186:2; 186:5; informed 51:13;108:24;114:12; ingots 63:20; ingredients 15:4; inhalation 32:19; Initially 25:20; initially 26:6;37:13; initials 135:24;82:5 ;82:13; inorganic 8:21;9:7;9:8; insecticides 134:3; inside 176:6;179:21; instead 17:22; Institute TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 126:19;152:22;177:21; Institution 73:14; institutions 32:23; instrumentation 142:16; insulants 14:21; insulated 43:14;59:8; insulation 59:11;99:25; integrity 122:21; intellectual 167:12; intelligent 41:25;149:2;' intended 117:16;121:3;179:15; intentionally 181:3;181:5;181:16; interchangeably 61:8; interested 108:18;121:18;194:10; interesting ---------------46:13;59:2; interests 66:15;60:4;66:21; 99:2;122:25;143:15; interface 40:25;42:23; interfering 139:25; interlayer 68:7; intermminably 126:23; internal 28:13;41:10;75:8; International 68:22;68:24; internationally 56:8;70:21;49:11; 50:10;50:13;51:19; 52:3;52:20;53:24; 55:10;55:16;56:10; 57:3;69:1;69:5;69:16; 69:17;69:20;114:20; 114:22;114:24;114:25; 115:1 ;115:2;137:9; interpretations 169:12;165:5; interrogatories 5:5; interruption 111:17; interviewed 9:21; into 12:14;14:12;17:10; 25:25;26:10;34:1; 40:17;56:22;65:22; 66:17;66:24;67:24; 68:21;69:12;69:12; 69:13;69:14;69:19; 70:10;76:9;91:25; 98:21;107:19;109:4; 109:23 ;111:1;129:15; 139:10;139:18;168:10; 170:11;178:1; 179:5; 179:16;180:3;180:7; 181:3;181:6;181:16; 181:17;182:3;193:23; introduce 12:14; introducing 11:8; invention 156:3; inventories 34:5;40:18; inventory 29:11;40:20; investigated 168:14;173:8; investigation" 173:5; investigations 73:13 ;75:17;126:6; 126:15;140:23; investments 67:4; invited 170:1; involved 12:8;12:9;19:7;21:25; 29:3;42:20;42:22; 49:22;52:9 ;54:11; 56:18;57:1;65:9; 66:22;81:24;85:25; 88:8;88:9;95:15; --------95:20;106:11 ;119:2; 119:4;131:5;131:21; 131:22;146:4;162:20; 163:4;164:19;174:12; 190:1;191:14; involvement 29:17;42:12;49:19; 49:20;49:24;111:23; 181:20;10:1;41:15; involving 6:9;6:11 ;6:13;22:14; 36:10;151:16; irrelevant 79:17;167:17; irrespective 59:20; irresponsibly 168:2; Isomeric 129:20;129:21; isomeric 128:11;128:23; isomers 15:22;16:1;129:17; 129:18;176:7;175:24; issues 76:8;121:13;157:6; 170:16;189:14;76:15; 81:9;81:10;81:13; 147:25;148:4;148:6; 151:14;170:7;174:13; 175:18;176:6;176:9; 176:10;185:7; Italian 44:24;92:13;111:13; Italy 27:21;46:17; items 20:22;175:15;159:4; 160:9; itself 143:14;185:6; _JT_ January 58:2;62:1;131:24; 133:4;133:10;133:12; 133:15;133:16;137:1; 137:25;145:19;153:8; 161:16;161:19; Jensen 91:22;92:2; 126:21; 127:11;127:22;128:2; 133:22;135:13;138:15; 138:18;139:6;139:8; 140:20; 141:7; 141:19 142:12;142:15;143:6 143:16;143:22;144:1 148:11 ;148:14;148:17; 152:21 ;152:25;153:2; 153:11;154:25;155:20; 155:20;155:24;156:1 156:5;156:14;156:21 157:6; 157:13 ;158:14 158:25;160:23;167:1 175:16;175:23;176:1 176:3 ;176:14; 176:17 177:5;179:13;180:10 Jensen's 128:6;134:8; 134:25; 134:25;135:2;135:11; 138:14;150:1 ;150:5; 150:8;150:10;151:13; 151:15;153:5;155:1; 168:5;168:17;169:10 169:11;169:13;169:19; 170:4;171:4;171:11; 184:22; Jensen-widmark 121:6; Jim 162:19; Jim's 162:21; jobs 152:5;13:22;34:9; 67:24;157:14; Joe 131:2;131:3;131:4; 131:5; John 22:15;23:14;23:17; 23:18;25:3;25:6; 34:17;136:1;136:3; 136:7; joined 9:16;13:12;67:12; 188:18;188:18; joint 35:11;65:1;118:17; 127:10;139:2;10:2; Journal 121:20; journals 121:12;121:16;145:10; 145:16;145:18; judgment" 116:13;116:25; 117:4; June 21:17,194:15; jury 155:9,158:10; justly 85:1; --JK\.-" keeping 123:2;183:21;111:5; 115:10;171:24;172:14; Kelly 112:3;114:8;ll5:22; 116:5;116:21 ;117:22; 137:6;148:5;154:9; 154:13;162:15;163:9; i.e. - Kelly Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11039 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 163:18;170:18;171:3; 171:22;172:12;173:14; 175:8;175:22;182:25; 183:3;183:10;183:14; 183:22;184:2; 184:20; 185:19;186:17;187:14; Kelly's 112:5; Kentucky 193:9; kept 58:22;114:11 ;153:19; Kevin 5:9; Kevin's 111:17; kingdom 36:23; knew 41:18;53:4;60:14; 73:23;87:13;88:2; 88:4;88:8;88:9;88:17; 88:21;95:22; 131:2; 142:21 ;155:20;174:13; 176:1;187:9; knocked 19:25; knowing 31:8;41:12; knowledge 50:5;74:11;74:14; 74:18;86:2;147:17; 147:20;163:5; known 62:9;101:16; -L- L-i-l-j-e-h-o-l-m-e-n 43:8; laboratory 9:2;9:4;9:11;142:19; laminated 68:7; languages 41:14;78:6;78:8; 81:19;146:2;160:11; largely 43:13; larger 38:11 ;62:14;64:12; 105:7; largest 19:5;19:6;47:24; 51:19;51:21;51:22; 51:23;19:8;19:11; 43:10;43:12;44:20; 48:4;54:9;59:25; 105:9;107:15;131:17; 131:19;170:22;171:11; lasted 13:1;25:12;77:6; 77:7;105:3;107:22; 110:15;110:17;116:15; 123:13;138:5;146:2; 149:25;167:16;172:6; 173:2;175:8;176:16; Later 14:15;25:21; later 16:20;20:20;22:13; 22:18;47:4;48:12; 83:18;97:23;114:19; 156:5;159:21;10:21; 10:24;35:2;71:16; 127:5; lawful 5:2; lawyer 107:21 ;8:10;8:12; 8:15; lays 142:12;76:7; 128:4; 164:3; leadership 190:15;190:17; 187:24; 187:24;189:3;189:19; leading 64:16;157:13;172:3; 178:21;179:10; leap 89:16; learned 37:13;71:11;71:20; 83:14;93:17; learning 65:11;64:11;64:14; 66:4;108:19; least 39:10; leave 116:13;116:25; led 140:1;140:13;142:12; 142:13;170:18; left-hand 154:1 ;24:19;67:8; 130:20;130:20;131:12; lept 65:20; Less 45:8; less 10:12;10:14;17:18; 29:13 ;38:19;128:3; 128:6; 184:21 ;185:3; letters 106:7;71:23;72:4; 72:8;72:13;72:14; 72:25;73:2;73:3; 73:7;73:11;73:12; 73:18;73:21;74:10; 74:13;74:17;74:23; 75:3;75:4;75:10; 75:20;76:22;78:20; 79:2;79:6;7^:7;79:13; 80:5;80:19;80:21; 82:11 ;83:7;83:11; 83:12;83:16;84:7; 87:10;87:13;87:24; 88:1;88:15;88:17; 89:1;90:20;92:19; 92:22;93:9;93:17; 98:19;100:23;101:4; 102:20;103:1;103:3; 103:5;104:7;105:17; 105:18;105:21;106:18; 107:4;107:23;109:14; 110:15;110:18;111:19; 112:2;112:14;112:22; 113:4;114:5;115:22; 115:24;116:4;116:14; 117:12;117:22;125:7; 131:7;131:15;134:6; 134:17;134:23;136:23; 137:3;138:2;138:6; 176:13;176:17;176:20; levels 15:11;33:3;121:11; 179:11;180:18;180:25; 9:10;13:5;16:4;16:12; 17:21;17:21;54:13; 82:21 ;86:25;142:24; 156:4;170:13;181:18; leverage 45:15; liable 164:2; liaison 26:25; liberally 181:2;84:21; life-time 60:16; lifetime 186:16;20:18;95:7; 186:7;186:19;186:22; lighting 19:10; liked 45:8; likely 144:6;155:5;169:2; 183:11; Liljeholmens 43:7;43:9;45:10; limited 11:12;40:17;53:8; 59:15;177:15; limits 179:12; lines 7:2;41:2;50:11;96:17; 163:5;166:11 ;14:19; 40:8;42:11;42:25; 43:3;47:3;47:5;47:18; 85:24;96:25;109:10; 118:25;171:14; liquid 14:21;61:1;109:8; listed 9:2;20:22;153:23; 173:14;24:22;27:14; 34:4;130:23;133:6; 137:10;153:12;153:18; 153:20;153:22; 175:15; literature 29:4;29:6;29:8;29:20; 32:8;34:6; little 12:3pl:7;34:3;80:25; 98:3;121:9;145:11; 145:18;160:19;178:4; 182:8;186:24; liver 95:11; living 80:13;111:14;159:5; 159:8;159:14;163:21; Lkb 142:9;142:21;143:3; 143:18;143:25;145:10; 145:16;146:19;148:9; 149:3;149:7; 149:13; 149:16;149:19;150:15; 150:17;151:7;151:12; 151:16;151:23; lkb 137:22; load 181:23; local 69:10;96:19; location 24:14;47:6;58:16; London 9:17;10:4;10:25; 22:8;22:10;22:17; 24:9;24:11;26:11; Deposition of DAVID WOOD NOVEMBER 9, 1995 39:23 ;39:25;70:5; 70:14;70:18;70:22; 71:2;71:6;71:19; 74:7;105:19;112:12; 113:2;133:4;133:14; 135:25;137:6; long-term 163:3;13:2;13:11; 19:22;27:14;36:25; 37:3;47:13;48:13; 61:25;67:6;67:17; 87:2;95:7;133:5; 158:17;163:6; looked 60:7;94:25;159:7; looking 27:5;129:11;129:17; 129:18;131:7;139:20; 140:2; looks 154:2;51:16;113:17; 145:16;177:3; looseness 78:6;114:1; lose 150:9; lost 14:6; Lots 187:10; lots 183:20;24:10;42:2; 45:18;61:5;67:19; 69:16;129:8;158:11; 160:16;189:2; Louis 21:22 ;21:23;22:1; 22:4;22:23;22:25; 23:11;49:12;65:23; 82:17;82:23 ;83:20; 83:25;102:22; 106:3; 112:3;112:8;114:7; 114:8;114:10;114:19; 115:23;124:23;137:4; 137:8;162:15;163:4; 163:10;163:20;165:13; 170:9;171:23;172:13; 193:3;193:13;194:12; Louis" 172:10; lousy 189:18; lower 17:23;181:18;56:15; 121:23; lubricants 54:25; lubricating 100:6; -M- m-a-l-e-i 63:8; M-a-r-s 25:24; magazines 121:24;122:18;123:1; 161:21; mailed 136:25;133:14;184:8; mainland 39:19; mainly 15:7; maintain 92:5;18:2;137:4; 147:22;158:24; major 14:6;19:2;19:16; 25:10;27:19;38:7; 43:6;43:18;44:2; 45:9;45:13;46:22; 50:9;50:10;52:4; 55:12;60:4;61:4; 62:4;62:21 ;62:23; 