Document gK0ddaVrKEo3NL9nR44b0yy3

IN THE CIRCUIT COURT OF THE CITY OF ST. STATE OF MISSOURI Judith Bechtold, wife of/and Stephen E. Bechtold, Elizabeth Tamewitz, as Personal Representative of her deceased husband, Kenneth F. Tamewitz, Kellie Lee Trisler, as Personal Cause No. Representative of her deceased mother, Mina Trisler, Phyllis Goodman, as Personal Representative of her deceased husband, Charles Goodman, Jr., LOUIS 922 00911 Monsanto Company and Westinghouse Electric Corporation. DE POSITION OF DR. GEOR&E ROUSH, JR. T aken on behalf of the Plaintiffs June 15, 1994 WALLER REPORTING, INC. 515 Olive Street, Suite 1506 St. Louis, MO 63101 (314) 621 2571 WALLER REPORTING, INC. IN THE CIRCUIT COURT OF THE CITY OF ST. STATE OF MISSOURI Judith Becht old, wife of/and Stephen E. B echtold, Elizabeth Tamewitz, as Personal Representati ve of her deceased husband, Ken neth F. Tamewitz, Kellie Lee T risler, as Personal Cause No. Representati ve of her deceased mother, Mina Trisler, Phyllis Goodman, as Personal Representati ve of her deceased husband, Cha rles Goodman, Jr., LOUIS 922 00911 Monsanto Company and Westinghouse Electric Corporation. DEPOSITION OF DR. GEORGE ROUSH, JR., produced, sworn, and examined on behalf of the Plaintiffs on June 15, 1994, between the hours of nine o'clock in the forenoon and five o'clock in the afternoon of that day, at the offices of Husch & Eppenberger, 100 North Broadway, St. Louis, Missouri 63101, before KATHLEEN A. WANN, a Registered Professional Reporter and a Notary Public within and for the State of Missouri. APPEARANCES The Plaintiffs were represented by Mr. C. Joseph Murray of the Murray Law Firm, 909 Poydras Street, Suite 2550, New Orleans, LA 70112. The Defendant, Monsanto, was represented by Ms. Carol Rutter of the law firm of Husch & Eppenberger, 100 N. Broadway, St. Louis, MO 63102. The Defendant, Westinghouse, was represented by Mr. Thomas P. Berra, Jr. of the law firm of Lewis, Rice Fingersh, 8182 Maryland Avenue, Suite 400, Clayton, MO 63105 3786. WALLER REPORTING, INC. QUESTIONS BY: Mr. Murray ... Ms. Rutter ... INDEX OF EXAMINATIONS LINE . 4 13 50 15 1 Roush, George M.D fmr Mons Medical Director in BECHTOLD HARTOLDMON0009835 IT IS HEREBY STIPULATED AND AGREED by and between counsel for the plaintiffs and counsel for the defendants, that this deposition may be taken in shorthand by KATHLEEN A. WANN, a Registered Professional Reporter and Notary Public, and afterwards transcribed into typewriting, and the deposition of the witness is to be read and signed by the witness by agreement of Counsel and consent of the witness. o0o DR. GEORGE ROUSH, JR., of lawful age, being produced, sworn, and examined on the part of the Plaintiffs, deposes and says: DIRECT EXAMINATION QUESTIONS BY MR. MURRAY: Q. Good morning, Dr. Roush. We met earlier. My name is Joe Murray, and I represent the plaintiffs in this action. You've given depositions before; correct? A. Yes. Q. I have in my possession a June 11th, 1987 deposition that you gave in the Cecil Scott case, which was a case filed down in Texas. Do you remember that deposition? A. I remember it, but I don't remember Q. Sure. I don't expect you to remember everything that was said. But the point I'm making is 2 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9836 1 that I'm not going to I'm going to try not to repeat 2 the things that were discussed in this deposition. But 3 if I do, if there are some questions that I ask that may 4 sound repetitive from that, please excuse me. 5 As you know, Dr. Roush, this lady is taking 6 down everything that's said, so it's necessary for you 7 to answer verbally to all of my questions rather than 8 nodding your head one way or the other. 9 A. Yes, sir. 10 Q. Let me first ask you, Dr. Roush, are you 11 still employed by Monsanto? 12 A. No. 13 Q. When did you leave their employ? 14 A. Eighty eight ('88) . 15 Q. What was your position when you left? 16 A. Medical director. 17 Q. And did you retire or did you go to 18 somewhere else? 19 A. I retired. 20 Q. And you haven't been employed since that 21 time? 22 A. Only as a consultant. 23 Q. And by whom have you been employed as a 24 consultant? 25 A. Primarily by Monsanto. 3 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9837 1 Q. In what kinds of cases have you been 2 employed as a consultant by Monsanto? 3 A. Related to either toxicological studies or 4 related to the health of some worker. 5 Q. All right. Were there any particular 6 chemicals that you were dealing with in those instances? 7 A. No. 8 Q. All right. Let me ask you this. Have you 9 ever testified for Monday or have you ever been 10 employed as a consultant by Monsanto with regard to 11 PCBs ? 12 A. Yes. 13 Q. And what case was that? 14 A. Well, there have been a number of cases. 15 Q. Okay. All right. And what issue was it 16 that you were helping Monsanto with in those cases? 17 A. That's a general question. Maybe you can 18 narrow it down and I can talk about something narrow. 19 Q. Were you consulted in your capacity as a 20 medical expert in those cases? 21 A. No, I was representing Monsanto. 22 Q. So it would have been on occasion where you 23 were mainly a factual witness? 24 A. Yes. 25 Q. And to your recollection you've never been 4 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9838 1 employed by them as an expert to talk about a specific 2 medical issue or something like that? 3 A. No. 4 MS. RUTTER: I would object to the form of 5 the question in that he's not a lawyer. I think you're 6 asking for a legal conclusion. 7 Q. (By Mr. Murray) Do you know what it means, 8 Dr. Roush, to be used as an expert in a legal case? 9 A. No. 10 Q. Okay. When you did your consulting work 11 for Monsanto, were you asked to express opinions 12 regarding the toxicity or adverse human health effects 13 related to PCB exposure? 14 A. That's a complicatedquestion. Could you 15 ask it again? 16 Q. I didn't mean it to be. I'm sorry. When 17 you were employed by Monsanto as a consultant 18 A. As consultant. 19 Q. were you ever asked to express an 20 opinion with regard to the toxicological effects related 21 to PCB exposure? 22 MS. RUTTER: Object to the vague form of 23 the question. Asked by whom, or do you you don't 24 by anyone? 25 Q. (By Mr. Murray) Includingby Monsanto, 5 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9839 1 yeah. I'm asking about what Monsanto asked you to do. 2 A. Usually it was related to a continuing 3 problem related to PCBs. 4 Q. That doesn't quite answer my question, but 5 I think it's my fault and not yours. 6 There are times when you testified either 7 in deposition or in court for Monsanto? 8 A. Yes. 9 Q. All right. Have you evertestified in 10 court for Monsanto? 11 A. No. 12 Q. All of your testimony at least thus far has 13 been in deposition form; correct? 14 A. Yes. 15 Q. All right. Inthose depositions were you 16 ever asked to express opinions regarding the 17 toxicological effects of PCB exposure? And let me limit 18 that to toxicological effects in humans. 19 MS. RUTTER: Object to the vague form of 20 the question. Are you asking him now if the lawyer 21 taking the deposition, regardless of whether that was a 22 plaintiff's lawyer 23 MR. MURRAY: Yes. 24 MS. RUTTER: or Monsanto? Okay. 25 Q. (By Mr. Murray) Yes, in a deposition have 6 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMON0009840 1 you ever been asked that regarding your opinion on that? 2 A. I probably I think so, yes. 3 Q. This is a tough thing. Let me ask you 4 this. How many times have you testified in a 5 deposition? 6 A. A number of times. 7 Q. How many times? 8 A. I don't know. I don't remember. 9 Q. Can you give me aroughestimate? 10 A. Maybe 15. 11 Q. Okay. 12 A. That's just a guess. 13 Q. How many times have you testified since 14 1987 in a deposition? 15 A. For Monsanto? 16 Q. Yes. 17 A. Less than five. 18 Q. Do you remember the names of those cases? 19 A. No. 20 Q. Do you remember any of those cases? 21 A. No. 22 Q. You don't remember one of them? Answer out 23 loud, please. 24 A. No. 25 Q. Do you knowwhether or notthose cases 7 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9841 1 related to alleged adverse health effects related to 2 PCBs exposure? 3 A. Yes . 4 Q. All of them? 5 A. I think so. 6 Q. Okay. On those five occasions do you 7 remember the name of the lawyer that was representing 8 Monsanto? 9 A. No. 10 Q. Do you remember the name of the lawyer that 11 was representings Monsanto in any of those cases? 12 A. No. 13 Q. Do you remember the name of the lawyer on 14 the other side who was questioning you? 15 A. No. 16 Q. How long ago was the last time you 17 testified? 18 A. I would say '88 again. 19 Q. Okay. So it's been roughly six years since 20 the last time you've given a deposition in a PCB case? 21 A. I think so. 22 Q. Okay. As I understand it, Dr. Roush, you 23 graduated from medical school in 1951; correct? 24 A. Yes . 25 Q. Tell me what you did after medical school. 8 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9842 1 A. Internship at Marquette in Milwaukee. 2 Q. All right. 3 A. One year. Then to the University of 4 Pittsburgh, master's of public health, occupational 5 medicine, research in metabolism of the heart, so that 6 takes it up to '54 I think. 7 Q. Let's stop right there for a minute. Tell 8 me about the field of public health. What does that 9 entail? 