Document ev0dKzo1EbRX3JdQ00M8dKwjy

42 1 Sayers 2 Q. In what year? J A. 1967. 1 photo well. 4 Q. Would you hold that up, please, for the 5 camera? 6 A. (Complies.) 7 MR. LANIER: It looks a little bit by 8 Austin Powers. 9 MR. WILL: Counsel, I would ask that 10 you please keep those comments to yourself. II I don't think you'd do that in front of a 12 judge, and 1 don't think you'd do that in 13 front of a jury. 14 MR. LANIER: That was a joke that 15 would be cut out. And actually I would do 16 it in front of a judge and a jury. 17 Q. That's a depiction of you when you 18 wrote the report? 19 A. Yes, it was. 20 Q. Who typed up the report? 21 A. A young lady called Iris Kent, who was a 22 secretary to Peter Cheston and myself at the time. 23 Q. Did you decide, then, to whom to 24 distribute the report? 25 A. Peter Cheston issued a covering letter. 44 1 Sayers 2 work with the Pneumoconiosis Research Unit, and the 3 proposition was made in that report. 4 And thirdly, it was really an 5 explanation as to why in the U.K. we haven't 6 penetrated the market properly as much as had 7 initially been anticipated. 8 Q. Your sales hadn't been as great? 9 A. That's right. 10 MR. LANIER: Objection to form. II Q. You mentioned that one of your 12 objectives was to get Dr. Demehl to give some 13 advice about this. What did you hope to do or 14 expect to do with any advice Dr. Demehl gave you? 15 A. Well, certainly pass it back to 16 customers and prospective customers. 17 Q. Let's take a look at the report now at 18 page 6, paragraph 2.4. That's titled dockers; 19 correct? 20 A. Yes. 21 Q. And you had previously mentioned the 22 dockers as a group of workers who were aware of 23 this asbestos situation? 24 A. Yes. 25 Q. You state in your document that "Until 43 1 Sayers 2 and he decided upon the copy list. 3 0- As you remember it to whom was your 4 memorandum sent? 5 A. As far as 1 can remember. Hal Reichard. 6 Bob Woolery up in Niagara. Bud Pufahl in New York. 7 obviously Dr. Demehl. and Tom Frangos. who was our 8 link man in the New York office. 9 Q. Who was Tom Hall? 10 A. Tom Hall was my future boss when I got II to Belgium. 12 Q. Do you remember, did he get a copy of 13 the report? 14 A. He did. That's right. 15 Q. Mr. Sayers, what did you hope to 16 accomplish by writing this report? 17 A. Well, really there were three 18 objectives. We had accumulated some new 19 information which we thought was worthwhile putting 20 down into a report. Really the aim with that was 21 to try and put it before Dr. Demehl to seek some 22 guidance really on the basis of the '64 toxicology 23 report. 24 The second objective was. as you will be 25 aware, there w as a recommendation in the report to 45 1 Sayers 2 the last few months, asbestos was imported into the 3 U.K. in hessian bags." 4 Is that what you say? 5 A. That's right. 6 Q. What is a hessian bag? 7 A. 1 think the word "jute" is equally 8 applicable. It is a jute natural fiber. It is 9 spun and woven into a fabric from which bags were 10 made. 11 Q. Is that what in the U.S. we call a 12 burlap bag? 13 A. 1 believe it is. 14 Q. Did Union Carbide asbestos ever come in 15 hessian bags? 16 A. Never. 17 Q. How was it packed? 18 A. It always arrived in kraft sacks, kraft 19 paper sacks. 20 0- To your information did the dockers ever 21 refuse to handle a shipment of Union Carbide 22 asbestos? 23 A. No, they didn't. 24 Q. So this refusal had to do with other 25 types? SPHERION DEPOSITION SERVICES (212)490-3430 12 (Pages 42 to 45)