63:25;64:24;65:4; 65:8;65:23;146:7; 146:11;159:7;178:22; 180:4; makes 49:16;77:16;81:7; 99:1 ;105:1; 159:2; 160:6; making 13:4;19:8;29:6;29:13; 98:17;128:3;160:16; 166:18;178:17;187:14; Maleic 63:7; maleic 63:5; managed 13:22;22:24;29:14; management 28:16;28:17;34:2; 34:2;111:22;113:16; 174:6; managers 40:4;40:8;23:22; 45:4;48:12;48:16; 48:19;48:22;48:24; 49:9;49:11;50:13; 52:21 ;53:24;55:11; 55:16;57:4;57:6; 57:7;57:11;58:1; 58:5;61:11;61:14; 61:14;61:16;61:19; 61:23;62:3;62:18; 63:2;63:22;66:6; 82:16;114:22;118:23; 118:24;151:22;174:7; managing 34:4;34:5; manner 31:22; manufactured 19:14;43:9;46:9; 46:10;46:24;47:4; 47:5;48:3;57:15; 76:12;82:3;85:9; 85:20;86:8;86:8; 86:14;86:16;86:21; 86:22;88:7;89:14; 89:22;90:3 ;90:5; 93:20;93:24;98:4; 98:5;98:9;99:4;99:8; 99:11;125:25;157:18; manufacturers 19:2;19:12;38:8; 44:10;44:17;81:20; 89:22;113:19;156:13; 19:5;43:11;43:12; 44:21 ;46:21;47:7; 67:4;85:7;86:3 ;87:14; 88:3;91:24;98:12; 116:7;129:2;178:18; manufacturing 29:10;32:3;32:9; 33:17;46:23;47:1; 47:2;85:10;85:12; 85:14;85:17;179:7; many Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Kelly - many HARTOLDMONOO11040 Deposition of DAVID WOOD NOVEMBER 9, 1995 6:3;10:8;25:18;26:14; 33:25 ;34:9;38:9; 39:4;39:9;64:15; 64:16;66:1;69:7; 95:23;110:4;116:5; 131:5;166:7;170:8; 179:18;100:19;159:24; margin 130:20;152:14;154:1; marked 20:8;20:10;49:3; 72:1;102:12;102:14; 115:13;115:15;122:2; 122:4;124:9;124:11; 132:20;132:22;136:16; 136:18;136:21;152:9; 152:11;156:15;161:5; 161:7;162:6;162:8; 163:19;171:21;172:12; 174:19;174:21;182:15; 182:17; Market 48:11;57:6;6I:23; marketing 53:24;55:16;57:3; 61:11;63:2;63:22; 64:1;114:22;114:25; -1-14:25;!63:3-;-----------marketplaces 37:17;69:20;15:1; 37:14;37:25;38:6; 38:7;39:16;48:6; 51:17;57:14;60:3; 66:12;69:15;92:12; 111:24; markets 12:16;12:17;25:25; 69:10;23:8;24:9; 30:10;40:23;43:13; 44:19;45:6;45:20; 48:16;48:18;48:19; 48:19;49:11;50:13; 52:3;52:20;55:10; 57:7;57:11;57:12; 61:13;62:2;62:18; 67:2;78:1;183:18; 183:20;20:4;102:10; 115:11 ;121:25;124:7; 132:17;136:14;152:7; 161:2;162:3;174:17; 182:13; Marsh 25:24; mass 141:4;142:22;146:21; 147:13;148:18;149:19; 150:12;151:5;153:5; 155:8;169:15; materials 64:18;64:19;65:24; 66:1 ;66:3 ;66:7;93:6; 98:12;108:18;110:5; 128:11;128:23;128:25; 129:8;134:I4;138:13; 140:11;150:23;151:17; 157:25;159:22;18:6; 47:23 ;64:19;64:20; 75:8;89:7;90:19; 93:13;101:2;101:15; 101:23;109:6;109:8; 110:6;111:2;126:5; 126:14;180:13;187:8; mathematics 8:25; matriculated 8:6;8:7; matters 6:5; mature 128:3; maximize 143:19; May 20:19;21:3;21:13; 21:17;35:14; Maybe 107:2; maybe 117:19;120:18;30:20; 30:21 ;44:21;53:19; 63:6;69:9;91:15; 97:22;101:2;119:22; 138:4;140:21;165:9; 172:20;176:10;180:6; 184:8;187:17; means 125:5;160:12; meant 33:9;104:15;106:4; 106:19;110:8;110:18; 110:21 ;134:19 ;166:18; 9:11 ;10:6;16:18; 17:5;17:17;27:19; 30:18;32:1;35:2; - 35:11 ;36:22;49:13; 51:4;51:7;53:19; 54:24;55:24;56:18; 72:22;75:4;78:9; 81:14;84:2;91:21; 93:22;96:5;96:7; 96:8;96:23;104:14; 105:1; 106:1; 106:17; 106:20;107:2;107:17; 108:12;110:22;116:15; 118:22;120:15;123:12; 123:25;125:11;127:14; 131:12;131:16;135:10; 142:19;142:21;145:1; 145:15;149:21;150:20; 154:21 ;155:9;157:12; 158:10;172:25;181:5; 187:20;191:8; mechanics . 8:24; .... media 41:15;42:5;72:18; 8i:3;92:23;92:24; 101:22;121 !!28:2; 143:13;164:3; medical 31:15;32:20;104:10; 104:19;104:24;105:12; 105:20;105:23;105:24; 106:1 ;106:2;106:4; 112:7;112:9;137:6; 147:22;154:19; Medicine 121:20; meetings 139:4;170:8;170:8; 44:6;53:21;79:11; 79:18;79:23;80:1; 112:25;125:8;132:6; 139:2;139:3;139:5; 139:9;140:20;163:10; 163:14;163:19;168:25; 23:5^39:1 ;39:5;39:9; 39:13 ;39:23;39:25; 40:7;132:13;138:18; members 65:25;46:2;60:21; memorandum 137:14; 138:11; 138:12; 141:4; 141:16; 141:24; 142:2;149:5;153:7; 163:9;163:11 ;163:16; 163:16;163:17;163:18; 163:25;164:13 ;171:21; 172:7;172:11;173:14; memory 144:8;173:18; memos 182:10;133:3;133:19; 134:22;135:6;137:10; 137:25;140:19;142:6; 144:5;144:6;144:10; 145:9;145:15;148:11; 153:16;153:24;162:14; 165:22;168:24;172:18; 173:22;175:4;175:9; 176:11 ;186:5; mental 89:16; mentioned" 73:4;21:12;22:18; 43:23;46:25;61:9; 108:17;129:1;176:2; 192:6;131:24;132:2; mentored 24:24; ...... --... merged 68:20; messages 50:7; metabolism 159:8;159:12;160:1; metabolized 159:5;159:13; metals 65:12; methodology 190:4; methods 187:11;100:25;109:18; 109:25;110:7;110:9; 110:11;110:19;111:9; 40:24;53:19;54:23; 56:17;131:23;131:25; 132:5;138:19;138:21; 138:23;142:15;143:6; 144:1;148:21 ;176:2; 176:4; middle 71:8;122:21;173:9; might 11:11;32:11;37:25; 38:2;38:20;43:24; 47:21;47:22;50:8; 52:9;52:9;52:25; 72:19;76:11;88:6; 129:25;140:18;173:3; 190:6; military 49:22; millions 150:9; mind 45:18;89:18;98:19; 134:21; 151:12; 170:10; 173:11;182:7;193:17; minerology 8:25;153:24;157:4; minor 36:22;49:19;49:20; 59:15;165:9; minutes 97:23;176:8;51:10; 112:21; TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY misleading 123:18;143:21;106:22; Missouri 5:19;5:22;49:12; 69:11;193:1;193:5; 193:14;194:13;194:18; misstate 51:11; mistaken 91:19; mistakes 106:6;169:18;170:14; misunderstanding 76:17;81:4;141:14; 51:15; misunderstood 86:25; mixtures 129:20;129:21;140:10; 156:2;15:22;16:1; 129:5;129:7;129:8; 130:3;130:6;130:13; 130:16;130:18; modestly 28:18;179:19; modified 29:7; modifier ........... ..... 68:2;68:4; moisture 97:3; mold 63:19; molecules 59:2;78:3;98:16; moments 86:20;21:22;22:18; 26:6;84:8;115:16; 115:18;152:16;156:8; money 177:8;177:17; monitoring 120:20;40:23;41:22; 121:1; Monsanto 5:12;9:16;9:19;9:24; 10:3;10:9;10:19; 11:6;11:6;11:7;11:11; 11:17;12:6;12:13; 12:19;12:23;14:24; 16:23;17:3;18:25; 20:19;20:21;20:24; 21:8;21:22;21:24; 22:23;24:7;25:25; 26:11;26:15;26:18; 26:22;26:23;27:17; 27:23;28:11;30:5; 30:I4;30:16;31:13; 31:20;32:18;32:22; 33:10;34:14;35:10; 36:13;36:20;36:21; 38:9;39:20;41:8; 42:7;42:11 ;42:12; 42:18;44:18;45:7; 46:9;46:12;46:20; 47:18;47:24;48:3; 48:14;49:16;50:17; 53:5 ;53:14;54:20; 54:21 ;54:22;55:4; 56:19;56:20;56:25; 57:15;58:7;58:8; 58:12;58:23;58:23; 59:21 ;60:12;64:4; 64:18;64:21;64:23; 65:7;65:12;65:13; 65:21;66:1;66:16; 67:3;68:9;68:10; 68:12;72:15;75:8; 76:13 ;77:25;79:21; 79:22;80:24;81:7; 82:3;82:18;85:7; 85:9;85:14;85:17; 85:20;86:3;86:20; 87:14;88:2;88:6; 88:17;88:22;89:14; 89:21 ;90:2;90:5; 90:22;91:23;92:7; 99:1;99:9;106:8; 106:13 ;112:7;113:16; 118:13;118:24;119:11; 120:20;123:9;124:23; 125:12;125:13;125:20; 125:24;126:3;126:4; 126:13;126:14;129:19; 130:4;131:11;131:17; 131:25;132:3;145:11; 146:4;146:7;146:14; !46:16;147:16;147:19; 147:24;149:7;149:12; 149:15;149:17;150:9; 150:11;150:25;151:4; 151:19;152:24;153:1; 157:19;162:15;162:20; 163:4;163:6; 164:15;-- 164:20;164:25;165:13; 165:18;165:21;165:24; 166:2; 166:5; 166:25; 167:13;167:24;168:1; 168:3 ;168:16;168:19; 169:5;169:8;169:18; 170:2;170:17;171:24; 172:14;174:2;176:6; 181:24;186:25;187:20; 187:23;188:3; 188:5; 188:12;188:16;188:18; 188:19;189:1;189:12; 189:18;190:13;190:14; 190:24;191:1;191:3; Monsanto's 27:3;31:15^32:20; 35:22;35:25;38:12; 40:10;40:12;41:5; 42:8;42:24;44:13; 45:14;45:21;48:1; 50:21 ;50:25;51:16; 55:21;56:11;57:19; 64:2;66:10;66:15; 72:20;72:21 ;72:22; 74:2;75:24;76:19; 91:1;92:11;116:18; 129:13;131:6;133:4; 135:22;148:6;150:2; 150:6; 151:8;156:11; 157:16;165:11;165:12; 165:13;166:24;170:4; 171:13;171:15;177:25; 179:4;180:5;188:2; 188:4;189:13;191:2; Monthly 121:20; months 38:21 ;80:15;38:21; more 10:12;10:13;11:20; 13:7;13:15;24:10; 28:16;29:18;36:4; 37:20;38:3;38:18; 39:11;39:13;42:1; 42:2;45:16;46:13; 55:24;64:6;65:11; 69:8;101:20;107:12; 111 :21;120:12;120:19; many - more Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11041 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 134:13;149:2;150:22; 155:14;155:15; 160:8; 160:9;169:1; morning 42:10;183:3;183:6; 183:10; Most 36:9;130:8; most 52:2;56:7;64:8;65:13; 103:21;104:6;117:12; 123:1; 164:17; 164:24; 165:7;165:8;179:23; 181:10; Motors 131:18; moved 23:16;24:12;24:17; 24:19;24:25;26:11; 37:16;67:21;67:25; 68:3;70:10;70:13; 109:11;14:12;21:2; 23:24;24:3 ;24:6; 24:7;26:12;40:1; 54:7;63:25;69:14; 70:21 ;97:17;97:21; 107:22;117:20;149:25; 180:13;181:17; moving 40:17; much 8:23 ;11:14;11:20; 