10 A. It can be either way. It can be either 11 working with individuals or it can be working with 12 health related problems, so most of public health is 13 related to a population rather than to one person. 14 Q. Okay. And does that field include adverse 15 health effects to humans relating from exposure to toxic 16 chemicals? 17 A. It can. 18 Q. And your master's was in public health and 19 occupational medicine? 20 A. Yes. 21 Q. Tell me about occupational medicine. What 22 is that field? 23 A. It's a means of looking at workers in a 24 plant or somehow within the industry, and we can either 25 get them to tell us about a problem, we take those, or 9 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9843 1 else we go out and look for the problems ourselves. So 2 it can be either them coming to us or we get them 3 outside. And once we do that, if we are interested in 4 that subject, then we look at that subject in some 5 depth. 6 Q. Okay. So if I understand you correctly, 7 somebody from XYZ manufacturing plant might come to you 8 as a specialist in occupational health and say, We have 9 this problem with the workers in our plant. Could you 10 come in and check it out for us? 11 A. Yes. 12 Q. Okay. And the other way that you might 13 become involved in a situation is if you just had an 14 academic interest in it and then you go out looking for 15 plants that might have a problem that related to your 16 academic interest? 17 A. Right. It's one that we think would be out 18 there already. We won't go out and look for it if we 19 don't think it's there. 20 Q. Okay. All right. And you received that 21 degree in '54? 22 A. Fifty four ('54) . 23 Q. All right. Were you familiar, Dr. Roush, 24 back in that time period, when you were receiving your 25 training in public health and occupational medicine, 10 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9844 1 were you familiar with the types of studies that were 2 being conducted with regard to the toxicity of various 3 industrial chemicals? 4 A. Yes. We would somehow that man could 5 come to the school of public health, or else we could be 6 interested in it, and that can be the subject of a 7 presentation to the medical students' learning process, 8 working within the medical process itself, or else what 9 was so typical back at that time was worrying about coal 10 miners. 11 And so when do you have to take the man out 12 of the plant in order to keep them from developing lung 13 disease? Or what are we going to do that will protect 14 him so when he goes into his job that he won't have lung 15 disease? And it can happen with other diseases and 16 problems, but it's not a continuing one like you would 17 have with miners. There's a continuing versus 18 short term interest. 19 Q. Okay. Were you doing a lot of work back in 20 that time period with regard to coal miners? 21 A. No, but they were being brought in, and 22 industrial hygienists, as another way of looking at 23 medical problems. And so you go out and take a sample 24 of the air. And so an industrial hygienist was trying 25 to get a handle on this not medical; I mean And so 11 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9845 1 if it was a medical problem, then we would send it to 2 some other university that was doing that particular 3 study. 4 Q. During your course work leading to your 5 master's degree or even leading to your medical degree, 6 were you taught the procedures to be used in testing for 7 toxicological effects of various chemicals? 8 A. Yes. 9 Q. And when we talk about toxicological 10 effects, we really have to break that down, do we not, 11 into acute effects and chronic effects? 12 A. Yes, sir. 13 Q. Okay. That was true even back in the early 14 '50s; right? 15 A. Right, but the question is degree. 16 Q. But certainly a chronic effect of exposure 17 to a chemical was recognized even way back then? 18 A. Right, but I'm the only one that does the 19 acute. 20 Q. I'm sorry. 21 A. I'm the only one that does the acute, 22 because it depends on how long it is and how big the 23 problem is. 24 Q. There were people in the field however 25 during that time period doing chronic studies though; 12 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9846 1 were there not? 2 A. Yes, but most of them were not chronic. 3 Most of them were acute. Even today. It depends on 4 Q. Sure. 5 A. Lots of them are 6 Q. That's normally where you start to 7 determine the toxic effects with anything is an acute 8 study; correct? 9 A. Yes. 10 Q. If there's noacute study, there's not much 11 sense in going on to the chronic study 12 A. Well, that's a big decision, because it 13 takes a prolonged exposure in order to produce that 14 effect like coal miners though. 15 Q. Correct. And that was recognized way back 16 in the '50s also; is that correct? 17 A. Correct. 18 Q. Okay. How werepeople testing for chronic 19 results back in the '50s? 20 A. Use the same tools as is done in clinical 21 medicine. We don't reinvent the stethoscope to look for 22 lung disease related from being in the coal mines and 23 comparing that to the effect on the heart that produces 24 the same kind of pulmonary sounds. 25 So the tools for looking at a man with 13 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9847 1 occupational disease is X ray, stethoscope, blood tests. 2 What we add is silica from the coal mine or exposure to 3 a gas found in the plant. And so we take those tests 4 that I was taught and apply it. 5 Q. Okay. So what you're saying is that you as 6 an occupational medicine specialist would see somebody 7 who already had been chronically exposed 8 A. Yes. 9 Q. and take that individual, and then run 10 your various medical tests to determine the extent of 11 any illness that he suffered from that exposure? 12 A. Yes. 13 Q. Okay. Were there also animal studies being 14 run during that period of time? 15 A. Some. 16 Q. Okay. And those animal studies were both 17 acute and chronic? 18 A. Yes, but chronic was so expensive and they 19 took so much there were not as many done as now. 20 Q. I see. But they certainly were being done 21 back then? 22 A. Yes. 23 Q. And during that period of timewas there 24 some type of definition used or a standard used to 25 determine whether a study was going to be was an 14 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9848 1 acute study or a chronic study? And I'm talking about 2 with regard to length of time on the study. 3 MS. RUTTER: By that period of time, 4 Mr. Murray, could you clarify? 5 Q. (By Mr. Murray) I'm still talking about 6 the early '50s, when you were leading up to your 7 degree in public health. 8 A. Ask the question again, please. 9 Q. Yeah. I'm talking about in terms of the 10 we know that there's acute studies that you can run on a 11 various on a certain type of chemical and there are 12 chronic studies that you can run. 13 A. Yes. 14 Q. And mostly those studies would differ both 15 in dosage, the amount of chemical being that the 16 animal would be exposed to, but also in length of time; 17 correct? 18 A. Yes, that's another way of getting to the 19 same dose. 20 Q. Right, okay. 21 A. The dose is also related to particle size, 22 whether it gets in the lungs at all. 23 Q. Okay. 24 A. If it's small it may. If it's big they may 25 just cough it back up. 15 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9849 1 Q. So what I'm trying to get at is, was there 2 some kind of a standard that was used in the field to 3 determine whether a study was an acute study or a 4 chronic study with regard to the length of time that 5 that study was being run? 6 MS. RUTTER: In the early 1950s? 7 Q. (By Mr. Murray) Yes, we're still until 8 I tell you otherwise, that's the time period we're 9 talking about. 10 A. Most studies back at that time were studies 11 on man acutely, because that is something the physician 12 can do by himself and doesn't need that industrial 13 hygienist to help him remove that 14 Q. I understand that, but we've already 15 established there were studies being done on animals 16 during that time period. And there were both acute and 17 some chronic studies on animal and man during that 18 period of time. And what I'm trying to understand is 19 how you differentiated during that period of time. What 20 was a chronic study and what was an acute study? 21 A. We have a history. Somebody tells us what 22 to look for, study someone exposed to coal dust, and 23 that can be an acute study. And if I say, Well, I don't 24 really see very much, let them go on and say they're 25 and we'll follow him carefully so he doesn't get any 16 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMON0009850 1 really adverse effect. 2 Q. Right. I understand, Dr. Roush. But I 3 think that we're miscommunicating here. I'm talking 4 about animal studies 5 A. Yes. 6 Q. solely regarding animal studies right 7 now that were being done in the early '50s. And there 8 were acute animal studies and chronic animal studies; 9 correct? 10 A. Yes, but not many animal studies. 11 Q. I understand that. All I'm trying to do is 12 to determine how you as a scientist, if you're looking 13 at a published study that was related to exposure to 14 animals on a given chemical, how did you determine 15 whether that was an acute study or a chronic study? 