Document baKNN96njv6bwrzxdEv7Zn2ak

T. Marmor Page 101. Page 103 1 other people's writings? 2 A. In discussions. I'm the editor 3 of the volume. So, again, these are-country . 4 reports on what is going on-in each country 5 each year. 6 Q. Is the boilermaker report 7 published?. 8 A. No, it has justaffected the way 9 I wrote about that book. Learning about . 10 that -- let me.put it this way. I've just:.- 11 finished another book, a.little book called 12 Fads in Fashionin Iiealthcare Policy and 13 Management. One of the chapters of that book 14 is the growth ofa movement for health 15 promotion in which l talk about the new 16 prospective on health and that, ofcourse;. 17 brought back all of the disputes in the 4970s - 18 when this movement started. 19 So, other than that, the 20 concentration on asbestos; of course, was in 21 connection' with Celotex- and in connection with 22 the boilermaker's report, and in connection 23 with the research I did to produce-this. . 24 document.- 25 Q. . This document again being M-armor- 1 research and that started in May of 2002? 2 A. Right. 3 Q. And continues until today, which 4 is April of 2003? 5 A. Yes. 6 Q. Tell me what you've done since 7 then during this third-leg-of your 8 concentration. , 9 A. Well, in this case, what I had to 10 do, and for reasons I'll explain in just a 11 second, I had to expand my capacity to do 12 research because I'm limited by Yale's rules in 13 the number of days'a week that I can do any 14 outside work at all. -So, I put together a 15 research team made up of my former post-docs 16 and former associates to spend ah enormous17 amount of time scouring the literature publicly 18 available on-asbestos and its-harms; asbestos 19 and its benefits for various groups. That 20 group has work steadily since May: 21 I'm limited to one day a- week, so 22 that they do the scouring under itty direction. 23 and we discuss each of those categories of 24 publicly available information,-how-you go 25 about getting it, what sort- Of exhibit would be Page 102; 1 Exhibits -- - 2 MS. ROSENBERG: Binder. 3 Q. Binder.'When-did y<ou do that 4 research? 5 A. That research got done between 6 May of last-year and now. 7 Q. Let me back up for a moment How- 8 much were you paid .for your research in the 9 boilermaker case?" . . ', ' > ; 10 A. I think it was sOmfethlng like:' - 11 $400 an hour, between 350 and.400.- I need to 12 lOOk-It-Up. . ' , - 13 Q:- ' What was the total? 14 A.. -T think it.Was close to the total 15 for the McCracken case, about $40,000.. 16 Q. That was for the second leg of. 17 your-concentration? 18 A. Right. 19 Q. Lei's talk about the third leg of 20 your concentration, now -- don't let me 21 mischaracterize - but would it be; the third 22 leg of your concentration, be the research that 23 you've done for the Union Carbide Company?. 24 A. Yes, absolutely. 25 Q. That is the third leg of your Page 104 1 a fair representation of what was publfcly 2 available when there was many, many 3 illustrations of it. 4 You want me to describe the parts 5 to it? 6 Q. Sure. Feel free. 7 A. We broke it up .in to four8 different categories; one is what literature 9 was publicly available in the medical and 10 scientific communities going back to the : 11 earlier part of the century and particularly 12 the 1920s. 13 The second group of available 14 literature that we want to look at was what was 15 known about asbestos in the public health 16 community that became prominent in 1930s. 17 The third group is when and what 18 was available in the literature of unions about 19 asbestos and its dangers and benefits, and the 20 fourth what about general government, not just 21 public health, and finally, if you widen the 22 net to the general media, what was available 23 where that could have reached wide publics and 24 be thought to be in a defensible sense publicly 25 available or not. 26 (Pages 101 to 104) POHLMAN REPORTING COMPANY (314)421-0099