30:3;38:11;42:1; 105:7; 114:19;130:11; 138:3; 145:21 ;157:10; 164:19;174:25;177:20; 181:7;181:18; must 73:5; mutually 64:4; Myself 119:2; myself 52:24;118:17;155:10; 162:16;173:23;174:12; 175:5; -N- named 100:19; names 130:19;5:13;5:16; 48:1;60:12;62:7; 65:5;122:8;124:25; 125:12;126:21;135:16; 135:18;135:24; nanograms 186:6;187:10;186:15; national 52:7;69:10; native 78:8; Natural 177:6; natural 8:15; Nature 121:17; nature 18:17;27:25;28:12; 32:13;44:9;47:23; 54:12;89:25;119:14; 157:25;181:22;187:5; Ncr 164:18;165:1;165:8; 165:8;165:21;165:23; 166:16;172:20; necessarily 92:11;101:18;149:23; 170:1 ;173:22; necessitate 169:2; needed 24:20;24:23;48:5; 49:6;51:11;64:6; 64:11 ;65:3;80:23; 147:16;149:23;153:18; 168:14; needing 65:7; needles 80:14; needs 57:14;129:1;191:15; 7:22;26:20;41:8; 54:15;63:6;77:1; 81:9;81:23;82:25; 107:8;107:9;107:12; 107:14;113:12;131:21; 138:3;142:25;143:7; 173:8;174:25;182:7; 188:14;190:6;190:11; negative 160:12; networks 119:12; New 121:17;122:15;122:17; 123:13;135:20;135:22; newly 59:8;76:15;155:12; Newport 46:24; News 121:15; newspapers 42:3;42:10;81:17; 84:24;88:13;128:2; 185:8; 185:9; 140:24; 150:2;164:3;57:16; 67:2;85:3;113:15; 115:3;123:3;142:10; 155:8;157:12; Next 154:11; next 9:15;20:4;23:15; 49:8;57:4^7:25; 61:12;61:22;63:24; 67:11 ;83:21 ;117:8; 164:10;173:3;190:6; nobody's 143:15;152:24;187:9; 187:13; nomenclature 76:9; non-European 51:17; non-U.S. 51:16; non-agricultural 66:11; non-containing 50:18; non-electrical 144:20;182:12; non-factual 168:11; non-fire 59:5; non-flammable 160:12; non-inflammable 160:10; non-responsive 107:23;150:1; non-technical 190:11; non-verbal 6:24; none 22:5; noon 70:2; Normally 44:8; normally 41:7;95:4;97:1;97:2; 189:24;133:13; North 28:2;28:4;68:5;136:12; 148:7;193:12; northern 47:7;47:3; Norway 27:21; nor 194:10; not" 104:12; notarial 194:12; Notary 192:18;193:4;194:17; noted 26:6;122:9;21:1; 64:7; Nothing 107:18; nothing 5:3;73:23;81:17; 87:21 ;125:7;142:23; 145:18;151:15;177:22; 193:20; Notice 193:8; notice 35:6; notification 29:1; notified 167:24; noting 188:9; notoriety 156:5; novel 146:19; November 35:3 ;35:18;70:9; 70:25;71:9;72:9; 76:23;78:20;79:12; 79:19;80:5;80:19; 87:24;92:19;94:18; 103:4;105:18;153:3; 154:6;192:3;193:15; nucleus 140:2;140:4; Number 20:10;175:9; numbers 129:12;136:19;152:12; 161:8;162:9;174:22; 5:23;9:21;10:6;15:6; 19:2;19:7;19:9;19:11; 20:5;26:18;28:3; 38:4^8:11;40:3; Deposition of DAVID WOOD NOVEMBER 9, 1995 41:9;41:13;45:17; 60:2;92:3;102:15; 114:9;114:10;115:17; 122:5;124:12;130:1; 130:14;132:23;150:24; 151:1;165:18;171:12; 173:15;177:4;182:18; Nutrasweet 66:18;66:21; -o- o-i 36:11; o-l-e-f-i-n 65:4; oaths 193:6; obfuscate 98:15; objections 178:6;194:2;7:17; 30:18;91:15;167:9; 188:9; objective 158:4;10:5;30:17; 31:17;55:23;74:8; 86:5 ;91:6;95:13; 95:19;97:7;97:15; 110:1 ;111:3;116:16; 120:5;122:19;123:15; 123:23;125:6;136:5; 141:20;146:22;149:9; 150:4;151:10;156:18; 156:25;161:17;162:1; 165:2;167:2;168:18; 169:7;169:21;170:5; 171:6;177:2;178:2; 180:9;182:4;183:15; 186:12;188:7;189:16; 191:5; obliquely 147:10;147:14; observation 72:18; observing 140:12; obtained 134:7;101:24;175:11; Obviously 11:18;34:4; obviously 27:19;73:19;117:2; 181:15; occasionally 56:17;56:21;38:1; occurred 158:3; occurring 57:24; October 13:13;70:6;71:7; Oecd 175:17;175:17; . Off 47:10;70:1;191:16; offered 9:23;9:25;66:20; offering 69:3;7:16; officer 154:20; offices 26:18;72:16;193:12; 22:8;24:15;40:3; 70:24;83:25;123:7; 133:4;135:23; officially 70:24; offshore 54:3 ;54:6;54:11; 54:13 ;55:7;55:9; 19:25 ;20:6;151:22; 161:1; 170:11; oils 100:3;100:6;43:15; 59:13; Ola 36:11;36:24;36:25; 37:19;71:23;72:5; 84:23;103:5;105:18; 112:21; 112:22; 120:22; 132:7;132:10;139:7; 184:1; old 154:3; Olefin 65:3; olefins 65:4; once 38:20;39:10;39:13; 104:15; ones 43:25;66:1;180:18; ongoing 13:16; Only 135:15; only 21:12;28:13;36:22; 42:16;43:16;65:25; 73:4;73:5;99:17; 101:2;116;10;150:17; 155:13;167:18;181:9; 189:2; opening 168:23; opens 73:3;173:3;180:6; 180:21;180:22;181:8; 181:10;181:19;182:1; operating 64:24;71:2;71:6; operations 66:10;65:3; opinion 122:17; opportunity 46:12;66:4; opposed 17:25;18:1;25:15; 26:19; opposite 114:9;114:9; optimize 23:7; oral 5:5; ordering 151:22;20:5;51:13; Organic 8:21; organic 9:9;14:2;75:20;75:23; 78:2;147:5;157:24; organisms 159:5;159:9;159:14; Organization 46:4; organizational 174:14; organizations Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 more - organizations HARTOLDMONOO11042 Deposition of DAVID WOOD NOVEMBER 9, 1995 131:19;9:17;22:7; 103:19;171:14; organized 65:21; organs 74:22;75:19; orientation 11:5;11:10;11:16; 12:5;12:20;13:5; original 174:5;190:24;190:25; origins 46:18; others 6:15;6:15;81:7;169:14; otherwise 166:16; ourselves 38:7; outcome 16:9;105:6;168:25; outlined 52:13; outset 7:25;139:22;189:19; outside 26:19;53:10;128:5; 160:1; overall 118:25 ;26:17 ;33:1; 102:1;111:17;123:12; 125:11;163:5;186:3; 186:6;186:15;189:13; 190:6;190:7; ownership 174:15;151:1;96:12; 96:24;41:9;68:15; 89:18;102:3;147:11; 170:21 ;190:14; oxalalcohols 65:14; oxygens 110:23; -P- P-a-l 36:11; P-r-o-d-e-l-e 44:24; P-y-r-o-c-l-o 15:3; pace 185:11; packaging 6:12; pages 193:24;24:7;77:6; 84:6;89:1;122:10; 122:12;137:12;137:13; 137:14;137:17;138:10; 144:10;145:25;146:1; 158:20;161:14;161:21; 172:8;177:4; paid 177:5; paint 96:2;100:10;100:10; Palm 36:11;36:11;36:24; 36:25;37:3;37:7; 37:10;37:19;37:22; 38:15;38:23;39:1; 39:5;39:7;39:9;39:23; 40:2;42:16;43:1; 71:23 ;72:6;72:25; 73:9;73:11;73:18; 74:1;74:19;76:6; 76:11;77:12;77:16; 77:20;78:12;78:20; 79:2;79:9;79:25; 80:5;80:18;80:21; 82:7;83:8;83:18; 84:23;87:9;87:11; 87:24;88:15;89:12; 90:9;90:11;92:18; 93:17;99:16;103:5; 105:18; 112:21 ;112:22; 119:6;120:22;132:7; 132:10;139:7; 175:11; 175:23 ;176:4;176:19; 184:1; Palm's 76:22;79:6;79:13; 82:11;84:7;89:1; 90:25;91:3 ;100:23; pannicking 185:10;185:13; papers 128:14;128:15; . paperwork 81:15;62:16;63:13; 63:15;75:5;80:7; 80:11;93:18;152:21; 153:21;157:2; _______ Paragraph 158:21; paragraph 75:10;77:7;77:8; 77:17;78:25;79:1; 79:2;84:7;84:10; 84:17;87:10;87:13; 87:25;88:16;89:2; 100:23 ;100:24; 104:8; 104:13;107:4;108:16; 110:18;116:4;116:4; 118:2;118:3;118:4; 118:10;134:17;138:6; 141:10;141:24;144:8; 144:11; 158:22;158:22; 158:25;164:1;164:11; 165:3;168:24;172:4; 172:7;177:3; Parks 130:24; -- Particularly ' ' 119:14; particularly 39:17;89:7;9:24; 13:25;22:21;23:6; 29:2;36:8;39:18; 52:3;55:12;77:3; 78:25;87:17;92:2; 99:10;122:9;122:14; 125:14;138:10;139:11; 142:25;144:7;147:21; 153:21; 165:21;165:22; 180:15;185:4;185:6; parties 194:9;194:10; partner 46:14;69:21; parts 20:20;63:13;168:12; 181:12; party 128:21;8:10;18:2; 22:5;22:16;28:7; 28:9;45:24;46:3; 46:5;46:18;49:23; 50:9;54:24;55:2; 56:24;62:14;62;23; 65:10;67:21;78:4; 88:6;98:18;111:12; 121:8;142:7;142:19; 144:7;154:22;159:14; 169:11 ;173:9;175:14; 180:13;180:14;180:15; 181:9;183:19; past 55:22; patient 97:9; Paton 68:22;68:23;69:21; Paul 82:12;82:15;83:8; 102:23;103:14;104:4; 137:3; payment 40:14; Pcb 16:18;16:20;74:21; 75:3;75:14;93:1; 93:4;158:15;159:1; 180:3 ;189:2; Pcb-containing 57:18;58:17;59:23; Pcbs 16:15;50:15;51:1; 51:4;56:6;56:10; 56:11;56:14;56:21; 56:23 ;57:19;57:23; 58:7;58:10;59:1; 60:24; 144:3; 146:8; 146:9;146:12;146:17; 151:8;154:18;155:21; 156:2;156:4;156:7; 159:3;159:8;160:7; 182:2;187:18; Pets 51:2;51:7; peaks 140:11;140:12;158:2; 130:8;157:9; peers 11:9;155:15;143:12; pending 193:8; penetrate 78:1; pentachlorobiphenyl 160:13; pentachlorophenol 105:7;105:8;116:8; penultimate 84:10;84:17;89:2; 100:23; people 25:21;32:6;33:2; 33:6;36:9;42:19; 50:7|56:17;61:6; 76:7;90:1;93:14; 95:23 ;105:13;107:13; 109:10;109:16;119:11; 121:4;i27:23;131:25; 139:14;145:2;145:23; 147:16;150:17;151:22; 153:18;153:20;153:23; 155:17;157:23;159:11; 166:13;167:18;171:12; 181:2;185:10;185:10; 185:13;186:1;187:15; percentages 17:14;17:17;19:21; 129:22;130:11;17:18; 17:20;45:16;48:2; 130:4;135:21 ;179:23; 184:2;184:6;184:7; TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 184:10; performance 14:22; perhaps . 