16 A. They would tell me the man who has done 17 it would tell me in his write up. 18 Q. I write a paper saying I exposed these 19 animals for a period of one week to such and such a dose 20 of chemicals 21 A. Yes. 22 Q. and I consider this a chronic study. 23 Would you agree with that? 24 A. Not from what you just said. 25 Q. Okay. Well, that's the whole point I'm 17 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9851 1 trying to make. There was some time period involved 2 where you could tell by looking at the time period used 3 that it may be an acute study or a chronic study. Is 4 that a fair statement? 5 A. Yes. 6 Q. Okay. Was there a determination in your 7 own mind during the early '50s as to what would be 8 how long a chronic study would have to go before it 9 would be called a chronic study? 10 A. It would be determined partially or in a 11 major manner it would be mostly an observation as we 12 watch the man in his exposure. 13 Q. I'm talking about animals, Doctor. 14 A. I understand. We weren't doing manyanimal 15 studies, and it's hard to do it. That's the reason I 16 went to the coal. We have a coal mine a man that 17 goes in the coal mine 18 Q. Were you familiar with animal studies that 19 were being done during that time period? 20 A. A few. 21 Q. And I'm not limiting this to coal or to 22 anything else. I'm just talking about in general, 23 learning the toxicological effects of various chemicals, 24 there were animal studies being done during that period 25 of time; correct? 18 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9852 1 A. Yes, yes. 2 Q. All right. In your own mind did you have a 3 way to distinguish whether a study was chronic versus 4 acute given the length of time that it had gone? 5 A. No, you can't go by that way. 6 Q. Okay. All right. So did you say however 7 though that if it only ran a week, you couldn't consider 8 that a chronic study? 9 A. That's right. 10 Q. All right. How long would it have to run 11 before it would become a chronic study in your own mind? 12 A. We have a subacutein between. 13 Q. Let's talk aboutthose categories, and you 14 give me your own idea in the '50s as to what the time 15 limits would be for acute, subacute and chronic. 16 A. It all depends on how irritating or how 17 much man can tolerate. If man can't tolerate an acute 18 one, we don't go any further. If we have a man exposed 19 to something, and we look at him and he may have a 20 little discomfort, we'll say, Let's go on. So we do a 21 subacute. And if the animal or man tolerates that, then 22 we go to a life time study possibly. 23 So it's going on a lot is responding to 24 what we see as well as how the animal appears to be 25 reacting or what we do in a study that would help to say 19 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9853 1 whether it's acute or not. 2 Q. I'm going to try again. 3 A. Okay. Sure. This is a big this is a 4 very difficult subject. 5 Q. And I know that there's no simple answer. 6 A. Yes. 7 Q. But what I'm trying to get in my own mind 8 is, if I look at a study that was done in the '50s and 9 this study ran for two months, 16 days, would I consider 10 that a chronic study or an acute study or a subacute? 11 MS. RUTTER: Objection. Calls for 12 speculation and conjecture. 13 A. Do a study. If the animal can't tolerate 14 that, that's an acute study. That means he can't 15 tolerate very much of that material. And if he does 16 tolerate it, either I had decided before we started that 17 that we're going to do a subacute study that means 18 we're going to do it for a couple of months 19 Q. (By Mr. Murray) Okay. 20 A. and if he tolerates that, well, then 21 we'll say, Let's go on. Let's do what we talked about. 22 Let's do a chronic 23 Q. Okay. That's what I'm talking about. If 24 you were establishing a protocol in the early '50s to 25 determine the chronic effects of a certain exposure on 20 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9854 1 an animal, how long would you make that study run? 2 A. You would I'm saying the same thing. 3 I'd do anacute. I would do a subacute, depending on 4 Q. But you're not listening to the question. 5 The questionwas I'mnot interested in what comes 6 before the chronic study. You've already determined 7 that a chronic study is necessary. How long would you 8 make that study for? 9 A. Usually it's a routine two year study. 10 Q. Okay. That's all I want to know. 11 A. But really that's oversimplified, because 12 it can be in between there. 13 Q. Sure. I understand that. Basically 14 chronic studies are two year studies, but there can be 15 exceptions. You may want to run it for I assume it 16 also could depend on the animal being used? 17 A. Sure. 18 Q. Some animals don't have a two year life 19 span? 20 A. Sure. But it is extremely complicated, and 21 most people won't stay at it to make it work. 22 Q. Now, I notice in your educational and 23 employment history that you or at least in your early 24 years developed what I maybe would consider a 25 subspecialty in cardiology? Is that a fair statement? 21 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9855 1 A. I had advanced training in it. 2 Q. Okay. Is that training and the work you 3 did in cardiology related to toxicological effects on 4 the heart or just heart troubles in general? 5 A. In occupational medicine. I was in 6 occupational medicine. A man works in the plant. He 7 does some level of activity. And he starts having heart 8 effects, maybe or maybe not related to that excess work. 9 Q. Okay. So in my own mind basically your 10 interest and specialty in cardiology still was in some 11 way related to your overall specialty of occupational 12 medicine? 13 A. Sure, and it could well be that we'd say 14 that, well, I'm not sure they should go on working with 15 that material. 16 Q. Okay. Did you ever run any animal studies 17 yourself in your entire employment history and 18 education? 19 A. No. 20 Q. Normally that wouldn't be something an 21 occupational medicine doctor would do; would it? 22 A. No. I'm much more inclined to see what the 23 animals did and see what we can 24 Q. You're much more interested in seeing what 25 the studies others did with animals and applying that 22 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9856 1 experience to humans; correct? 2 A. It improves our understanding of what that 3 chemicals does. 4 Q. Now, you were with Ethyl Corporation prior 5 to coming to Monsanto? 6 A. That's correct. 7 Q. What did you do at Ethyl? 8 A. Concern for the health of workers who 9 handle tetra, t e t r a, ethyl, ethyl, lead. 10 Tetraethyl lead. It was put in the gasoline to improve 11 the octane. 12 Q. I understand. 13 A. Every car that was used had tetraethyl lead 14 as part of the gasoline. That wasn't my problem. But 15 the people who put that tetraethyl lead into the 16 gasoline, when they were first starting that up in 17 Dayton, Ohio, they killed a number of people acutely 18 from trying to put those two together. 19 Q. Um hmm. 20 A. That's an acute study. I wasn't there at 21 that time. When I got to see them they were saying, how 22 are we going to monitor these people who do that to 23 insure that they don't have that repetition? And they 24 had an examination program. They went around and 25 visited every refinery that put tetraethyl lead in so 23 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9857 1 they don't have the effects 2 Q. Was that part of your duties to actually go 3 around to make those visits to the plants and examine 4 those people that had been dealing with it? 5 A. They had been doing that for a number of 6 years. I don't know when they started making tetraethyl 7 lead. But when I did that, I went around to see if it 8 was adequate. Are we missing something orare we 9 wasting time? So I worked both sides. Butthere the 10 animal data was very important to me so I could decide 11 what to doin looking at them. 12 Q. You started with Ethyl Corporation in what 13 year? 14 A. In '65. 15 Q. All right. Was that a full time position 16 when you first started with them? 17 A. Yes. 18 Q. Okay. 19 A. Well Yes. 20 Q. You were also doing teaching 21 A. I was teaching at Tulane I mean in 22 Cincinnati. 23 Q. And how long did you stay with Ethyl? 24 A. Until '73. We had problems with shipping 25 with tetraethyl lead getting out, people going in and 24 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9858 1 cleaning out gasoline towers, people dying in both of 2 these. And so my job there was, how can I handle this 3 so that that doesn't take place? 4 Q. Okay. Did you go directly from Monsanto 5 to Monsanto from Ethyl? 6 A. Yes. 7 Q. Did you teach after coming to work for 8 Monsanto? Did you continue teaching? 9 A. No. 10 Q. Are you presently doing any teaching? 11 A. No. 12 Q. After you left you told me that you did 13 some consulting work for Monsanto. Have you done any 14 consulting work for anyone else? 15 A. Consulting work has almost always been 16 possible poisoning or health effects related to 17 something that we're doing. 18 Q. I understand. But my question was whether 19 you've done it for anyoneother thanMonsanto. 