Document bOEN8GBKox2x0KMR6Y0BV8MvO

138 1 Sayers 2 say, "Action taken by Union Carbide U.K.. personnel 3 is recorded" in your paper; right? 4 A. Yes. 5 Q. You say, "Up to date information is 6 presented," don't you? 7 A. 1 do. 8 Q. You say, "its implications are 9 discussed," aren't you? 10 A. Yes. 11 Q. Well, sir, you understand you are 12 writing this paper because people were concerned 13 about your asbestos product? 14 A. Yes. 15 Q. You didn't have all the up-to-date 16 information in here, did you? 17 A. So it would seem. 18 Q. You didn't have all the Union Carbide 19 information in here, did you? 20 A. There was more Union Carbide information 21 which didn't go in it. 22 Q. Did that make you wonder why they had 23 you, a 28-year-old kid, write this paper instead of 24 the medical director himself, who actually had 25 access to all this information? 140 1 Sayers 2 Q. You prepared this paper because you 3 wanted answers to questions, didn't you? 4 A. Yes, 1 did so. 5 Q. And in all the answers they sent you 6 back, they didn't send you the study that showed 7 your asbestos more dangerous than the others, did 8 they? 9 A. I didn't see a copy ofthat, no. 10 Q. And in fact, the letter that Mr. Hall II showed you a copy of wasn't even sent to you that 12 talked about it; right? 13 A. That is true. 14 Q. So those answers didn't get to you, did 15 they? 16 A. Some of it clearly did, by dint of that 17 letter, and Tom Hall was also visiting New York on 18 occasions. So he passed on some information to me. 19 naturally. 20 Q. Sir, before they let you and your wife 21 stuff a bunch ofasbestos into baggies, they never 22 told you that asbestos was more dangerous than the 23 other kinds ofchrysolile they tested; is that 24 right? 25 MR. WILL: Objection to the form, 139 1 Sayers 2 MR. WILL: Objection to the form of the 3 question, assumes a fact not in evidence. 4 A. I think you misunderstand the reasons 5 for the assembly ofthe document. 1 was meeting 6 logjams at some customers, and 1 wanted some 7 guidance and assistance. So 1 assembled the 8 external information that was available. 9 MR. LANIER: This gentleman's got to pop 10 a tape out. It will just take one second. 11 THE VIDEOGRAPHER: The time is 12:28 12 p.m., August 2nd, 2002. This tape number 13 one of the videotaped deposition of Mr. Ian 14 Sayers. 15 (Pause.) 16 THE VIDEOGRAPHER: The time is 12:29 17 p.m., August 2nd, 2002. This is tape number 18 two of the videotaped deposition of Mr. Ian 19 Sayers. 20 Q. Sir, before we changed tapes, you had 21 just answered a question and you told me the reason 22 you prepared this paper was because of you were 23 meeting logjams as you tried to market your 24 asbestos; is that right? 25 A. Yes. 141 1 Sayers 2 misstates testimony. 3 A. We haven't gotten that knowledge, no. 4 Q. You didn't have that knowledge really in 5 your mind until I told you today, 2002; isn't that 6 right? 7 A. As regards the report, no. 8 Q. No, 1 am correct; right? In other 9 words -- 10 A. Yes. 11 Q. Let's look at a little bit more of your 12 report. If you'll turn with me to page 4 where 13 it's got the introduction. 14 A. Yes. 15 Q. It looks to me like your third -- well. 16 as I read the introduction, 1 get the impression 17 you're trying to get some additional guidance from 18 Union Carbide. 19 A. Yes. 1 stated that already. 20 Q. You're saying here in this that over 20 21 potential customers have raised this issue, and 22 they want an assurance that Carbide's material will 23 not be a source of danger; right? 24 A. Yes. 25 Q. If Carbide can give (hat assurance, then SPHERION DEPOSITION SERVICES /*> I *> \ lOA *5 I *5 A 36 (Pages 138 to 141)