131:16; periods 186:4;11:3;11:4; 13:1;13:9;13:11; 18:13 ;21:20;22:2; 22:5;22:19;22:21; 26:1;37:11;37:15; 37:18;37:22;39:12; 39:l5;39:22;48:23; 54:2;58:3;61:19; 68:16;70:4;70:21; 71:1 ;71:5;106:11; 121:13;123:17;187:14; Perry 193:12; Personally 119:9; personally 39:1;146:4;77:17; 145:14;155:4;159:2; personnel 35:4;35:9;11:13; 42:16;103:21;118:11; 118:12;121:18;126:20; 135:23;148:2;154:3; 170:19;170:21;171:2; 171:3;174:2;175:20; 190:11; perspective 139:12; pertained 175:13; pertinent 42:6; peruse 152:16;40:2;67:20; 157:21;157:22; pesticide 90:20; Peter 25:24; petrochemical 65:9; phamacological 173:5; pharmaceuticals 12:10;47:21;47:22; phase 62:23; phenolic 125:4; phenols 85:10;94:2;94:7; 94:8;94:12;94:15; 94:20;94:23;95:1; 95:6;95:8;95:10; 95:11;95:16;95:18; 95:21;98:6;98:8; 98:11;99:24;100:2; 100:5;100:9;100:12; 85:7;85:12;85:15; 85:18;85:20;85:24; 86:9;88:9;94:9;96:13; 96:16;96:23; phone 113:7; phosphate 50:21 ;54:4;55:14; 125:16;125:17;125:19; 125:20;125:25;131:8; phrase 31:25;87:9;120:14; physically 70:13;8:22;9:6;10:7; 180:17;181:9; Physics 121:21; physics 8:24; picked 7:2;6:24;70:19;83:13; 164:3; picture 179:1; pieces 150:21;151:2;150:16; 179:17;179:24; pigments 100:13;100:18;63:10; pike 80:12; pilgrimage 170:11; pine 96:10; Pipeline 5;10;6:10;53:14; 53:17;53:22; placed 65:6;....................... places 129:10;129:12;26:10; 37:20;41:13;64:13; 99:16;102:1;110:3; 149:20; Plaintiff's 20:7;20:10;72:1; 102:11 ;102:14;115:12; 115:15;122:1;122:4; 124:8; 124:11 ;132:19; 132:22;136:15;136:18; 152:8;152:11;161:4; 161:7;162:5;162:8; 171:22;172:12;174:18; 174:21;182:14;182:17; planes 56:15; planned 177:7; planning 12:16; plans 176:21; plants 32:10;67:1;145:1; 145:1;179:8;46:22; 136:12;186:19;139:24; plasticizers 6:11;67:15;67:25; 131:6;131:10; plastics 12:6;66:11;100:13; 100:18;68:6; played 171:19; playing 120:17;120:2;120:7; 120:15; Please 102:10;115:11;115:15; 124:6;124:7;132:17; 133:1 ;136:14;138:3; 144:14;152:7;152:16; 162:3;167:5;174:17; 174:25;178:8;182:13; please 5:15 ;7:13 ;7:22;8:4; 20:4;20:16;30:25; Gore & Perry Reporting Co. St. Louis, Missouri organizations - please (314) 241-6750 621-4790 HARTOLDMONOO11043 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 72:12;91:11;97:21; 102:18;120:13;154:9; 161:2;162:12;175:2; plenty 65:20; plural 105:25; points 173:15;173:20;175:12; 183:23 ;9:24;11:14; 13:25 ;21:24;25:1; 28:8;31:12;34:19; 35:13;36:18;36:19; 39:18;42:2;44:6; 45:23;54:9;56:6; 59:13;60:15;64:8; 65:8;68:18;76:10; 77:3;99:10;99:22; 103:20;107:6;109:11; 109:21 ;109:22;111:8; 111:12;113:25;117:12; 131:9;135:8;138:15; 139:21;143:6;145:19; 147:21;157:10;158:4; 158:10;159:16;162:22; 164:21 ;166:23;167:19; 168:19;170:25;171:11; 171:16;176:12;182:9; Poisonous 89:6;90:6;90:17; poisonous 78:22;79:4;79:8; 94:16;94:17; Polaroid 63:17; pole 25:1; policy 171:20; pollution 164:8; polychlorinated 16:24;51:5;51:8; 74:21 ;74:24;75:6; 75:13;76:2;76:5; 76:18;76:24;77:10; 77:13;77:21;77:23; 78:15 ;82:2 ;87:10; 87:12;87:15;88:1; 88:16;88:18;88:22; 89:13 ;91:4;91:24; 92:14;93:3;93:4; 98:5;101:8;104:18; 104:21;106:9;106:14; 108:1;108:6;108:7; 134:19;134:20;136:13; 140:8;140:14;140:16; 155:2;155:6;155:11; 159:18;166:3;177:18; 177:25;179:5;180:6; 180:7;181:25; polymer 68:2;68:3; polyphenyls 116:6; population 188:22; portion 31:2;91:13; 108:3; 144:15;167:7;178:10; portrayed 52:16;56:17;33:22; positions 9:23;20:23;9:25; 10:22; 19:22;23:20; 24:17;28:11;36:6; 47:13;48:10;49:8; 49:10;49:24;50:16; 57:4;57:25;61:12; 61:21 ;61:25;62:18; 63:23;64:17;65:7; 66:6;66:7;66:14; 67:6;67:11;67:17; 67:20;70:5;70:10; 92:5;92:13; 112:5; 114:17;117:3;120:17; 151:21;174:2;174:12; possibility 147:7; possible 76:4;81:1; possibly 101:1;179:10; potentially 46:13;57:17;180:3; 180:21;13:21;43:19; 169:10;169:10;169:11; 169:12;177:24;179:3; 181:17;181:20;181:23; 182:2; pourous 109:6;109:7;110:6; power 19:8; Ppo 17:13;17:21;18:1; 18:7;18:9; practically 175:19; practices 33:7;33:5;113:25; practicing 143:1; pre-published 128:21; precious 65:12; precisely 6:7;23:9;14:8;103:19; precision 33:3; predominantly 51:14; preliminary 73:20; - preparation 153:7; prepared 35:8;136:24;136:25; 183:7;35:7;41:13; preparing 34:8; presence 23:8;23:9;24:10; 26:15;26:22;27:4; 27:17;27:22;45:14; 51:16;55:17;92:25; 150:23;187:17; presentation 153:2;79:18;79:22; 79:25;128:14;160:10; preservation 95:24;96:1;96:5; preservatives 95:7;96:21;96:19; 97:1 ;97:25; preserve 96:3; Press 137:22; pressure 100:7;41:3;41:5; 41:9;41:13;41:17; 41:23;120:3;120:8; 120:13;128:4;137:24; 138:7;138:10;141:6; 141:17;142:1; 142:7; 145:10;145:17;148:9; 149:4;166:13; pretty 42:4;71:9;71:21; 96:22;155:5;189:11; previously 6:19;25:8;29:17; 72:1;116:19;118:8; 131:25;132:3;136:21; 137:7;147:6;175:7; 26:13;49:15;87:6; 117:25;153:18;153:20; primarily 118:11;118:13; primary 63:20;110:22; prime 91:24; Prior 23:24;73:22; prior 37:6;73:2;73:5;103:1; privy 170:6; Probably 71:7; probably 10:14;38:18;38:18; 40:2;51:22;51:23; 52:5;67:23;70:19; 83:2;89:2;89:4;90:15; 105:16;107:8;115:4; 116:7;117:9;125:2; 130:16;133:15;144:13; 155:10;169:25; problem's 185:17; problems 76:9;133:25;157:6; 160:18;108:17;108:19; 108:25;109:2;116:10; 133:21 ;134:2;134:3; 172:15;174:16;180:4; procedures 160:21;179:8;142:8; 147:18;150:22; processes 160:20; processing 101:22;14:7;14:8; 30:13;61:23;62:3; 62:13;62:14;62:19; 63:3;63:23;69:19; procurement 28:1; Prodelec 44:24;146:14;157:19; produced 29:4;59:13;129:19; 140:12; producers 19:17;38:11;58:13; 60:5;63:21;64:16; 65:9;92:13;146:9; 146:12;38:10;45:1; 45:2;47:25;146:7; 146:17;60:19;60:19; 64:18;129:14;160:2; producing 14:8;60:5;60:10; 63:20; Deposition of DAVID WOOD NOVEMBER 9, 1995 Product 13:19; production 29:11;34:5;59:20; 62:15;102:15;115:17; 122:5;124:12;129:13; 132:23 ;136:19;152:12; 161:8;162:9;174:22; 182:18; Productor 142:9;142:21;143:3; 143:18;143:25;145:11; 145:17;146:20;149:3; 149:13;149:16;149:19; 150:15;150:17;151:7; 151:12;151:16;151:23; products 11:17;12:4;12:15; 12:18;13:19;13:23; 14:2;14:3;14:16; 16:24;22:24;29:12; 29:22;30:2;33:11; 36:13;36:16;40:12; 40:19;46:2;47:8; 47:19;51:12;51:17; 52:2;62:8;62:21; 62:22;63:2;64:18; 66:20;66:23;74:20; 76:20;85:7;88:1; 90:12;90:13;96:6; 105:5;107:13;108:8; 125:25;131:10;145:3; 170:25;171:17;187:25; 188:4;189:20;9:8; 11:19;11:21;13:14; 13:23;14:3;14:12; 14:18;15:6;18:5; 18:9;23:4;28:16; 28:19;28:21;28:23; 28:24;29:14;31:24; 33:15;33:20;34:2; 34:13 ;34:13;34:16; 34:21 ;35:17;35:21; 36:7^6:12;40:4; 40:8;41:2;42:11; 42:25;43:2;45:4; 45:5;47:3;47:13; 48:12;48:16;48:22; 48:24;48:24;49:9; 49:16;50:11;70:10; 70:17;70:24;76:12; 81:6;82:3;82:16; 85:24;86:23;87:14; 88:3;89:21;90:2; 97:8;98:14;98:25; 105:20;107:7;109:4; 111:22;113:16;113:18; 113:21 ;118:22;118:23; 118:25;151:22;158:1; 163:5;171:13;174:6; 174:6;174:9;187:21; 190:15;191:12; professionalism 145:22; professionally 127:25;20:22;40:22; 121:23;143:1;143:22; 143:24;148:7;151:2; 155:15; Professor 132:7; professor 126:18;126:19;160:19; profitably 66:24; programs 151:24;49:22;54:12; 116:12;116:18;121:1; 131:6;139:11;141:5; 141:17;142:3; progression 26:21; progressive 27:3; projects 67:2; promote 142:10;143:20; pronounce 79:14;87:18;124:25; properly 178:21; properties 59:9; property 102:3;57:18; propounded 5:5;194:1;194:5; propylene 64:22;65:5; protection 96:13;97:3; protocols 152:1;160:21; proud 128:5;128:6;188:11; proved 60:6; provider 157:20;190:6;189:23; providing 33:4; prudent 96:12; Public 192:18;193:4;194:17; publications 119:7;119:17;120:4; 121:7;121:10;122:23; 123:4;104:12;107:3; 107:5;107:25;121:5; 121:11;122:7;122:8; 122:10;123:10;123:22; 143:8;143:11 ;161:15; publicity 72:18;73:13;74:7; 74:13;74:16;85:3; 120:20;128:7;164:9; 184:22; publicize 182:7;41:11;41:20; 84:22;107:14;121:1; 128:1 ;170:12;170:24; published 84:13;106:13;106:17; 106:20;108:5;108:9; 119:8;120:24;127:9; 127:25;139:14;139:15; 143:17; publishing 104:19;145:12;106:9; 107:10;108:11;123:14; 128:16; purchased 150:12; purchases 65:16;66:7;102:4; 102:5;149:16;149:18; purchasing 27:23 ;64:1;64:14; 64:17;64:21;65:22; purely Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 please - purely HARTOLDMONOO11044 Deposition of DAVID WOOD NOVEMBER 9,1995 24:14;28:16;15:16; 15:18;101:17;101:23; 129:17;129:18;176:6; purification 101:22; purposes 101:19;126:5;127:23; 136:24;126:14; pursuant 110:19;193:7; putting 130:14;35:5;87:20; 120:15;139:23; 143:20; 143:22;156:7;167:25; 169:13; puzzlement 80:22; Pydraul 12:21 ;12:23;49:20; 49:25;50:1;50:5; 50:21;50:25;51:12; 52:10;53:25;54:5; 54:15;54:18;55:6; 55:8;55:13;56:25; pydrauls 50:18;55:25; Pyroclor 15:3;15:12;16:15; 16:17;16:21;17:1; 17:4;17:6;17:10; 17:16;17:24;18:3; 18:8;18:10;18:11; -Q- qualifiable 81:6; qualifications 169:14; qualified 155:14;159:22;169:23; 170:2;171:14;193:5; qualify 178:12; quantities 105:7;150:24;186:3; 186:15; quantum 8:24; quarters 38:3;85:6;38:1; question" 146:5; questioned 84:22; quickly 83:9;175:20; quite 36:21;105:1;134:18; 164:16;164:20;165:6; 166:10;166:17;173:4; 97:20; quotation 80:17; quote 74:20;77:9;79:3; 79:6;80:12;84:12; 89:2;89:4;100:24; 104:9;116:5;116:10; 134:18;140:20;142:2; 146:3;164:1;164:6; 171:23;172:13;172:19; -R- R-i-s-i-n-g 36:3; raised 176:6;189:14;191:3; rambling 117:17; Randy 135:21; range 12:11 ;29:3 ;43:9; 62:11;65:14;66:20; 69:3;121:11;121:22; 156:11;187:3; ransom 177:18;68:1;184:4; rapidly 83:10;175:21;183:25; rates 94:25;143:4; rather 33:23;64:8;82:6; 87:22;93:25;175:20; Raw 64:19;64:19; raw . 