20 A. Yeah. 21 Q. Who? 22 A. Small companies that would say someone 23 tried to handle a chemical, unusual chemicals, used in 24 paint that includes some solvent that might have some 25 effect, and my job was to say it did or did not. That's 25 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9859 1 the kind of problem. Or people working with lead, a 2 fair amount of them. 3 There's a big lead operation close to St. 4 Louis, and the doctor was saying, well, I think that may 5 be a lead poisoning, and asked me to look at them and 6 confirm whether 7 Q. All right. Your consulting work since 8 you've left Monsanto has been Who actually hires you? 9 Have you been hired by companies, or have you been hired 10 by lawyers, or both? 11 A. By companies. 12 Q. Okay. I need the names of those companies 13 if you can remember, the ones you can remember. I don't 14 expect you to remember everything. 15 A. Led. Usually I suppose 70 percent or 16 more has been me seeing people with a question about 17 lead poisoning. And that's this lead plant just south 18 of here. I can't think of it. 19 Q. You don't remember the name? 20 A. No. But it's one of the biggest in the 21 country. And when you're dealing with lead, lead gets 22 around and people are getting it. The question is, are 23 they getting too much. 24 Q. So somebody might be working at this plant, 25 gets sick, blames the lead, and your job is to come in 26 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMON0009860 1 and examine that individual and make a determination as 2 to whether or not whatever he's got might have been 3 caused by the lead? 4 A. Or say it's not. 5 Q. Okay. All right. And you don't remember 6 the name of the company that you've been doing that for? 7 A. It isn't that much. I'm talking about I 8 suppose I've been doing this for eight years, once, 9 twice, three times a year, something like that, but 10 that's all. 11 Q. Has it all been from that one major 12 company? 13 A. Yes . 14 Q. Have you ever actually testified at trial? 15 A. No. 16 Q. Okay. You have given depositions though 17 with regard 18 MS. RUTTER About lead? 19 Q. (By Mr. Murray) With regard to these led 20 cases, yes. 21 A. No. 22 Q. No? 23 A. No, I just help that manager of that plant 24 so that he wasn't doing harm or that he wasn't doing 25 something 27 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9861 1 Q. Okay. I understand. So those cases 2 weren't in litigation? 3 A. No. 4 Q. Or if they were, you weren't a part of the 5 litigation? 6 A. That's right. 7 Q. Have you ever testified or have you ever 8 been employed by a company other than Monsanto to give 9 advice or counsel with regard to PCBs? 10 A. No. 11 Q. I'm going to ask you some questions about 12 some documents, Dr. Roush. The first document, I'm 13 going to show you what is numbered Monsanto or I should 14 say MONS 030773, and it continues through to 030780. 15 And this document appears to me to be a 16 compilation of several different documents. I'd just 17 ask you to look at that and review it for a minute, and 18 then I'll ask some questions about it. 19 A. (Witness complies.) 20 Q. Okay. Are you finished reviewing the 21 document, Doctor? 22 A. Yes . 23 Q. Do you recognize this document? 24 A. Yes. 25 Q. Okay. And tell me 28 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9862 1 MS. RUTTER: I would object to the form of 2 the question in that it's a number of documents stapled 3 together. 4 MR. MURRAY: All right. I didn't do the 5 staplings. It came to me as one document. 6 So that's what I'm going to ask you about 7 first of all is, tell me in general what those documents 8 are. 9 A. Well, a question is raised whether working 10 in a plant can cause death. And the way you do that is 11 you count the dead, those who have died, and we say, 12 yeah, we have so many who have died from cancer. But 13 that's only a start. Because now that I've got that, is 14 that unusual to only have four? You say, well, did you 15 see everybody in the plant 16 Q. (By Mr. Murray) I understand what you're 17 saying, Doctor, and I'm not trying to cut you off, but 18 basically what I'm trying to understand is, what are 19 these to get a general description of these 20 documents. And basically you're telling me that this is 21 an epidemiological study done at Monsanto on Monsanto 22 workers? 23 A. Yes. And it is characteristic of such 24 things. We didn't have enough of them to study. 25 Q. I understand that. This was a study that 29 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9863 1 was done in the mid '70s? 2 A. Yes . 3 Q. And at whose request was the study 4 performed? 5 A. I don't recall. 6 Q. Who instigated the study, do you recall? 7 A. I can't recall. 8 Q. There was a name in here by Frederick 9 Johannsen? 10 A. He worked for me. 11 Q. Was he the person sort of in charge of 12 doing the study? 13 A. Yes, sort of. 14 Q. Sort of? 15 A. He's a toxicologist. 16 Q. Okay. And ultimately the study was taken 17 over by somebody else; correct? 18 A. Yes, someone more proficient. 19 Q. And that was Judy Zack? 20 A. Yes . 21 Q. Okay. 22 A. You can't do a toxicology study with four 23 deaths. You can't do a lifetime study with only four 24 deaths. And us getting into that computer was to 25 improve the number of them in the study. 30 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9864 1 MS. RUTTER: Let Mr. Murray ask you the 2 question. 3 Q. (By Mr. Murray) I don't want to get into 4 the merits of the study. 5 A. Yes. 6 Q. The things that I'm interested in is, there 7 were some problems that he ran into in running the 8 study 9 A. Yes. 10 Q. one of which was the small number of 11 people that was involved; right? 12 A. Yes. 13 Q. Okay. And part of the solution to that 14 problem was to send the data to an outside 15 epidemiologist; correct? 16 A. Yes. 17 Q. And that was a do you remember who that 18 was? 19 A. Mahboubi? 20 Q. Mahboubi. I don't think I could have 21 pronounced it either. He was with the Eppley Institute? 22 A. Yes. 23 Q. Let me just do this, Doctor. I'm going to 24 show you all of the documents that I've been able to 25 find with regard to Dr. Mahboubi, one of which begins 31 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9865 1 with Monsanto number 094559, runs through 094561, and 2 this is a letter dated October 7th, 1975. And then the 3 other document, again this document came to me stapled 4 together, and they're Bates numbered consecutively 5 beginning MONS 094652 and ending 094571. I'd just ask 6 you to Generally can you tell me, are these letters 7 from the epidemiologist you hired with regard to that 8 study? 9 A. Yes. Yes. I think that was using 10 Mahboubi. 11 (Whereupon, a discussion was held off the 12 record 13 Q. (By Mr.Murray) As Ireviewed those 14 documents, Doctor, and I'm just going to ask you for 15 your recollection if this is the way you remember it 16 going down, Mr. Johannsen, or is it Dr. Johannsen 17 A. Doctor. 18 Q. Dr. Johannsen accumulated some data on the 19 people who worked in the Department 246 at the Krummrich 20 plant; right? 21 A. Yes. 22 Q. And that wasbasically wherethey 23 manufactured PCBs? 24 A. Yes. 25 Q. Okay. And then he submitted that data to 32 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9866 1 Dr. Mahboubi, and Dr. Mahboubi was going to take that 2 data and determine what, if anything, of significance he 3 could determine from it? 4 A. Right. 5 Q. Okay. And this basically was a mortality 6 study; correct? 7 A. Yes. 8 Q. He wanted to know whether or not there was 9 an excess of any types of specific deaths occurring in a 10 population of people occurring within that department; 11 correct? 12 A. Yes. 13 Q. Now, I wanted to direct your attention to 14 the last report of Dr. Mahboubi, and at least I'll say 15 it was the last one I could find, dated November 19th, 16 1975. If you could just review that document, and I'll 17 ask you some questions about it. 18 A. (Witness complies.) 19 Q. Okay. Am I reading that report correct, 20 Dr. Roush, that Dr. Mahboubi actually found a 21 statistically significant excess number of lung cancer 22 deaths ? 23 A. Yes. 24 Q. And he recommended a certain follow up with 25 regard to determining whether or not those deaths may 33 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9867 1 have been related to some type of plant exposure; is 2 that correct? 3 A. Yes, but he hadn't gone that far. He was 4 still back at trying to say, was there an excess of 5 cancers in there. And then the conclusion was, there 6 are very few of them. Now, what are we going to do 7 about those few cancer cases? 8 Q. Right. And one of the things he wanted to 9 find out was the smoking habits of each of those 10 individuals? 11 A. Right. Right. 12 Q. And he indicates in his letter that you 13 might be able to go back to the hospitals where the 14 people died and get the smoking history from the 15 records; right? 16 A. Yes. 17 Q. Was that ever done? 18 A. I don't think so. 19 Q. Okay. 20 A. The other problem that you have to do is 21 you have to decide had they worked there long enough. 22 Q. I understand. I understand that. And in 23 fact, Dr. Johannsen actually did a follow up on that; 24 didn't he? 25 A. Yes. 34 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9868 1 Q. And he determined that the people who 2 worked there longer had an even higher statistically 3 significant lung cancer rate; right? 4 A. That's right. 