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Page 208 1 an amazingly strong data set for an occupational cohort 2 for which we can infer disease causation. 3 It is true there are some things that would be 4 ideal, for instance perhaps this cohort's more exposed 5 than Mr. Mallia was, Mallia, and therefore we're 6 talking about exposures that are much greater than what 7 he experienced because he isn't involved in beveling 8 and he's working much later in history than these 9 people. 10 So all I can tell you for purposes of this 11 case, these people were probably exposed I would expect 12 much more than he was in spite of the work practices 13 that he described. 14 Q But you have no factual basis for that 15 statement other than -- 16 A Other than I studied all the published 17 information on the issue which is, seems to be a pretty 18 good basis for my view. 19 Q There is no published information regarding 20 work practices of mechanics contemporaneously published 21 in the 50s, is there? 22 A No. 23 Q Andthe 1960s other than the Hickish study? 24 A No. All you can do is base it on experience 25 through interviews. ESQUIRE DEPOSITION SERVICES (415) 288-4280