47:23;64:20;65:15; 65:23 ;66:1;66:3; 66:7; reached 65:2;155:4;160:23; 183:24;60:15;107^^ 160:2; reacting 185:13; reaction 80:20;80:22;84:18; readers 153:12; 123:8; readily 102:1;128:25; reading 79:5;84:16;121:22; 165:4;166:13;173:9; 180:10; ready 60:9;30:25pl:3; 42:2;78:8;78:11; 84:18;89:3;91:14; 108:4;116:9;117:13; 121:7;121:12;121:14; 121:15;121:17;12i:17; 121:19;123:5;123:1(S; 124:1;126:7;141:14; 144:5;144:16;155:6; 157:2;163:17;165:4; 165:7;166:11;167:8; 173:2;173:7;178:8; 178:11;192:2; reality 76:17; realization 146:24; 147:2; realized 155:1; really 12:25; 16:19;24:12; 33:22;59:16;62:8; 68:17;81:25;88:13; 94:10;107:18;113:20; 117:10;134:19;168:21; 187:13;43:25; reasons 56:14;157:20;188:18; 35:4;35:16;67:18; 159:3; reassurance 185:21;185:23; rebuttals 145:12; recalled 118:1 ;6:5;6:15;12:25; 17:9;17:20;53:18; 53:21;55:3;71:17; 71:19;73:8;73:25; 74:4;83:16;83:19; 83:20;83:23 ;85:11; 85:16;86:1;94:19; 102:25;103:20;104:3; 109:20;117:21 ;122:14; 124:19;127:12;127:15; 127:18;128:8;138:20; 138:22;138:23;139:2; 139:5; 142:20;144:5; 145:7;148:19;148:24; 154:13;154:15;161:24; 163:8;173:17;175:10; 176:12;176:13; 183:4; 183:9; recategorization 18:4; received 13:7; 14:2;29:1 ;71:23; 72:5;74:6;74:12; 74:15 ;81:14;82:7; 83:17;88:14;103:5; 112:22; 113:8;116:18; 117:5;117:21;119:5; 120:3; 121:18;126:8; 128:1 ;133:7;133:9; 133:11;133:15;153:10; 154:25;155:19;165:21; 165:22;183:22;185:25; 11:2;11:16;12:4; 12:20;13:18;13:23; 116:12;128:23; receiving 13:16;81:15;83:7; 105:18;163:15;164:16; 164:20;165:6;165:16; 166:10;166:12; recently 104:6; Recess) 70:2; recess) 47:11;132:16;191:17; recipients 141:3;145:9; recognition 84:20; recognized 28:15;30:6;150:22; 20:13 ;69:7;102:16; 122:7; 122:8;122:9; 122:11;132:23;136:21; 136:23;147:15;152:19; 153:25;161:8;161:11; 162:10;174:23;175:1; 182:18;182:21; recognizing 28:12; recollection 153:17; recommendations 104:10;104:23;105:11; 105:15;178:16;186:24; 187:7;101:7;105:22; 110:10;114:2;145:14; recommended 109:2;109:21;li4:4; 114:6;102:6;149:15; 149:17; record) 20:6;161:1; records TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 35:12;84J;5:16; 20:17;31:3;35:4; 47:10;70:1;72:13; 91:14;97:11;97:18; 97:19;102:19;104:21; 108:4;115:16;115:21; 117:9;122:4;133:2; 136:20;144:16;162:13; 167:8;175:3;178:11; 188:16;191:16; recounting 80:7; recover 179:23; reduce 190:9; redundant 123:12; referenced 13:6; referred 16:23;17:12;62:6; 62:13;75:2;75:4; 75:13;75:15;76:23; 77:13;77:22;87:25; 88:15;134:1;153:7; Referring 74:9; ....................... referring 49:6;69:6;72:5;84:8; 116:22;130:21;174:8; 174:10;174:11; refers 183:3;18:8;19:18; 34:24;147:16;147:19; reflected U2:14^1:2;21:7; 24:16;35:5;97:18; 97:19; reformulated 51:1;56:19;56:25; refresh 144:8;173:17; regarding 11:16; 12:5;29:20; 101:6; 127:8; regardless 178:6; regional 69:10;46:7; registered 89:5;90:6;90:17; 90:19;89:3; regularly 123:5;38:17;115:6; 121:8; regulations 58:15; related 6:14;11:21;13:20; 18:16;18:17;18:21; 50:10;74:2;75:5; 78:2;78:22;79:3; 79:7;81:22;90:2; 92:11;93:3;93:11; 94:20;98:25;107:25; 118:14;121:5;133:25; 155:1;155:6;170:23; 175:23 ;182:11;190:19; 194:10; relates 77:18;57:12;94:7; 105:3; relating 6:13;30:15;31:14; 32:19;71:12; 106:9; 106:14;163:11; relationships 24:5 ;22:6;23:1 ;23:11; 37:19;145:3;41:3; 41:5;41:11;41:20; 108:17; Release" 137:22; release" 138:8; releases 179:9;41:9;41:13; 41:17;63:19;84:21; 105:6;137:24;138:10; 140:24;141:6;141:17; 142:2;142:7;145:10; 145:17;148:9;149:4; 180:23;181:15; releasing 180:2; 180:3; 181:11; relevance 80:25;182:8; relevant 107:16; relying 49:2;41:19;41:22; remains 179:18; .................. remarks 194:2; remember 6:8;20:2;43:24;47:5; 60:17;83:3;83:4; 83:9;86:13;103:17; 117:8;117:10;127:20; 138:20;176:5;176:15; 176:17; remind 6:20; removed 156:1;51:1;69:18; Repeat 108:2; repeated 30:24;91:7; repeating 97:20;91:11;106:23; 144:14;167:3;167:5; 188:13;188:14; repellent 97:3; rephrase 31:11 ;37:4;39:8; 178:12;178:24; replacement 58:24;59:3;59:21; 57:17;58:9;179:22; reply 5:5; reported 22:9;23:14;26:7; 73:22;79:5;80:18; 92:23 ;92:24;99:20; 134:18;134:22;144:18; 183:5;187:7;193:22; reporter) 31:3;91:14;108:4; 144:16;167:8;178:11; 6:23; Reporting 193:12; reporting 21:20;22:3;22:6; 22:12;22:15;22:19; 22:22;22:25;23:10; 23:17;24:2;24:4; purely - reporting Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 HARTOLDMONOO11045 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 24:5;24:13;25:6; 25:16;25:18;34:20; 72:17;76:8;89:17; 90:1;115:7,115:8; 169:11; reports 113:18;133:24;134:11; 135:6; 155:16; 165:17; 184:2;185:1 ;23:15; 23:25;25:2;25:3; 34:17;82:6;84:23; 93:9;99:19;99:20; 113:8;113:17;114:1; 114:6;126:22;127:9; 127:15;143:1;143:22; 144:6;154:20;162:23; 162:25;177:10;185:2; 186:13; representation 81:5; representative 37:1 ;40:6;43:2;72:16; 79:22; represented 66:21; representing 5:9;5:11;57:18;66:15; reputation 81:17;85:1;188:17; requested 31:2;91:13;108:3; 128:23;128:24;144:15; 167:7;175:8;178:10; requests 128:10;183:22;64:1; 64:3;175:7;190:19; required 111:7; requirements 40:21; researchers 79:10;89:20;99:3; 127:11;139:13;142:9; 73:17;74:2;74:6; 74:12;74:15;74:20; 75:1;75:16;75:21; 78:14;82:4;89:13; 92:21 ;93:20;104:25; 118:21;119:7;123:21; 128:12;136:2;136:2; 136:4;136:11;139:11; 139:19;141:5;14l:7; 141:16;142:3;143:14; 151:18;151:24;159:9; 160:15;160:20; resent 188:15; reserve 40:18; reservoirs 163:22; residence 5:20; resident 24:21;5:18; residues 134:12;139:17;139:22; 140:13;172:21;150:24; 157:11; resins 63:12;67:13;67:13; 67:21 ;67:23;68:4; 98:18;17:13;67:14; resistant 60:18;60:19;98:12; 98:18; resituated 59:6; resolution 148:4; Resources 177:6; resources 174:14; respected 143:9; respects 194:3;11:23;12:20; 29:19;53:7;63:1; 136:4;136:8;142:1; 167:1 ;186:17;189:1; responded 109:20;175:21; responding 105:2;175:6;30:19; 91:16;110:2;144:13; 160:25;167:10;167:22; 188:10;188:11; responses 6:24;7:1;109:17; 110:24;113:11;115:23; 128:4;173:1;184; 1; responsibilities 21:21;22:3;22:14; 22:19;25:7;27:9; 28:22;28:25;29:19; 30:8;33:15;33:19; 35:21;43:3;47:17; 53:7;55:15;57:10; 58:4;58:21;62:2; 62:4;62:17;62:25; 66:13;171:16;188:20; Responsibility 58:6; responsibility 21:3;22:23;29:5; 29:9;29:21;42:9; 57:20;63:4;63:17; 66:23 ;82:1;82:5; 114:21;115:2;115:8; U8:17;118:21;119:l; 119:16;167:20; responsible 34:12;36:13;36:16; 52:19;52:22;52:23; 64:21 ;64:22;65:15; 81:20;89:17;118:13; 119:25;120:2;183:18; 187:20;188:5;189:3; 191:4; responsibly 58:7;118:8;168:4; responsiveness 190:18;31:8;117:25; 190:14;190:20;190:24; 191:1;191:9;191:14; restate 87:23; restructured 68:3; restructuring 67:19;184:13; resulted 180:18;16:7;120:24; 152:25; retained 59:19; retardant 59:5; retention 157:7;157:8; retired 163:6; retirement 68:9;68:11 ;68:15; 68:15;68:14;68:14; retract 133:10; return 70:3; revealed 74:20; reverse 191:11; reviewed 35:8 ;115:25; 174:24; 175:8;179:8; reviewing 163:16;6:17;115:16; 115:18;128:1;138:4; 143:12;145:17;149:22; 157:5; reward 68:16; Richardson 133:20;133:24; 134:7; 134:17;134:21;134:24; 135:7;135:10;135:12; 135:12;135:14; Richardson's 135:2;135:9;135:16; 135:18; Ridge 5:21; right-hand 