5 Q. All right. And then I think you indicated 6 to me that Dr. Zack took all of that and then went 7 further with it? 8 A. Yes. 9 Q. I don't want to ask you something you don't 10 know, and I frankly don't have this document with me. 11 But I remember seeing a study done by Dr. Zack, and it 12 was actually the one I saw was something that you 13 would expect as a final draft of a study, a scientific 14 study. Was something like that actually done? 15 A. Yes. 16 Q. Was that ever published? 17 A. Yes. 18 Q. In what journal was thatpublished? 19 A. I don't remember. I think it was 20 Epidemiology, but it might not 21 Q. All right. All right. Was Dr. Zack an 22 employee of Monsanto? 23 A. Yes. 24 Q. And that's Judy Zack; right? 25 A. Yes. 35 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9869 1 Q. Z a c k? 2 A. Yes. 3 Q. All right. As I remember your previous 4 testimony, this study was instituted in order to as a 5 result of a conversation you had with somebody from 6 Mobil 7 A. Yes. 8 Q. where they had indicated they had found 9 what they considered to be an excess of melanoma; is 10 that correct? 11 A. Yes. 12 Q. Okay. Doyou know of any other studies, 13 epidemiological studies, that Monsanto either did 14 themself in house or commissioned someone else to do 15 other than what we've just been talking about? And I'm 16 talking about with regard to PCBs. 17 A. I thinkthat's all. 18 Q. Okay. And I'm going to show you a document 19 labeled SCM 019723 through 019728 and ask you if you 20 recognize that. 21 Are you finished, Dr. Roush? 22 A. Yes. 23 Q. Do you recognize it? 24 A. No. 25 Q. Okay. Do yourecognize that first page as 36 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMON0009870 1 a Monsanto memo? Were you the author of it? 2 A. It means a transfer. I was the one on this 3 that says where it goes next. I didn't do the study on 4 this . 5 Q. No, I understand. But that first page was 6 written by you? 7 A. Yes. 8 Q. Okay. And that was my next question, was 9 do you remember who did that drafted that release? I 10 say release. It's not a realease. It's a statement. 11 A. Yes. I don'trecall. 12 Q. You don't recall. Your memo makes 13 reference to a toxicity section of the Monsanto 14 statement under Action No. 5 of the reference memo. Can 15 you give me any idea what that's talking about? 16 A. Action where is Action 5? I don't know 17 how to find Action 5. I understand quite well what this 18 is about. 19 Q. What is it? 20 A. It's the problem of interpretation of the 21 liver effects 22 Q. Oh, no, I understand that. But I'm trying 23 to understand what it was drafted for. What purpose was 24 it going to be used for? 25 A. I think is to get it to Washington 37 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9871 1 Q. Okay. 2 A. why it does or does not produce the 3 effect that they would say is worse than others or 4 Q. I would suggest a statement that was going 5 to be used as Monsanto's position in front of various 6 government agencies 7 A. Right. 8 Q. in regard to the toxicities of PCBs? 9 A. Right. And this is an early draft 10 Q. A first draft? 11 A. An early draft. 12 Q. Let me show you the next one, that SCM 13 number 019716 through 719, and ask you if you recognize 14 that. 15 Okay. Is that a subsequent version of that 16 first draft of the report that we just discussed? 17 A. Yes . 18 Q. Who is Wayne Withers? 19 A. A public relations type 20 Q. Okay. Do you know whether or not that 21 subsequent memo was adopted in that form, or were there 22 some other changes made to it? 23 A. I don't think changes were made. 24 Q. And was the memo subsequently used in the 25 manner in which you talked about earlier? 38 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9872 1 A. I don't know. 2 Q. Okay. I'll show you the next document 3 labeled SCM 076859 through 076860. First of all, do you 4 recognize the handwriting on that document? 5 A. No, I don't. 6 Q. Have you ever seen that document before to 7 your recollection? 8 A. Yes I've never seen this before. 9 Q. Okay. You notice these initials up at the 10 top right hand corner of the first page? 11 A. Yes . 12 Q. WS is that a T or a J? Or do you know? 13 A. I think that's a J. 14 Q. Do you recognize those initials? 15 A. No. 16 Q. Can you think of anybody at Monsanto during 17 the 1983 time period who would have the initials WSJ? 18 A. No, I don't. 19 Q. Okay. I thought I'd give it a shot. 20 A. Sure. 21 Q. After the two year chronic tests that were 22 run on the Aroclors in the mid '70s, do you know whether 23 or not Monsanto ever went back and ran any other chronic 24 studies? And specifically do you ever remember if they 25 ran an 18 month study on rats? 39 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9873 1 A. Well, they did a two year study on rats. 2 Q. I understand. 3 A. Yes. 4 Q. I understand. After that two year study 5 did they ever go back and run an 18 month study on them? 6 A. I don't know. 7 Q. During the time period you were there did 8 they ever do that? 9 A. I don't think so. 10 Q. Okay. I'll show you another document which 11 has no it has several different numbers on it. I 12 think the most obvious number is the S number 000008 and 13 000009. I'd just ask you to look at that and tell me if 14 you've ever seen that before. 15 MS. RUTTER: Joe, I'm going to want copies 16 of all these documents. I assume you won't object to 17 that. 18 MR. MURRAY: You've got copies of them. 19 MS. RUTTER: Some of these are from SCM. 20 MR. MURRAY: We got them from you though. 21 MS. RUTTER: Well, that doesn't mean I've 22 got them easily accessible at my finger tips. 23 MR. MURRAY: You can take a copy. I don't 24 have any objection to that. 25 MS. RUTTER: Okay. 40 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9874 1 Q. (By Mr. Murray) Do yourecognize the 2 document, Doctor? 3 A. Never saw it. 4 Q. Let me just say that for future reference 5 if you look at a document and you can tell right away 6 that you've never seen it before, just tell me that and 7 we won't go into it any further; okay? Do you 8 understand what I'm saying? 9 A. Yes. 10 MS. RUTTER: What he's saying is, if you 11 don't recognize it, just say so and he's not going to 12 ask you questions about it. 13 A. I thought you wanted me to 14 Q. (By Mr. Murray) I wanted you to see it and 15 make sure that you had recognized it or not, but if you 16 look at a document and know that you haven't seen it 17 before and don't recognize it, just say so and we can 18 skip it and just go to the next one; okay? 19 A. Sure. 20 Q. Tell me, what is the MonsantoBiohazards 21 Committee I guess? And to the time period of August of 22 '81 what was that and what was its purpose? 23 A. I forgot the time when this goes back, but 24 it's at least ten years. I brought together a group of 25 outside consultants. And then we talked about if we 41 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9875 1 had liver damage, we'd have a pathologist to help us to 2 get an interpretation of that for Monsanto's benefit. 3 So we had a pathologist, a biochemist not only are 4 they these are the chairmen of the departments 5 Q. Of medical in medical institutions 6 A. at the top drawer medical schools 7 Q. Okay. 8 A. and biochemists and more. 9 Q. So it's a group of scientists, outside 10 independent scientists that you brought together to 11 discuss particular issues relating to I assume all kinds 12 of different chemicals, not just PCBs? 13 A. Oh, yeah, that's right. 14 Q. Okay. And how often would that group meet? 15 A. Once a month. 16 Q. And were the scientists whowere members of 17 that group paid by Monsanto for their time? 18 A. Yes. 19 Q. Were they on like a retainer, or were they 20 paid on an hourly basis, or do you know? 21 A. Hourly or daily basis. 22 Q. Okay. Now, I want to direct your attention 23 to a copy of the minutes of the meeting of the 24 Biohazards Committee dated August 25th, '81. And I want 25 to specifically ask you about a sentence in here that 42 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9876 1 says, The most satisfactory formulation is that the PCB, 2 in company with many other chlorinated hydrocarbons, is 3 a promoter in the carcinogenic process. Was that a 4 conclusion that the committee reached, or was that your 5 own opinion, or was that Monsanto's position? 6 MS. RUTTER: I would urge you to take a 7 look at the document before answering his question since 8 it dates back apparently to 19 9 MR. MURRAY: I'm not asking him about the 10 document. I'm asking him about 11 Well, can you look at the document, Doctor? 12 I don't care. I'd like to get out of here before 13 tomorrow. 14 MS. RUTTER: If this doesn't have anything 15 to do with PCBs, I doubt if he's going to ask you 16 questions on that. 17 Q. (By Mr. Murray) Do you remember my 18 question, Dr. Roush? 19 A. I'm sorry. 20 MR. MURRAY: Would you read back the 21 question, please? 22 (Whereupon, the question was read back by 23 the reporter as follows: 24 Q. "Okay. Now, I want to direct your 25 attention to a copy of the minutes of the meeting 43 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9877 1 of the Biohazards Committee dated August 25th, 2 '81. And I want to specifically ask you about a 3 sentence in here that says, The most satisfactory 4 formulation is that the PCB, in company with many 5 other chlorinated hydrocarbons, is a promoter in 6 the carcinogenic process. Was that a conclusion 7 that the committee reached, or was that your own 8 opinion, or was that Monsanto's position?") 