Document bBa8VqvjDGR00rMQzzr2Jj4x0

126 1 Sayers 2 Union Carbide's asbestos was all curved, didn't 3 you? 4 A. Not all curved. There were curved 5 fibers contained therein. 6 Q. And you knew there were straight fibers? 7 A. Oh, yes. 8 Q. So when you told thisjury that you were 9 reassured and you didn't think Union Carbide was as 10 dangerous because it had curved fibers that II wouldn't flow so well through the system, did you 12 fail to tell the whole truth and tell them about 13 the straight fibers? 14 MR. WILL: Objection to form. He never 15 testified to that, that he felt reassured. 16 A. 1 knew the chrysotile asbestos that 17 Dr. Timbrell was talking about was not curving 18 asbestos. 19 Q. Did you go tell all of the people buying 20 your asbestos that you didn't have the safe curved 21 kind in your opinion, y'all had this spear kind. 22 straight kind? 23 A. 1 don't think that really entered into 24 the discussion in those days. 25 Q. Did you put a call report in that says. 128 1 Sayers 2 MR. WILL: Objection to form, assumes a 3 fact not in evidence. 4 A. No. 5 Q. When Union Carbide asked you to do this 6 Exhibit Number 1, you were supposed to review the 7 literature, weren't you? 8 MR. WILL: Objection to the form of the 9 question, assumes a fact not in evidence. 10 A. It was an assembly of the cogent II literature that 1 could find at the time. 12 Q. Well, sir, did Union Carbide ever 13 provide you with this confidential report from the 14 Mellon Institute? 15 MR. WILL: Asked and answered. 16 objection. 17 A. 1 don't think that's relevant to the 18 report itself. 1 was compiling information that 19 was available in the public domain. 20 Q. Sir, did you know that this report 21 tested Union Carbide's asbestos and compared it to 22 other chrysotile asbestoses? 23 A. No, 1 did not. 24 Q. Did you know about this report that 25 showed Union Carbide's to cause more significant 127 1 Sayers 2 hey, it looks like the curved kind may not be as 3 dangerous as our straight kind? 4 A. 1 can't remember the content of the call 5 report. 1 would think it was unlikely. 6 Q. Well, sir, don't you think you owed your 7 customers the truth? 8 A. That's what 1 was seeking for. 9 Q. Don't you think you should have told 10 your customers that y'all think this straight kind II that y'all are showing pictures of is more 12 dangerous than the other kinds they could be 13 buying? 14 A. The geometry at the time that 1 was 15 involved with the asbestos really never came up 16 with regards to Calidria. 17 Q. I'm going to show you a document that's 18 marked PW 462. It's a Mellon Institute special 19 report. 20 Have you ever seen that before, sir? 21 A. No, 1 haven't. 22 Q. When Union Carbide asked you to do a 23 review of the literature, did they give you their 24 own literature that's shown there in that exhibit. 25 PW 462? 129 1 Sayers 2 problems than the other types of chrysotile 3 asbestos? 4 A. No, I did not. 5 Q. You asked me before was l sure of the 6 date of that report. 7 Sir, what is the date on that report in 8 the top right-hand comer? 9 A. It seems to be the 8th of July'66. 10 Q. Is that before or after your report? II A. After. 12 Q. Excuse me, sir, what time was your 13 report? 14 A. Sorry. Was that '66? 15 Q. Yes, sir. 16 A. That was before. 17 Q. So Union Carbide had test results 18 showing Calidria to be more dangerous almost a year 19 before you did your report; isn't that true? 20 MR. WILL: Object to the form of the 21 question. 22 A. It would appear so, yes. 23 Q. And Union Carbide never told you that. 24 did they? 25 A. Not to the best of my recollection. SPHERION DEPOSITION SERVICES (212)490-3430 33 (Pages 126 to 129)