161:18;182:22;16:5; 16:8;16:13;16:16; 16:25;22:20;23:12; 33:17;42:14;44:7; 47:1 ;51:2;51:3 ;51:5; 51:14;53:11;59:19; 65:18;65:19;70:11; 71:3 ;72:23;73:15; 75:11;75:14;75:19; 81:11;85:21;87:15; 88:19;88:23;90:10; 91:5;92:21;97:6; 109:15;111:2;112:23; 113:11;114:5;116:22; 117:22;130:2;131:13; 133:10;133:12;137:25; 141:12;143:8;144:4; 144:24;144:25;152:14; 153:3 ;153:15;158:11; 160:23;161:25;171:2; 171:2;173:16;175:20; 175:24;186:10;189:15; rigs 54:8;54:7; rings 129:4;129:9;130:1; 130:18;130:6;130:7; 130:8;130:9;130:10; 130:15;140:2; ripe 45:21; rise 95:11; Rising 36:2;36:5;37:2;40:9; 41:16;41:22;42:16; 44:11;44:13;72:14; 72:17;175:4; . road 122:21 ;149:22; roles 24:13;11:10;11:12; 11:15;17:14;24:13; Deposition of DAVID WOOD NOVEMBER 9,1995 24:24;25:10;26:24; 28:8;28:15;28:17; 28:18;40:9;48:16; 48:17;48:17;48:25; 54:24;61:15;64:14; 103:17;103:19;111:22; 118:24; 171:19; 174:4; 190:15; Rolls 149:22;149:23; Roily 5:11; Ronald 193:4; rose 62:7; routinely 121:14;38:3; Rowan 193:9; row 38:21; Royce 149:22;149:23; Rte 59:14; Ruabon 136:11; Ruan 43:20; running 6:25;107:19;151:8; -S- S-k-y-d-r-o 49:17; S-t-r-a-n 36:3; csfotv 33:4;105:20;170:23; 171:18;172:21;187:25; 189:20p0:2;30:8; 33:8;109:18;109:24; 110:6;110:12;110:21; Saflex 68:6; salesman 11:20;13:7;19:23; 20:2;21:2;21:5;21:15; 21:16;21:17;22:12; 22:13;25:16;25:16; 135:22; salesmen 25:18;26:23;27:2; 27:23;10:22;11:13; 11:15;13:1;13:5; 13:8;13:16;13:17; 14:11;24:18;25:2; 25:8;25:21;26:2; 26:18;27:8;28:8; 28:14;28:16;28:20; 29:9;33:16;34:2; 34:13;36:25;40:22; 43:1;70:4;72:16; 111:12;111:23;181:6; 181:8;108:7; salmon - 80:12; Same 91:15;167:9; same 7:7; 10:20;22:7;24:7; 62:8;63:14;105:16; 137:9;138:24;138:25; 156:22;157:9;157:9; samples 126:4;126:8;126:14; 128:11;140:9;151:8; 175:24;176:5;150:24; 153:6; sampling 92:1; San 6:12; satisfactorily 57:22;35:13; saved 191:6; saw 11:8;11:15;42:5; 80:20;123:7;131:7; saying 29:1 ;32:15;32:16; 41:23;42:9;80:12; 80:22;108:12;109:21; 114:11;117:11;119:18; 148:13;149:21;166:14; 173:11;185:17;185:18; 186:1;186:13;187:2; 187:23;191:8; scale 108:15;122:24;170:12; Scandinavian 44:9;44:11;45:24; 46:3; scattered 140:3; scavengers 17:12;17:25;18:7; schedules 34:5; scheduling 29:11; school - 8:6;8:7; sciences 8:15;8:23;99:23; 143:10;143:11;185:11; 185:12;185:15; scientifically 31:16;32:21;139:15; 81:15;104:16;119:7; 119:13;119:17;120:3; 121:5;121:7;121:10; 121:11;121:13;122:20; 122:25;128:15;157:3; 159:7;159:15; Scientist 121:17;122:15;122:17; 123:14; scientists 79:11;79:19;80:8; 81:24;93:15;99:19; 114:2;118:5;136:2; 92:9;92:9;121:19; 128:3;128:18;148:7; Scotland 100:20; screening 122:23; script 152:20;154:2; sealant 96:17;97:2;97:2; 194:12; Searle 66:18; sea 80:13; secondly 69:2;46:25;47:2; 51:20;56:12;62:12; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 reporting - secondly HARTOLDMONOO11046 Deposition of DAVID WOOD NOVEMBER 9, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 68:3 ;77:7;84:16; 91:9;104:8;104:13; 107:3;130:24;134:16; 144:10;145:25;146:1; 155:14;158:22;172:8; 177:4; secretary 106:5; section 154:14;154:20; sectors 60:3; security 5:23; seeing 120:2;140:14;142:13; 149:4;155:5;157:17; 180:20;180:20; seek 80:23; seemed 76:14;117:11 ;185:10; 185:10;185:14; seemingly 33:4; seems 21:13;93:12;17:19; 43:24;104:3;131:12; 148:10;148:10; 158:6; 173:17;180:16;185:5; selling 13:20;13:22;14:13; 14:16;22:24;26:13; 26:24;29:23 ;30:11; 50:1;56:20;59:21; 90:19;111:13 ;166:6; 13:20;14:1;49:18; 66:23 ;88:4;88:17; sending 73:7;73:21;105:17; 155:15; 111:19;114:4; 114:7;149:1; senior 22:12;103:12;103:21; 103:25;104:2;114:9; sense 99:22;128:21;149:2; 152:5;180:12;185:15; sentences 116:15;77:12;78:12; 78:18;79:6;84:17; 84:19;107:22;110:15; 110:17;149:25;164:10; 173:1;173:3;183:2; 36:11;72:25;73:11; 73:18;103:4;104:4; 104:5;107:24;112:2; 112:13 ;133:17;148:25; 153:12;153:14;153:21; 163:11 ;176:13;176:16; 176:17;184:8; separately 138:21;148:15;47:18; 139:3 ;139:3; September 13:13;71:7; sequence 52:12;61:17;83:1; 108:14;138:22;139:4; 191:8; sequentially 138:21; series 6:21;92:2;115:3; 151:16; seriously 30:7;188:20; 6:4;57:2;130:9; 38:20;76:8; 101:16; 62:10;64:9;67:14; serve size 176:15;21:5;37:15; 67:15;68:1;44:6; 44:13;67:1;96:16; 10:3;10:6;47:3; 37:18;86:20; 129:15; 96:18; skills somewhat species service 48:7;69:3; 17:23 ;157:4; 134:5;147:5; 58:18;179:18; Skydraul Somewhere Specifically sets 12:12; 19:24; 127:14;165:16; 158:14;158:25;33:3; Skydrol somewhere specifically 33:4;110:15;110:17; 49:17; 122:21 ;148:17; 54:15;74:24;77:7; 135:24;169:9;170:10; sky soon 84:7;127:12;127:16; 193:25; 56:16; 83:7; 158:19;179:25;11:21; seven slightly sophisticated 12:15;13:8;14:23; 130:10;173:20;175:13; 29:13;101:20;141:2; 54:9;129:15; 41:16;52:8;54:4; 175:15 ;183:23; 33:23 ;67:20; Soren 108:17;129:12;129:12; several slower 91:22;92:2;126:21; 145:2;153:17;167:22; 9:23;38:15;38:17; 94:23; 127:11;127:22;128:2; 189:21 ;190:19;190:20; 40:7;66:2;70:20; slowly 133:22;152:21;176:14; 191:13; 84:14;85:5;144:2; 95:8;95:5;95:9; 180:10; spectrographic 144:19; smaller Sorry 134:7; shall 104:11; 19:7;147:6;181:7; smallest 86:25;152:13;178:25; sorry spectrographs 148:18;153:6; shaped 157:20;17:14;17:15; 25:12;55:8;60:14; spectrometer 14:8; , 17:17;19:1;19:9; 108:22;117:16;117:24; 141:5;142:22;146:21; share 36:22;38:4;43:16; 127:2;137:13;137:15; 149:19;150:13;151:5; 45:6; 43:25;45:1 ;49:21; 141:10;149:16;155:25; spectrometry Shell 49:23 ;54:25;55:2; 171:25;178:7;188:8; 147:13;155:8; 133:20; 59:25;64:9 ;65:22; sorts speculate shifted 68:19;150:23;179:10; 97:4;9:4;13:18;32:24; 84:1;84:4;161:22; 178:25;............. .......... ' 183:19;186:2;187:18;" " 40:21 ;42:21 ;60:8; ... Speculative shipping smattering 61:16;64:20;79:16; 168:22; 42:21; 51:24; 81:6;109:21;110:4; spelled shopping socially 110:10;110:11 ;113:16; 43:8;75:9;75:9;77:13; 34:3; 84:25;5:23; 120:7;121:4;123:18; 77:14; shorthand Society 128:16;130:12;131:21; spellings 193:23; 121:21; 140:5;140:6;143:3; 64:23;37:2;101:12; shortly society 145:16;145:22;148:13; 63:6; 34:19;148:21;73:20; 181:5; 156:3;158:8;159:23; spend 75:3; sodium 160:1;160:3;167:25; 123:25; shouldn't 105:8; 169:4;172:20;173:11; spent 39:20;61:9; sold 177:16;185:16;185:24; 177:17;177:19;177:20; shown 11:17;12:23;14:24; 189:24;191:8;191:10; spilled 174:15;193:21;71:25; 15:6;17:3;18:2;18:12; sought 101:8;102:8; ll9:23;142:16; 18:23 ;43:20;88:22; 175:22;183:23; spirit side 157:19;188:1; sound,"Vidmark" 110:3; 152:13;156:7; solely 125:3; splintered Sieman's 53:25;38:10;146:16; soundness 60:1; 19:19; 190:5; 134:24;135:11; spoken signature - solicit sounds 126:24;132:2;83:20; 192:4;194:6; - - 167:20; 189:10;135:1;135:3; 83:24;84:3;102:23; significant solid 135:13;193:17; 112:20;112:21 ;112:23; 38:5;81:13; 160:20; source 132:8; silicates solutions 93:7; sponsor 14:2;14:4;14:14; 59:22;60:2; South 127:10; 12:13;14:2;18:16; solvents 53:2;68:6;69:13; spot 18:21; 62:15;63:15; space 157:9; silicone 59:8; somebody's 158:5;17:5;24:20; 49:22;51:25; Spain spraying 181:3;181:5;181:16; similarities 68:14;90:15;98:21; 27:21; spring 140:11;109:6; 119:14; 107:19;149:1;149:21; Spanish 10:23;13:14;14:1; 133:21; 134:1; 134:9; 191:9; 45:1; stability 134:14;140:14;157:8; somehow speaking 179:17; 158:2;180:25; 19:25; 76:6;76:12;94:21; stabilize simple something 38:24;53:16;82:23; 101:9;109:8; 189:11; 7:2;11:5;17:2;37:13; 83:3;127:1;127:4; stable simultaneously 42:5 ;42:11;47:21; 127:7;132:9;148:8; 134:13; 26:12;58:19; 47:23 ;48:2;53:4; specialist staff Sitting 64:11;81:5;81:21; 40:5; 22:17;24:11; 90:24;91:2; 81:22;89:19;92:6; specialized stages situations 93:10;96:17;98:21; 18:15;49:21 ;51:25; 158:1;12:14;13:15; 53:9;59:7;150:24; 98:24;106:25;107:8; 52:1; 24:25;25:5;30:5; 187:5;41:7;52:3; 108:11;110:8;115:4; specializing 34:18;45:9;49:10; 81:18;151:20;181:9; 116:25;119:25;151:18; 19:9; 60:1;68:5;81:14; 183:17;185:12;189:24; 154:3;164:12; specialties 151:12;151:16;157:23; Six Sometime 67:22;67:22; stain 67:7; 14:18;37:11; specialty 96:2; six sometimes 12:11;62:5;62:9; standards ' | | ( -| J 7'TM - 1 .1 V , ' v; secondly - standards Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 HARTOLDMONOO11047 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 