9 A. This was a statement by the Hazards 10 Biohazards Committee giving an opinion on how PCBs are 11 formulated 12 Q. (By Mr. Murray) All right. 13 A. and the action of them. 14 Q. That is based that is the Committee's 15 opinion as opposed to your own personal opinion 16 A. Yes, yes. 17 Q. or a position of Monsanto or anything 18 like that? 19 A. That would be testimony that would have 20 been as valuable as mine. 21 Q. Let me ask you, do you share that opinion? 22 A. This was some time ago, so I have some 23 advantage. I think that it can be a promoter in the 24 carcinogenic process, but that doesn't mean that it is. 25 Q. Okay. Let me go back to Judy Zack for a 44 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9878 minute, because I've forgotten to ask you some things. 2 When was that article published? 3 A I don't know. 4 Q Was it before you left Monsanto? 5 A Yes . 6 Q What month in '8 8 did you leave? 7 A I'm not sure. I think it was November 8 Q Okay. So that would have been 9 A No, that was a mis must have been 10 that was probably April. 11 Q So this last if this deposition was 12 the Cecil Scott case, that would have been roughly 10 13 months, 11 months before you left? 14 A. Yes. 15 Q. Okay. In discussing thatepidemiological 16 study, in your previous testimony you indicate that you 17 were in the process of writing up a case controlstudy, 18 and this was in June of '87. Would that be theDr. Zack 19 study that you were talking about there? 20 A. No, I don't think so. 21 Q. Okay. Let me then let you look at that 22 part of your testimony and ask you to tell me what you 23 were talking about. This is the specific part, and then 24 you can look at either side of that to get the context 25 of it. 45 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9879 1 Have you read enough to understand the 2 connection in what you were trying to say at the time? 3 A. What was the question again? 4 Q. My question was, what case control study 5 were you talking about there that you were in the 6 process of doing in June of 1987? 7 A. I don't remember the context. 8 Q. Well, let me see if I can help you with it 9 then. This part of your testimony was dealing with the 10 Johannsen epidemiological study of the workers in the 11 Krummrich plant. And you were talking about how it 12 probably wasn't meaningful because of the size of the 13 group that you were using and that type of thing. 14 A. Right. 15 Q. And the specifictestimony was, We found 16 lung cancers there, meaning in the Krummrich plant, and 17 whether that was related was another question. I assume 18 that what you're talking about there was whether that 19 was related to the PCB exposure? 20 A. Right. 21 Q. And the nextquestion was thequestion 22 which you can't answer for us to this day? 23 And the answer, Well, yes, we've done 24 follow up studies on that population and we have an 25 excess of lung cancer in that whole plant. 46 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMON0009880 1 Question: I see. 2 So it's not PCBs. 3 Question: What is it? 4 Then you go on to that answer where you 5 talk about the next thing we did is compare this. That 6 was with the national population. Then we compared it 7 with the local population. And we're in the process of 8 writing up a case control study to look at this. 9 You still can't tell me what that case 10 control study is? 11 A. No. 12 Q. Okay. Other than Judy Zack's report 13 though, you don't know of any other epidemiological 14 study done by Monsanto on PCBs; right? 15 A. I think Gaffey has one. 16 Q. Was that done by Monsanto? 17 A. Yes. 18 Q. Was that the control study that you were 19 talking about? 20 A. I can't answer that. 21 Q. What population was Gaffey looking at? 22 A. All of the exposures to PCBs. This was an 23 attempt to get around that problem of definition of 24 population. 25 Q. The exposure of whom? 47 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9881 1 A. Of the workers at Krum 2 Q. At Krummrich? 3 A. at Krummrich. 4 Q. Okay. Gaffey was a Monsanto employee? 5 A. Yes, he's a level above Zack. 6 Q. Is Zack still working at Monsanto? 7 A. No. 8 Q. Do you know where she's working then? 9 A. No, I cannot. 10 Q. Okay. What about Gaffey? 11 A. Gaffey is retired, but right he's in St. 12 Louis. 13 MR. MURRAY: I can't think of anything 14 else, Doctor Roush. I appreciate your time, sir. 15 CROSS EXAMINATION 16 QUESTIONS BY MS. RUTTER: 17 Q. I've got just a couple. Dr. Roush, you 18 testified that you thought the Zack study had been 19 published. Is it possible that you're wrong on that? 20 A. I don't think so. 21 Q. Okay. Mr. Murray asked you a question 22 about had you ever testified in court for Monsanto. You 23 have testified in trials in which Monsanto was a 24 defendant; is that correct? 25 A. I was trying to think of them, but I can't 48 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9882 think of one. Q. There was a trial across the river; was 3 there not? It had nothing to do with PCBs? 4 A. Yes. 5 Q. But youtestified in that? 6 A. Right, that was not with PCBs. 7 Q. All right. I just wanted to make sure that 8 wasn't a source of confusion. And you're uncertain of 9 the dates of the last time you gave a deposition 10 involving a PCB case? 11 A. Yes. 12 Q. Back in the 1950s was it common practice to 13 do long term chronic animal studies on industrial 14 chemicals that were not regulated by the FDA or the 15 Department of Agriculture? 16 A. It wasless common then than now. 17 Q. And I'm a little bit confused about the 18 last line of testimony about Dr. Gaffey. I've 19 personally never heard of an epidemiological study by 20 Dr. Gaffey. Are you sure that he did one? 21 A. I think so. 22 Q. But you're not 100 percent certain? 23 A. No. No. 24 MS. RUTTER: That's all I have. 25 MR. BERRA: I don't have any questions. 49 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9883 H4 ?8E5SffiM?offii5T}ofJ&Ei'? F1T TO HAKE 0M 50 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9884 [& - acutely] Transcript Word Index & 1506 30 & 1:1 50:25,25 1:1,1,1 50:21,25,25,25,25 16 50:25,25,25,25,25,25,25,25 20:9 167.40 0 50:25,25 50:25 314 1:1 50:25,25 3786 1:1 50:25______________ 000008 40:12 000009 40:13 00911 1:1,1 50:22,25,25,25 019716 38:13 019723 36:19 019728 36:19 030773 18 39:25 40:5 19 43:8 1950s 16:6 49:12 1951 8:23 1975 32:2 33:16 1983 39:17 1985 4 4 1:1 400 1:1 43 50:25 4786 50:25 492.590 50:25__________________ 5 28:14 50:25 5 030780 1987 37:14,16,17 28:14 2:19 7:14 46:6 50 076859 1994 1:1 39:3 1:1,1 50:12,25,25,25,25,25 50s 076860 50:25 12:14 13:16,19 15:6 17:7 39:3 1996 18:7 19:14 20:8,24 094559 50:25,25 515 32:1 19th 1:1 50:25,25,25 094561 33:15 53 32:1 Icc 50:25 094571 50:25 54 32:5 094652 32:5 1 1 1:1 50:25,25,25 10 45:12 50:25,25 10.00 2 2 1:1 50:25 203.40 50:25,25 24 50:25,25,25,25 246 32:19 9:6 10:21,22 50:25,25 55 50:25 56 50:25 57.03 50:25 59.40 50:25,25_______________ 50:25,25 2550 6 100 1:1 50:25 6/15/94 1:1,1 49:22 50:25,25,25 2571 50:21,23,25 11 1:1 50:25,25 62.40 45:13 25th 50:25 11th 42:24 44:1 621 2:19 26.00 1:1 50:25,25 1231575 50:25,25 63101 50:25 13 1:1 15 1:1,1,1 7:10 50:25,25 15.00 50:25 3 1:1 3.00 50:25 3.10 50:25 3 1:1,1 50:25,25,25,25 63102 1:1 50:25,25 63105 1:1 50:25 65 24:14 7 70 26:15 70112 1:1 50:25,25 70s 30:1 39:22 719 38:13 73 24:24 7th 32:2_____________________ 8 81 41:22 42:24 44:2 8182 1:1 50:25 87 45:18 88 3:14 8:18 45:6___________ 9 909 1:1 50:25,25 922 1:1,1 50:22,25,25,25 94 50:25____________________ a able 31:24 34:13 absent 50:25 academic 10:14,16 accessible 40:22 accumulated 32:18 action 2:17 37:14,16,16,17 44:13 50:25,25 activity 22:7 acute 12:11,19,21 13:3,7,10 14:17 15:1,10 16:3,16,20 16:23 17:8,15 18:3 19:4,15 19:1720:1,10,1421:3 23:20 acutely 16:11 23:17 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9885 [add - charge] add anybody back (cont.) 14:2 39:16 34:4,13 39:23 40:5 41:23 addressed apparently 43:8,20,22 44:25 49:12 50:25 43:8 based adequate appear 44:14 24:8 50:1 basically adopted appears 21:13 22:9 29:18,20 32:22 38:21 19:24 28:15 33:5 advanced apply basis 22:1 14:4 42:20,21 advantage applying bates 44:23 22:25 32:4 adverse appreciate bechtold 5:12 8:1 9:14 17:1 48:14 50:25 1:1,1,1,1 50:21,25,25,25 advice april beginning 28:9 45:10 50:25,25 32:5 afternoon aroclors begins 1:1 39:22 31:25 age article behalf 2:11 45:2 1:1,1 agencies ascii benefit 38:6 50:25 42:2 ago asked berra 8:16 44:22 5:11,19,23 6:1,167:1 26:5 1:1 49:25 agree 48:21 big 17:23 asking 12:22 13:12 15:24 20:3 agreed 5:6 6:1,20 43:9,10 26:3 2:1 assume biggest agreement 21:1540:1642:11 46:17 26:20 2:7 50:25 50:25 billed agriculture attachment 50:25 49:15 50:25 biochemist air attd 42:3 11:24 50:25 biochemists al attempt 42:8 50:21,25,25,25 47:23 biohazards alleged attendance 41:20 42:24 44:1,10 8:1 50:25 bit amount attention 49:17 15:15 26:2 33:13 42:22 43:25 blames animal attn 26:25 14:13,16 15:16 16:17 17:4 50:25 blood 17:6,8,8,10 18:14,18,24 attorney 14:1 19:21,24 20:1321:1,16 50:25,25,25 break 22:16 24:10 49:13 august 12:10 animals 41:21 42:24 44:1 broadway 16:15 17:14,19 18:1321:18 author 1:1,1 50:25,25,25 22:23,25 37:1 brought answer available 11:21 41:24 42:10 3:7 6:4 7:22 20:5 46:22,23 50:25 business 47:4,20 avenue 50:25 answering 43:7 anticipated 50:25 1:1 50:25 b back 10:24 11:9,19 12:13,17 50:25 called c 13:15,19 14:21 15:25 16:10 18:9 calls 20:11 cancer 29:12 