32:24;33:8;43:15; standpoint 59:12; staring 142:24; started 70:19;139:20;177:8; ctartc 77:9;158:24;160:15; 172:10;68:14;85:22; 107:2;117:17;151:22; State 193:1;193:5;193:13; 194:18; stated 33:14;35:1 ;51:10; 62:20;74:23;74:24; 79:13;86:19;93:9; 146:3;159:17; statements 92:22; 159:2;169:15; 145:15;159:13;168:23; 187:14; States 12:16;29:2;38:9; 52:20;52:23 ;52:25; 53:6;53:8;64:13; 74:16;82:8;82:9; 88:6;146:17;164:2; 165:12; States" 164:9;172:16; ctatne 35:3;75:20;100:24; 101:4;116:14;135:10; 164:5;165:4;172:23; 5:13;5:15;7:17;8:4; 20:23;27:23;28:2; 45:2;134:21;136:24; 138:1;141:16;145:20; 148:11 ;159:3; stay 19:22;64:5; stearinic 12:8; steels 14:9; Steenrod 114:14;114:16;114:17; 115:4;115:9;137:8; steps 142:12;7:7;7:18; 21:22;82:13;112:20; stewardship 190:16;191:12; sticking 187:1;129:3; still 13:15;23:17;25:2; 25:5;34:17;35:22; 56:5;70:18;92:3; 92:4;97:23 ;97:23; 98:20;120:10;155:9; 155:15;157:5;158:10; 158:11;171:1;171:25; 179:1;179:21;181:11; 185:9;191:5; stipulate 183:7; Stockholm 73:15;79:12;126:20; 132:13;139:1; stood 150:9; stopped 60:9; store 96:20; Str 102:15; straight 18:3;98:23; Strand 36:2;36:3 ;36:5 ;37:2; 41:16;41:22;42:17; 44:11 ;44:13;72:14; 72:17;175:4; Strand's 40:9; strangely 81:18;120:9;120:11; 159:21; strategically 65:6; strategy 69:2;69:5; stretching 159:25; . Strictly 79:16; strictly 8:23;128:16; strike 19:21;47:12;50:24; 54:19;54:20;80:10; 87:11;91:1;95:10; 98:4;107:22;110:16; 110:16;118:12;141:17; 148:8;149:25;150:10; 150:11;164:19;177:23; stripe 20:1;21:4; stronger 26:21 ;131:20;190:15; structure 28:6;28:14;95:4; stuck 129:9; student 8:16; studies 92:2;159:7;159:12; 160:5;176:21;177:7; 180:24;; . study 71:12;91;5;113:9; 118:14;119:10;120:3; 133:22;136:8;138:14; 143:20;190:10;190:12; stuff 96:20; subject" 164:4; subjects 14:9;74:25;78:14; 82:3;89:12;91:4; 92:20;93:20;119:18; 125:8;134:8;137:1; 140:23 ;163:20; submitted 143:11; subordinates 25:11 ;25:14;26:8; 26:7; Subscribed 192:12; subscribed 123:9; subscriber 123:6; subsequently 68:20;150:11; subsidiaries 53:1,53:10; subsidiary 18:6;53:3; Substances 89:6;90:7;90:18; substances 90:4;92:20;92:25; 134:8;134:13;156:21; 181:1 ;93:19; substantial 181:12;181:21; substantive 89:25; substrate 157:11; success 59:15; suddenly 60:15; sufficient 50:4;117:20; suggested 32:24;78:11 ;118:5; suggesting 143:16;143:18;188:23; suggestions 32:10;112:11 ;112:18; 188:15; suited 171:3;194:9; sulphur 61:2; summer 104:4; superiors 11:9;22:6; supervised 24:23 ;25:11;25:14; supervising 126:20; supervision 28:8;32:9;34:13; supervisors 45:8;24:18;24:25; 25:2;25:9;26:2;27:8; 28:19;28:20;28:21; 28:23 ;28:24;33:15; 33:20;34:16;34:22; 35:17;35:21;36:7; 36:12;45:6;47:14; 48:11;48:13;48:15; 48:16;48:20;70:4; 70:11 ;70:17;70:24; 103:13;115:1;137:5; 174:6;174:9; supplied 76:20;141:4; suppliers 45:13;45:16;45:13; 45:14;93:12; supplies 81:7; supplying 18:6;166:8;58:8; 58:24;113:19;127:24; supportability 89:25; supported 109:3;160:5; supporting 9:12;160:3;160:8; 28:9;28:13;34:6; 34:6;108:7;108:9; 143:14;171:17;187:21; 189:20; Deposition of DAVID WOOD NOVEMBER 9, 1995 supposes 77:20;77:20;77:9; 84:9; suppositions 90:20;99:16;77:17; 77:18;78:4;81:22; 90:25;91:3;91:17; Sure 70:16; surely 154:15;24:6;29:6; 29:10;29:14;34:9; 41:18 ;49:4;57:21; 58:6;58:11;58:18; 70:14;71:9;71:21; 96:20;111:25;119:4; 125:14;127:14;132:11; 133:13;134:18;135:22; 138:1;138:8;141:11; 154:15;156:6;161:20; 162:21; 167:4;176:7; 183:24;189:6; surface 80:14; Surprised 131:16; surprised 131:14;131:22; surrounding 76:15;177:19;184:22; sustain 33:7; Swede 132:9; Sweden 19:19;27:21;36:1; 37:1^9:5 ;39:6;39:9; 39:13;40:10;40:17; 40:23;41:2;41:3; 41:6;41:17;42:25; 43:5;43:11;44:3; 44:7;44:8;44:14; 44:16;45:10;46:7; 71:12;71:24;72:15; 72:18;73:13 ;73:22; 73:24;76:21;81:1; 84:24;90:12;92:6; 92:8;92:16;93:21; 93:25;94:13;98:9; 104:12;105:1;105:9; 105:10;105:13;106:9; 106:14;107:6;107:18; 107:25;108:6;108:8; 108:10;112:1;114:1; 114:12;120:11 ;120:24; 137:1 ;138:16;142:4; 151:25;157:21;158:7; 158:9;158:12;166:14; 166:20;167:14;167:21; 175:5;175:18;176:21; 177:21 ;183:17;183:19; Swedish 37:25;38:6;43:18; 44:12;44:15;44:19; 45:6;45:20;46:14; 73:17;74:2;74:6; 74:12;74:15;74:19; 74:25;75:16;75:17; 75:21;78:1;78:7; 78:14;79:10;80:7; 80:8;80:11;81:16; 82:4;84:24;88:13; 89:5;89:13;89:20; 90:1;90:6;90:17; 91:5;92:12;92:20; 93:18 ;93:20;94:2; 99:3;99:19;104:16; 107:9;107:16;111:24; 113:9;118:5;118:14; 120:3;120:21;123:21; 133:22; 136:4; 136:8; 144:2; 156:3; 175:14; 182:7; sweeping 160:7;160:16; swinging 45:12;63:25; sworn 5:2;192:12;193:l9; synthesis 9:7;9:9;129:16; systems 62:16;63:10;179:15; 179:17;180:6;180:11; 180:12;181:11;182:1; 63:13;180:21;180:22; 181:19; -T- tablet 48:1; talked 75:5;81:14;105:19; 112:17;114:11;120:9; 153:13;155:7;168:24; 176:5; talking 11:25;13:9;17:1; 18:13;23:1;34:6; 42:9;77:8;78:6;81:2; 81:3;81:4;89:20; 92:9;93:14;93:24; 97:8;98:24;99:3; 104:17;105:5;105:6; 105:14;105:22;105:23; 109:7;113:20;114:3; 117:6;118:6;130:22; 131:8;131:13;137:23; 144:21;144:23;150:14; 152:25;153:22;155:10; 180:24;183:3; talLe 159:20;40:3;50:3; 50:7;52:6;52:7;54:14; 54:16;56:13;58:14; 65:7;92:12;107:5; 107:8;143:3;148:6; 176:9; tape 87:21; Tcp 125:5;125:15; 125:16; 131:8; team 65:25;115:10; technical 10:22;11:20;13:7; 13:17;14:11;19:23; 20:2;21:2;21:5;21:16; 21:16;22:12;22:13; 29:4;29:6;29:20; 76:8;80:24;82:18; 109:3;121:3;121:12; 121:23;145:9;145:16; 147:24;151:19;152:5; 155:16;164:3;168:20; technicians 136:2; techniques 147:4;159:9;150:21; technology 14:7;32:4;56:14; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 standards - technology HARTOLDMONOO11048 Deposition of DAVID WOOD NOVEMBER 9, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 122:24; 155:8; 160:3; 121:23; telephone 73:6;73:8;73:20; 73:23 ;73:25;83:13; 183:13; telling 11:5;78:13;109:10; 116:24; temperatures 32:5;32:7;32:13; 56:15;100:6;129:6; temporary 46:12; tended 19:16;43:14;61:7; 185:2; tends 97:3;42:3;95:9;123:7; Tennessee 5:9;53:13;53:16; 53:22; tenuous 82:6; termed 62:5;77:21;78:15; terminology 88:12;98:22;159:21;_..... terms 15:18;30:8;31:5; 42:23;69:2;70:23; 87:18;88:12;107:10; 120:6;121:2;140:4; 140:9;141:8;141:18; 142:4;190:18;16:18; 17:3;36:25;48:15; 60:17;77:10;87:12; 93:1 ;93:4;106:18; 106:2Q;109:5;143:23; 156:2; terphenyls 51:8; territory 13:14;13:22; testified 51:11 ;126:10;193:21; testify 5:3;193:19; testimony 77:25;86:19;192:5; 193:22;193:25; testing 187:4;187:21;187:25; 189:22;191:10; tests 151:17;189:13;187:19; 190:5;190:7; Texas 64:25; theirs 39:20; themselves 22:24;26:24;40:20; 41:20; theoretical 9:12; theorization 140:17; theorized 180:11; theory 107:20; thereafter 26:8;34:19; therefore 19:18;30:10;33:6; 42:1;42:3;48:8;64:6; 111:24;115:5;132:10; 140:5; 153:19; 166:7; 173:9; thereto 194:3; thereupon 193:21; thermally 98:17; Therminol 49:20; they'll 96:20; they've 81:25; thickeners 63:10; thinking 84:25;123:3; third 51:22;84:6;88:25; 108:16;110:18;116:4; 118:2;118:3;130:24; 141:24;163:25;164:10; thoroughly 187:6; thought--- ------ --------- 61:13 ;89:17;91:8; 127:3;143:24;151:18; 155:20;59:9; thousand 10:15; three 38:2;38:3;45:12; 49:21 ;62:22;118:10; 128:20; 130:7;130:15; 130:17;137:12;137:14; 146:11;160:9;177:3; threw 178:4; thrown 125:23; timber 94:2;94:9;94:12; 95:6;95:24;96:1; 96:3 ;96:3 ;96:5 ;96;20; 97:1;97:25;105:&; . 105:10; times 6:3;7:16;38:2;38:15; 39:2;39:4;39:9;55:20; 157:7;157:8;189:14; timetables 58:12;185:7; tiny 54:24;62:22; tissues 134:5 ;75:22; title 28:18;57:5; to-wit 5:6; today's 6:18;6:18;6:25;7:21; 8:2;69:7;83:3 ;90:24; 91:2;96:21;98:20; 124:1;182:10;190:17; toehold 39:21; together 129:4;129:9;139:23; 143:20;143:23;194:1; toing 70:22; told 73:12;74:19;75:16; 77:25;78:21;79:9; 80:10;89:1;89:4; 109:13;109:23;133:19; 134:6;134:16;134:23; 135:7;138:12;141:3; 144:1;145:8;154:16; 163:9;163:18;163:24; 164:6;164:12;164:15; 164:20;164:24;171:22; 172:12;172:17;172:19; 172:24;176:19;184:10; 184:14;184:17;184:20; 185:19;186:5;186:8; 191:10; tomorrow 176:9; took 10:22;24:24;30:7; 49:23 ;68:8;68:13; 78:9;108:14;117:8; 117:10; 188:20; top 112:14;122:9; 122:11; 144:9;153:23; Total 6:4; totally ------- -------------10:14;47:18;87:5; 110:8;110:20;128:3; 158:4;158:18;170:14; 184:3 ;26:22; totem 25:1; touch 176:11; tour 142:19; toxicity 30:1 ;30:16;31:14; 185:21; toxicological 170:16;171:19;173:4; 176:21;177:9;177:10; 177:11;177:17;177:19; 187:4;187:21;188:4; 189:12;189:22;154:11; toxicology 139:16;154:18;154:21; 177:7; trace 134:4; Trade 46:1;46:4; trademark 156:11;46:7;121:15; trading 45:25;46:14; training 11:2;11:21;11:23; 13:1;13:5;13:8;13:16; 13:18;13:19;13:20; 13:24;14:3;69:4; 121:19; Tran 115:17;122:5;124:12; 132:23 ;136:19;137:18; 152:12;161:8;162:9; 174:22;182:18; transactions 121:20; transcribed 193:23; transcript 192:2;192:5;193:22; 194:4; transfer 51:21;52:10;56:3; 61:23 ;62:3;62:19; 63:3;63:23; transformers 6:14;14:24;19:10; 19:14;43:12;43:14; 43:15 ;43:16;43:17; 59:5;59:7;59:9;15:1; 15:14;18:10;43:10; 59:3;145:1; transition 57:23 ;60:1;60:9; translated 80:6;80:11; translates 92:18; translating 84:23;93:18;98:21; translation 80:18;81:16;99:15; transportation 180:11;180:12; transported 100:3; Transwestern 6:10; traveled---- --- -------56:7; traveling 52:6;39:4;44:7;54:12; trees 80:14;187:12; tremendous 164:8; trial 68:16;193:10; trichlorobenzene 17:7; Tricresyl 125:19; tricresyl 125:20;125:24;131:8; Tried 139:11; tried 33:22;59:17;108:14; 115:9;143:9; trips 23:3;44:8;40:2;169:2; tritetrachlorobenzene 17:7; troublesome 173:13;88:11;158:9; 166:4; true 160:17;192:4; 194:3; trust 183:5;183:11; truths 185:14;5:3;5:3;5:4; 193:19;193:19;193:20; trying 7:8;32:14;39:20; 47:5 ;77:25;91:20; 98:14;120:11;121:21; 140:5;140:17;142:10; 143:19;145:19;158:3; 158:8;166:5;7:7; 7:17;7:23;12:17; 13:3;26:10;33:25; 44:3;87:20;97:10; 140:15;167:13;167:22; tune 58:12; turbine 14:10; turn 104:17; twenty 154:2; Two 62:4;62:9; two 8:10;21:11;31:6; 36:9;43:17;43:23; 44:2;44:4;45:15; 46:22;58:2;60:4; 62:22;63:1;68:25; 116:15; 129:3;129:9; 130:6;130:17;147:3; 150:21 ;158:21;159:4; 168:24;173:7;177:3; 181:1 ;189:10;190:12; typed 152:20; types 15:25;17:24;57:14; 123:17; typewriting 193:24;8:13;9:8; 9:11;11:7;12:4;12:11; 16:1;17:20;28:24; 29:12;32:14;41:7;...... -- 43:19;47:22;55:6; 55:8;59:6;61:1;64:9; 69:5 ;96:2;114:20; 123:13;140:2;147:17; 150:19;178:16;187:5; 187:15; typical 183:13; typify 38:16;121:22; typing 106:6; -TT- U.s. 53:11;115:7; ultimately. 60:8;59:4;118:22; 128:13 ;151:1;152:25; 181:14; undergraduate 9:9;147:11;155:13; understood 41:24;76:7;86:18; 89:11; undertaken 33:24;133:22;119:6; undertaking 119:10; undertook 29:20;33:20;119:11; 119:21 ;120:6; undetermined 193:9; unfortunately 160:17; United 12:16;29:2;38:9; 52:20;52:23 ;52:24; 53:5;53:8;64:12; 74:16;82:8;82:9; 146:17;164:9;165:12; 172:16; unit 179:20; universal 59:24; University Gore & Perry Reporting Co. St. Louis, Missouri technology - University (314) 241-6750 621-4790 HARTOLDMONOO11049 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 8:8;73:15; university 8:8;8:20;9:14;10:17; Unless 160:2; unless 141:14;151:17; Unlike 38:8; unloading 40:16; unprofessionally 151:13;152:6; Unquote 101:3; unquote 79:4;134:19; unrest 84:14;85:5; unsafe 110:12; unscientific 81:18; unsimilar 114:18; unsupportable 159:15; unsupported 168:11;169:14; unusable 101:2; up-to-date 123:3;153:19; update 23:4; upon 41:19;169:13; upped 24:12; upper 130:20;182:22; usable 29:7; usage 16:19; used 14:4;16:19;17:3; 17:22;31:6;31:10; 31:10;54:5;54:22; 55:3;55:6;55:9;58:11; 60:12;62:11;63:10; 63:11;63:12;63:15; 63:16;63:19;81:19; 87:9;87:12;92:25; 93:21;94:2;94:8; 94:12;94:13 ;95:18; 95:22;95:23 ;95:24; 95:25;97:6;97:12; 97:25;98:12;98:17; 99:24;100:2;100:5; 100:6;100:9;100:12; 100:18;101:21;106:18; 107:3;120:14;125:2; 125:24;140:16;142:16; 143:2;143:23;151:13; 152:1;178:14;180:6; 181:4;181:4;185:23; 186:25;193:10; useful 123:2;179:18; users 38:5;43:4;43:22; 44:2;56:25;58:14; 107:10;170:24;30:9; 43:6;45:9; uses 93:3 ;94:1; 138:13; 138:14;144:20; using 26:4;31:5;60:6;96:24; 98:22;107:13;109:7; 120:7;150:21;156:4; 159:25;166:9;180:12; 181:25; -V- vacuum 52:1; vagueness 99:14; valid" 31:10; validity 152:3;160:22;30:16; 31:5;31:16;32:21; valuable 168:13; vapors 32:7;32:12;32:19; 32:25; variable 140:3; variations 67:20;129:25; various 9:1 ;15:8;15:11;19:17; 20:23 ;32:22;107:11; 129:10;130:17;157:19; 157:20;163:5;163:21; 164:3;171:12; vendor 102:4;102:5; ventilate 32:11; venture 65:1; verbal 6:22;7:1; vermiculite 109:5;109:24;111:1; versed 42:4;154:16; version 136:20;150:15; Videographer 5:13; videotape 6:25;125:2; views 143:21 ;45:20;56:11; 135:2; viscosity 15:8;16:8;59:13; visited 124:23; visiting 50:2;138:15; ' visitors 23:2; visits 32:10;39:6;39:6; 40:7;44:3;53:2;53:2; 138:25; vitae 20:18; vital 173:1; voice 170:22; volition 190:15; volumes 181:21;187:18;64:9; 64:12;181:12; -w- waived 194:6; Wales 46:24;47:3;47:7; 136:12; walking 83:3; wants 145:16; warehousing 40:18; waste ' 109:19;110:7;110:19; 110:25;111:9; wax 14:7; way 29:15;33:11 ;41:20; 52:15;78:10;87:18; 91:20;99:22;109:2; 120:16;124:18;127:16; 139:1 ;144:18;145:12; 158:7;159:4;163:17; 168:2;184:4;191:1; Week 121:14; WApItC 70:20;83:18;184:18; weight 129:22;130:4; welcome 87:8; well" 116:8; wellheads 54:7; wend 91:20; Wenner-gren 79:11;79:15;152:22; weren't 44:5;120:16;122:22; 144:23;100:17;168:3; Westinghouse 18:6;18:7; what's 20:9;42:4;71:25; 113:22; Whereas 28:20; whereas 46:4;59:23; whichever 154:22; whole 5:3 ;39:15;40:20; 131:11 ;193:19; Whose 82:1; whose 81:17;126:21;133:13; widely 94:10;43:9;95:6; Widmark 124:22; 126:4;126:13; 126:17;126:18;126:24; 127:1;127:2;127:4; 127:7;128:9;129:10; 131:23;132:5;132:8; 138:19;160:18;184:22; wife 67:7; Deposition of DAVID WOOD NOVEMBER 9, 1995 Wilde 162:17;163:2;163:3; 185:24;186:4; wildlife 71:13; willing 185:11; winding 32:5; wished 170:20,7:17; 131:19; witch 185:6; Within 133:17; within 9:20;11:11;12:19; 17:16;24:13;28:11; 29:7;30:13;60:23; 80:23;82:21; 118:12; 119:11;120:19; 121:3; 130:4;130:15;131:11; 167:16;171:13;174:13; 184:18; without 18:3 ;49:6;148:12; 167:12; Witness 192:1; 194:12; witness's 150:1;31:1;97:16; 167:6;178:9;193:14; 193:17;194:1;194:5; wonderful 183:20; Wood 5:1;5:12;5:14;5:15; 5:17;5:18;5:25;20:9; 20:13;47:12;68:19; 68:22;68:23;70:3; 71:25;72:4;96:19; 102:13;115:14;122:3; 124:10;132:21 ;133:6; 136:17;136:22;152:10; 154:3 ;161:6;162:7; 162:16;174:20;175:5; 176:5;182:16;192:1; 192:10; wood 96:6;96:21;96:25; wooly 114:1; words 7:8;7:18;31:6;73:3; 15:18;26:4;61:9; 107:3;120:18;154:11; 178:13;185:23; worked 10:9;32:22;41:10; 54:20;120:16;125:13; 131:2; Workers 144:2;144:19;144:25; working 9:19;10:4;10:10; 10:19;10:21 ;18:24; 26:19;27:23;33:1; 33:8;44:16;133:20; 133:24;160:21;162:19; 172:4; workplace 32:24;9:8;9:11;9:20; 11:7;32:11 ;33:5; 33:7;53:25;54:19; 54:21 ;55:2;56:15; 68:14;68:18;73:23; 89:25;96:25;104:25; 115:9; 119:14; 120:21; 121:6; 126:21; 127:22; 127:25;128:6;128:20; 133:21; 134:9; 134:11; 135:1; 135:2; 135:12; 136:3 ;136:7; 139:14; 139:21; 139:23; 139:25; 142:17;143:8;143:14; 143:17; 143:24; 147:12; 150:2; 150:5;150:8; 150:10;151:13; 151:15; 152:3;157:13;159:25; 160:5; 168:13;168:17; 169:12;169:13;169:19; 171:11;174:13; 177:5; 177:9; 177:10; 177:11; 177:13;177:15;177:17; 177:19;182:8;185:11; 185:15; 187:9; 187:15; 187:19;190:5; world's 47:24;156:13; world-wide 54:3;58:20;82:17; 30:6;48:3 ;49:19; 54:10;57:13;63:21; 69:8;93:2;171:11; worried 164:1; worry 178:15; worse 107:19; worth 66:3 ;78:9; write 38:1;38:2;38:24; 83:11,113:3; writing 36:9;78:7;103:1; 106:6; written 72:15;105:21;133:3; wrong 91:8;91:9; wrote 83:10;83:12;83:16; 84:12;87:24;89:9; 89:10;89:11;102:20; 102:23;102:24;104:9; 108:16;109:13;116:5; 127:14;141:1;142:6; 146:6;172:17; -Y- y-i 76:24;78:15; years 38:10;45:18;45:19; 49:5;57:2;67:7;96:11; 96:15;127:16;128:20; 131:5;133:21;133:25; 138:9;158:19;179:19; 189:13;190:7;190:8; 190:12; 190:16;10:16; 10:20;28:6;28:6; 38:15;39:4;39:10; 39:14;40:2;58:2; 66:2;68:13;71:8; 71:16;154:3;176:16; 190:10;190:12; York 135:20;135:22; young 155:12;159:24; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 University - young HARTOLDMONOO11050 Deposition of DAVID WOOD NOVEMBER 9, 1995 -z- zero 181:20; TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY .......................... - ---... ............. -.......---- ---------:... young - zero Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 , HARTOLDMONOO11051