33:21 34:7 35:3 46:25 cancers 34:5 46:16 capacity 4:19 car 23:13 carcinogenic 43:3 44:6,24 cardiology 21:25 22:3,10 care 43:12 carefully 16:25 carol 1:1 50:25 case 2:20,21 4:13 5:8 8:20 45:12 45:17 46:4 47:8,9 49:10 cases 4:1,14,16,20 7:18,20,25 8:11 27:20 28:1 34:7 categories 19:13 cause 1:1,1 29:10 50:22,25,25,25 50:25 caused 27:3 cc 50:25,25 cecil 2:20 45:12 certain 15:11 20:25 33:24 49:22 certainly 12:16 14:20 certificate 50:25,25 certify 50:25,25,25 chairmen 42:4 change 50:25 changes 38:22,23 50:25 characteristic 29:23 charge 30:11 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9886 [charges - depends] charges common 50:25,25 49:12,16 Charles companies 1:1,1 25:22 26:9,11,12 check company 10:10 1:1,1 27:6,12 28:8 43:2 chemical 44:4 50:25,25 12:17 15:11,15 17:1425:23 compare chemicals 47:5 4:6 9:16 11:3 12:7 17:20 compared 18:23 23:3 25:23 42:12 47:6 49:14 comparing chlorinated 13:23 43:2 44:5 compilation chronic 28:16 12:11,16,25 13:2,11,18 complicated 14:17,18 15:1,12 16:4,17 5:1421:20 16:20 17:8,15,22 18:3,8,9 complies 19:3,8,11,15 20:10,22,25 28:19 33:18 21:6,7,14 39:21,23 49:13 computer chronically 30:24 14:7 concern Cincinnati 23:8 24:22 concerning circuit 50:25 1:1,1 50:25 conclusion city 5:6 34:5 43:4 44:6 1:1,1 50:25,25 conducted clarification 11:2 50:25 confirm clarify 26:6 15:4 confused clayton 49:17 1:1 50:25 confusion cleaning 49:8 25:1 conjecture clinical 20:12 13:20 connection close 46:2 26:3 consecutively coal 32:4 11:9,20 13:14,22 14:2 consent 16:22 18:16,16,17,21 2:8 cod consider 50:25,25 17:22 19:7 20:9 21:24 coming considered 10:2 23:5 25:7 36:9 commission consultant 50:14,25,25 3:22,24 4:2,10 5:17,18 commissioned consultants 36:14 50:25 41:25 committee consulted 41:21 42:24 43:4 44:1,7,10 4:19 committee's consulting 44:14 5:1025:13,14,1526:7 context d 45:24 46:7 daily continue 42:21 25:8 damage continues 42:1 28:14 data continuing 24:10 31:14 32:18,25 33:2 6:2 11:16,17 dated control 32:2 33:15 42:24 44:1 45:17 46:4 47:8,10,18 dates controversy 43:8 49:9 50:25 day conversation 1:1 46:22 50:12 36:5 days copies 20:9 50:25 40:15,18 dayton copy 23:17 40:23 42:23 43:25 50:25,25 dead 50:25 29:11 corner dealing 39:10 4:6 24:4 26:21 46:9 corporation dear 1:1,1 23:4 24:12 50:25,25 50:25 correct death 2:176:138:23 13:8,15,16 29:10 13:17 15:17 17:9 18:25 deaths 23:1,6 30:17 31:15 33:6,11 30:23,24 33:9,22,25 33:19 34:2 36:10 48:24 deceased 50:25 1:1,1,1,1,1,1 correction decide 50:2,25,25,25 24:10 34:21 corrections decided 50:1,25,25,25,25 20:16 correctly decision 10:6 13:12 costs defendant 50:25 1:1,1 48:24 cough defendants 15:25 2:3 counsel definition 2:2,2,8 28:9 50:25,25 14:24 47:23 count degree 29:11 10:21 12:5,5,15 15:7 country delivery 26:21 50:25,25,25 couple department 20:18 48:17 32:19 33:10 49:15 course departments 12:4 50:25 42:4 court depend 1:1,1 6:7,10 48:22 50:25,25 21:16 cross depending 48:15 21:3 cut depends 29:17 12:22 13:3 19:16 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9887 [depo - extremely] depo disease early 50:22,25,25 11:13,15 13:22 14:1 12:13 15:6 16:6 17:7 18:7 deposes diseases 20:24 21:23 38:9,11 2:12 11:15 easily deposition distinguish 40:22 1:1,1 2:3,6,20,22 3:2 6:7,13 19:3 education 6:21,25 7:5,14 8:20 45:11 doctor 22:18 49:9 50:25,25,25,25,25,25 18:13 22:21 26:4 28:21 educational 50:25 29:1731:23 32:14,1741:2 21:22 depositions 43:11 48:14 effect 2:176:1527:16 document 12:16 13:14,23 17:1 25:25 depth 28:12,15,21,23 29:5 32:3,3 38:3 10:5 33:16 35:10 36:18 39:2,4,6 effects description 40:1041:2,5,1643:7,10,11 5:12,20 6:17,18 8:1 9:15 29:19 documents 12:7,10,11,11 13:7 18:23 desire 28:12,16 29:2,7,20 31:24 20:25 22:3,8 24:1 25:16 50:25 32:14 40:16 37:21 determination doing eight 18:6 27:1 11:19 12:2,25 18:1424:5 3:14 27:8 determine 24:20 25:10,17 27:6,8,24 eighty 13:7 14:10,25 16:3 17:12 27:24 30:12 46:6 3:14 17:14 20:25 33:2,3 dosage either determined 15:15 4:3 6:6 9:10,10,24 10:2 18:1021:6 35:1 dose 20:16 31:21 36:13 45:24 determining 15:19,21 17:19 electric 33:25 doubt 1:1,1 50:25,25 developed 43:15 elizabeth 21:24 dr 1:1,1 developing 1:1,1 2:10,15 3:5,10 5:8 employ 11:12 8:22 10:23 17:2 28:12 3:13 died 31:25 32:16,18 33:1,1,14 employed 29:11,1234:14 33:20,20 34:23 35:6,11,21 3:11,20,23 4:2,10 5:1,17 differ 36:21 43:18 45:18 48:17 28:8 50:25,25 15:14 49:18,20 50:8,22,25,25,25 employee different 50:25,25 35:22 48:4 50:25 28:16 40:11 42:12 draft employment differentiated 35:1338:9,10,11,16 21:23 22:17 16:19 drafted enclosed difficult 37:9,23 50:25,25 20:4 drawer enclosures direct 42:6 50:25 2:13 33:13 42:22 43:24 due entail directly 50:25 9:9 25:4 duly entire director 50:25,25 22:17 3:16 dust envelope discomfort 16:22 50:25 19:20 duties epidemiological discuss 24:2 29:21 36:13 45:15 46:10 42:11 dying 47:13 49:19 discussed 25:1 epidemiologist 3:2 38:16 discussing 45:15 discussion 32:11 e ea 50:25 parlipr 2:15 38:25 31:15 32:7 epidemiology 35:20 eppenberger 1:1,1 50:25,25,25 eppley 31:21 errors 50:25 established 16:15 establishing 20:24 estimate 7:9 et 50:21,25,25,25 ethyl 23:4,7,9 24:12,23 25:5 everybody 29:15 examination 2:13 23:24 48:15 50:25 examinations 1:1 examine 24:3 27:1 examined 1:1 2:11 50:25 exceptions 21:15 excess 22:8 33:9,21 34:4 36:9 46:25 excuse 3:4 expect 2:24 26:14 35:13 expensive 14:18 experience 23:1 expert 4:20 5:1,8 expires 50:14,25,25 exposed 14:7 15:16 16:22 17:18 19:18 exposure 5:13,21 6:17 8:2 9:15 12:16 13:13 14:2,11 17:13 18:12 20:25 34:1 46:19 47:25 exposures 47:22 express 5:11,196:16 extent 14:10 extremely 21:20 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9888 [fact - improve] f fact 34:23 factual 4:23 fair 18:4 21:25 26:2 familiar 10:23 11:1 18:18 far 6:12 34:3 fault 6:5 favor 50:25,25,25 fda 49:14 fed 50:25 fee 50:25 field 9:8,14,22 12:24 16:2 fifty 10:22 filed 2:21 50:25 filing 50:25 final 35:13 financially 50:25 find 31:25 33:15 34:9 37:17 50:25 finger 40:22 fingersh 1:1 50:25 finished 28:20 36:21 firm 1:1,1,1 50:25,25 first 3:10 23:16 24:16 28:12 29:7 36:25 37:5 38:10,16 39:3,10 50:25 fit 50:1 five 1:1 7:178:6 follow 16:25 33:24 34:23 46:24 following 50:2 follows go held 43:23 50:25 3:17 10:1,14,18 11:23 32:11 50:25 forenoon 16:24 18:8 19:5,18,20,22 help 1:1 20:21 22:14 24:2 25:4 16:13 19:25 27:23 42:1 forgot 34:13 40:5 41:7,18 44:25 46:8 41:23 47:4 helping forgotten goes 4:16 45:1 11:14 18:17 37:3 41:23 hereto form going 50:25 5:4,22 6:13,19 29:1 38:21 3:1,1 11:13 13:11 14:25 hereunto formulated 19:23 20:2,17,18 23:22 50:25,25 44:11 24:25 28:11,13 29:6 31:23 higher formulation 32:14,16 33:1 34:6 36:18 35:2 43:1 44:4 37:24 38:4 40:15 41:11 hired forwarding 43:15 26:9,9 32:7 50:25 good hires found 2:15 26:8 14:3 33:20 36:8 46:15 goodman history 50:25 1:1,1,1,1 16:21 21:23 22:17 34:14 four government hmm 10:22 29:14 30:22,23 38:6 23:19 frankly graduated hospitals 35:10 8:23 34:13 frede rick group hourly 30:8 41:24 42:9,14,17 46:13 42:20,21 front guess hours 38:5 7:1241:21________________ 1:1 full h 24:15 habits further 34:9 19:18 35:7 41:7 50:25,25 future 41:4_____________________ hand 39:10 50:25,25 handle g 11:25 23:9 25:2,23 gaffey handwriting 47:15,21 48:4,10,11 49:18 39:4 49:20 happen gas 11:15 14:3 hard gasoline 18:15 23:10,14,16 25:1 harm general 27:24 4:17 18:22 22:4 29:7,19 hazards house 36:14 human 5:12 humans 6:189:1523:1 husband 1:1,1,1,1 husch 1:1,1 50:25,25,25 hydrocarbons 43:2 44:5 hygienist 11:24 16:13 hygienists 11:22 generally 44:9 32:6 head i.d. george 3:8 50:25 1:1,1 2:10 50:8,25,25,25 health i.e. getting 4:4 5:12 8:1 9:4,8,12,12,15 50:25,25 15:18 24:25 26:22,23 30:24 9:18 10:8,25 11:5 15:7 23:8 idea give 25:16 19:1437:15 7:9 19:14 28:8 37:15 39:19 heard illness given 49:19 14:11 2:178:20 17:14 19:4 27:16 hearing important 50:25 50:25 24:10 giving heart improve 44:10 9:5 13:23 22:4,4,7 23:10 30:25 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9889 [improves - man] improves 23:2 inclined 22:22 include 9:14 includes 25:24 including 5:25 independent 42:10 index 1:1 indicate 45:16 indicated 35:5 36:8 50:25 indicates 34:12 individual 14:9 27:1 individuals 9:11 34:10 industrial 11:3,22,24 16:12 49:13 industry 9:24 initials 39:9,14,17 instances 4:6 instigated 30:6 institute 31:21 instituted 36:4 institutions 42:5 insure 23:23 interest 10:14,16 11:1822:10 interested 10:3 11:6 21:5 22:24 31:6 50:25 internship 9:1 interpretation 37:20 42:2 invoice 50:25,25 involved 10:13 18:1 31:11 involving krum 49:10 48:1 irritating krummrich 19:16 32:19 46:11,16 48:2,3 issue I 4:15 5:2 issues 42:11____________________ la 1:1 50:25,25 labeled j 36:19 39:3 job lady 11:14 25:2,25 26:25 3:5 joe law 2:1640:15 1:1,1,1 50:25,25 johannsen lawful 30:9 32:16,16,18 34:23 2:11 46:10 lawyer joseph 5:5 6:20,22 8:7,10,13 1:1 50:25 lawyers journal 26:10 35:18 lead jr 23:9,10,13,15,25 24:7,25 1:1,1,1,1,1 2:10 50:8,23,25 26:1,3,5,17,17,21,21,25 50:25,25,25 27:3,18 judith leading 1:1,1 50:25,25 12:4,5 15:6 judy learning 30:19 35:24 44:25 47:12 11:7 18:23 june leave 1:1,1 2:19 45:18 46:6 50:25 3:13 45:6 50:25,25,25,25,25________ led k kathleen 1:1 2:4 50:25,25,25 kaw 50:21,25 keep 11:12 kellie 1:1,1 kenneth 1:1,1 killed 23:17 kind 13:24 16:2 26:1 kinds 4:1 42:11 know 3:5 5:7 7:8,25 15:10 20:5 21:10 24:6 33:8 35:10 36:12 37:16 38:20 39:1,12 39:22 40:6 41:16 42:20 45:3 47:13 48:8 knowledge 50:25 26:15 27:19 lee 1:1,1 left 3:15 25:12 26:8 45:4,13 legal 5:6,8 length 15:2,16 16:4 19:4 letter 32:2 34:12 letters 32:6 level 22:7 48:5 lewis 1:1 50:25 life 19:22 21:18 lifetime 30:23 limit 6:17 limiting 18:21 limits 19:15 line 1:1 49:18 50:25 listening 21:4 litigation 28:2,5 little 19:20 49:17 liver 37:21 42:1 local 47:7 long 8:16 12:22 18:8 19:1021:1 21:7 24:23 34:21 49:13 longer 35:2 50:25 look 10:1,4,18 13:21 16:22 19:19 20:8 26:5 28:17 40:1341:5,1643:7,11 45:21,24 47:8 looking 9:23 10:14 11:22 13:25 17:12 18:2 24:11 47:21 lot 11:19 19:23 lots 13:5 loud 7:23 louis 1:1,1,1,1,1 26:448:12 50:25,25,25,25,25,25,25,25 lung 11:12,14 13:22 33:21 35:3 46:16,25 lungs 15:22 m mahboubi 31:19,20,25 32:10 33:1,1 33:14,20 mailed 50:25 major 18:11 27:11 making 2:25 24:6 man 11:4,11 13:25 16:11,17 17:16 18:12,16 19:17,17,18 19:21 22:6 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMON0009890 [manager - opinion] manager mind murray o 27:23 18:7 19:2,11 20:7 22:9 1:1,1,1 2:14,16 5:7,25 6:23 oath manner mine 6:25 15:4,5 16:7 20:19 50:25 18:11 38:25 50:25 14:2 18:16,17 44:20 27:1929:4,16 31:1,3 32:13 object manufactured miners 40:18,20,23 41:1,14 43:9 5:4,22 6:19 29:1 40:16 32:23 11:10,17,20 13:14 43:17,20 44:12 48:13,21 objection manufacturing mines 50:25,25,25 20:11 40:24 10:7 13:22 n observation marquette minute name 18:11 9:1 9:7 28:17 45:1 2:16 8:7,10,13 26:19 27:6 obvious maryland minutes 30:8 40:12 1:1 50:25 42:23 43:25 names occasion master's 9:4,18 12:5 mis 45:9 7:1826:12 narrow 4:22 occasions material miscommunicating 4:18,18 8:6 20:15 22:15 17:3 national occupational matters missing 47:6 9:4,19,21 10:8,25 14:1,6 50:25 mean 5:16 11:25 24:21 40:21 44:24 meaning 46:16 meaningful 24:8 missouri necessary 3:6 21:7 1:1,1,1,1 50:25,25,25,25,25 50:25 misspelled need 16:1226:12 neither 50:25 mo 50:25 new 22:5,6,11,21 occurring 33:9,10 o'clock 1:1,1 octane 23:11 46:12 means 1:1,1,1 50:25,25,25,25,25 mobil 1:1 50:25,25 nine October 32:2 5:7 9:23 20:14,17 37:2 36:6 medical monday 3:16 4:20 5:2 8:23,25 11:7 4:9 1:1 nodding 3:8 offices 1:1 50:25 oh 11:8,23,25 12:1,5 14:10 monitor normal 37:22 42:13 42:5,5,6 23:22 50:25 Ohio medicine mons normally 23:17 9:5,19,21 10:25 13:21 14:6 22:5,6,12,21 meet 42:14 28:14 32:5 monsanto 13:6 22:20 north 1:1,1,1 3:11,254:2,10,16 4:21 5:11,17,25 6:1,7,10,24 1:1 50:25 notarial meeting 42:23 43:25 melanoma 7:15 8:8,11 23:5 25:4,5,8 25:13,19 26:8 28:8,13 29:21,21 32:1 35:22 36:13 50:25,25 notary 1:1 2:5 50:18,25,25,25,25 okay 4:155:106:24 7:11 8:6,19 8:22 9:14 10:6,12,20 11:19 12:13 13:18 14:5,13,16 15:20,23 17:25 18:6 19:6 20:3,19,23 21:10 22:2,9,16 24:18 25:4 26:12 27:5,16 36:9 37:1,13 39:16,23 41:20 noted 28:1,20,25 30:16,21 31:13 members 42:17 44:17 45:4 47:14,16 50:25,25 32:25 33:5,19 34:19 36:12 42:16 48:4,6,22,23 50:21,25,25 notice 36:18,25 37:8 38:1,15,20 memo 37:1,12,14 38:21,24 50:25 monsanto's 21:22 39:9 noting 39:2,9,19 40:10,25 41:7,18 42:7,14,22 43:24 44:25 merits 38:5 42:2 43:5 44:8 50:25,25 45:8,15,21 47:12 48:4,10 31:4 month november 48:21 met 39:25 40:5 42:15 45:6 33:15 45:7 olive 2:15 months number 1:1 50:25,25,25 metabolism 20:9,18 45:13,13 4:14 7:6 23:17 24:5 29:2 once 9:5 morning 30:25 31:10 32:1 33:21 10:3 27:8 42:15 mid 2:15 38:13 40:12,12 50:25 ones 30:1 39:22 mortality numbered 26:13 milwaukee 9:1 33:5 mother 28:13 32:4 numbers operation 26:3 mina 1:1,1 40:11 50:25,25 opinion 1:1,1 5:20 7:1 43:5 44:8,10,15,15 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9891 [opinion - reason] opinion (cont.) people (cont.) possibly 44:21 23:22 24:4,25 25:1 26:1,16 19:22 opinions 26:22 31:11 32:19 33:10 poydras 5:11 6:16 34:14 35:1 1:1 50:25,25 opportunity 50:25 percent 26:15 49:22 PP 50:25 opposed performed practice 44:15 30:4 49:12 order period presentation 11:12 13:1336:4 10:24 11:20 12:25 14:14,23 11:7 org 15:3 16:8,16,18,19 17:19 presently 50:25 18:1,2,19,24 39:17 40:7 25:10 orig 41:21 previous 50:25 person 36:3 45:16 original 9:1330:11 primarily 50:25,25,25,25,25 personal 3:25 Orleans 1:1,1,1,1,1,1 44:15 prior 1:1 50:25,25 personally 23:4 outside 49:19 probably 10:3 31:14 41:25 42:9 pgs 7:2 45:10 46:12 overall 50:25 problem 22:11 phyllis 6:3 9:25 10:9,15 12:1,23 oversimplified 1:1,1 23:14 26:1 31:14 34:20 21:11 physician 37:20 47:23 P 16:11 problems page 1:1 36:25 37:5 39:10 50:25 Pittsburgh 9:4 9:12 10:1 11:16,23 24:24 31:7 50:25,25,25,25,25,25 paid place 25:3 procedures 12:6 42:17,20 50:25,25 plaintiffs process paint 25:24 paper 17:18 part 1:1,1,1 2:2,12,16 11:7,8 43:3 44:6,24 45:17 plaintiff's 46:6 47:7 6:22 produce plant 13:13 38:2 9:24 10:7,9 11:12 14:3 22:6 produced 2:12 23:14 24:2 28:4 31:13 26:17,24 27:23 29:10,15 1:1 2:11 45:22,23 46:9 partially 18:10 particle 15:21 32:20 34:1 46:11,16,25 plants 10:15 24:3 please 3:4 7:23 15:8 43:21 50:25 produces 13:23 professional 1:1 2:4 50:25 proficient particular 4:5 12:2 42:11 parties 50:25,25,25,25 pathologist 50:25,25,25 point 2:25 17:25 poisoning 25:16 26:5,17 30:18 program 23:24 prolonged 13:13 42:1,3 population promoter pcb 5:13,21 6:17 8:20 43:1 44:4 9:13 33:10 46:24 47:6,7,21 43:3 44:5,23 47:24 promptly 46:19 49:10 pcbs 4:11 6:3 8:2 28:9 32:23 position 3:15 24:15 38:5 43:5 44:8 44:17 50:25 pronounced 31:21 36:16 38:8 42:12 43:15 44:10 47:2,14,22 49:3,6 possession 2:19 proper 50:25 people possible protect 12:24 13:1821:21 23:15,17 25:16 48:19 11:13 protocol 20:24 public 1:1 2:5 9:4,8,12,18 10:25 11:5 15:7 38:19 50:18,25 50:25,25 published 17:1335:16,1845:2 48:19 pulmonary 13:24 purpose 37:23 41:22 put 23:10,15,18,25___________ q question 4:17 5:5,14,23 6:4,20 12:15 15:8 21:4,5 25:18 26:16,22 29:2,9 31:2 37:8 43:7,18,21 43:22 46:3,4,17,21,21 47:1 47:3 48:21 questioning 8:14 questions 1:1 2:143:3,7 28:11,18 33:1741:1243:1648:16 49:25 50:25 quite 6:4 37:17 r raised 29:9 ran 19:7 20:9 31:7 39:23,25 rate 35:3 rats 39:25 40:1 ray 14:1 reached 43:4 44:7 reacting 19:25 read 2:7 43:20,22 46:1 50:25,25 reading 33:19 realease 37:10 really 12:10 16:24 17:1 21:11 reason 18:15 50:25 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9892 [recall - show] recall remember reviewed saying 30:5,6,7 37:11,12 2:21,23,23,24 7:8,18,20,22 32:13 14:5 17:18 21:2 23:21 26:4 receipt 8:7,10,1326:13,13,14,19 reviewing 29:1741:8,10 50:25 27:531:1732:1535:11,19 28:20 says received 36:3 37:9 39:24 43:17 46:7 rice 2:12 37:3 43:1 44:3 10:20 remitting 1:1 50:25 school receiving 50:25 right 8:23,25 11:5 10:24 remove 4:5,8,15 6:9,15 9:2,7 10:17 schools recognize 16:13 10:20,23 12:14,15,18 15:20 42:6 28:23 36:20,23,25 38:13 repeat 17:2,6 19:2,6,9,10 24:15 scientific 39:4,1441:1,11,17 3:1 26:7 27:5 28:6 29:4 31:11 35:13 recognized repetition 32:20 33:4 34:8,11,11,15 scientist 12:17 13:1541:15 23:23 35:3,4,5,21,21,24 36:3 38:7 17:12 recollection repetitive 38:9 39:10 41:5 42:13 scientists 4:25 32:15 39:7 3:4 44:12 46:14,20 47:14 48:11 42:9,10,16 recommended report 49:6,7 scm 33:24 33:14,19 38:16 47:12 river 36:19 38:12 39:3 40:19 record reporter 49:2 scott 32:12 50:25 1:1 2:5 43:23 50:25,25 rough 2:20 45:12 records reporter's 7:9 seal 34:15 50:25 roughly 50:25,25 reduced reporting 8:1945:12 sec 50:25,25 1:1,1,1 50:25,25,25,25,25 roush 50:25 refer 50:25,25 1:1,1 2:10,15 3:5,10 5:8 section 50:25 represent 8:22 10:23 17:2 28:12 37:13 reference 2:16 33:20 36:21 43:18 48:14,17 seeing 37:13,1441:4 representative 50:8,22,25,25,25,25 22:24 26:16 35:11 refinery 1:1,1,1,1,1,1 roush's seen 23:25 represented 50:25 39:6,8 40:14 41:6,16 50:1 regard 1:1,1,1 routine self 4:10 5:20 11:2,20 15:2 16:4 representing 21:9 50:25 27:17,19 28:9 31:25 32:7 4:21 8:7 rsmo send 33:25 36:16 38:8 representings 50:25 12:1 31:14 regarding 8:11 rule sense 5:12 6:16 7:1 17:6 request 50:25 13:11 regardless 30:3 run sentence 6:21 research 14:9,14 15:10,12 16:5 42:25 44:3 registered 9:5 19:1021:1,1522:1639:22 set 1:1 2:4 50:25 responding 40:5 50:25,25 regulated 19:23 running share 49:14 result 31:7 44:21 reinvent 36:5 runs sheet 13:21 results 32:1 50:25,25 related 13:19 rutter sheets 4:3,4 5:13,20 6:2,3 8:1,1 retainer 1:1,1 5:4,22 6:19,24 15:3 50:2,25,25 9:12,13 10:15 13:22 15:21 42:19 16:6 20:11 27:1829:1 31:1 shipping 17:13 22:3,8,11 25:16 34:1 retire 40:15,19,21,25 41:10 43:6 24:24 46:17,19 50:25 3:17 43:14 48:16 49:24 50:25,25 short relating 9:15 42:11 relations 38:19 relative 50:25 release 37:9,10 retired 3:1948:11 return 50:25 returned 50:25 review 28:17 33:16 50:25,25 s sample 11:23 satisfactory 431 443 saw 35:1241:3 11:18 shorthand 2:4 shot 39:19 show 28:13 31:24 36:18 38:12 39:2 40:10 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9893 [sick - think] sick 26:25 side 8:14 45:24 sides 24:9 signature 50:25,25,25,25,25 signed 2:7 50:25,25 significance 33:2 significant 33:21 35:3 silica 14:2 simple 20:5 sincerely 50:25 sir 3:9 12:12 48:14 situation 10:13 six 8:19 size 15:21 46:12 skip 41:18 small 15:24 25:22 31:10 smoking 34:9,14 solely 17:6 solution 31:13 solvent 25:24 somebody 10:7 14:6 16:21 26:24 30:17 36:5 sorry 5:16 12:20 43:19 sort 30:11,13,14 sound 3:4 sounds 13:24 source 49:8 south 26:17 span studies (cont.) tamewitz 21:19 21:14,14 22:16,25 36:12,13 1:1,1,1,1 specialist 39:24 46:24 49:13 taught 10:8 14:6 study 12:6 14:4 specialty 12:3 13:8,10,11 14:25 15:1 taxed 22:10,11 15:1,2 16:3,3,4,5,20,20,22 50:25,25,25,25 specific 16:23 17:13,15,15,22 18:3 teach 5:1 33:9 45:23 46:15 18:3,8,9 19:3,8,11,22,25 25:7 specifically 20:8,9,10,10,13,14,1721:1 teaching 39:24 42:25 44:2 21:6,7,8,9 23:20 29:21,24 24:20,21 25:8,10 speculation 29:25 30:3,6,12,16,22,23 tell 20:12 30:25 31:4,8 32:8 33:6 8:25 9:7,21,25 16:8 17:16 St 35:11,13,14 36:4 37:3 17:17 18:2 28:25 29:7 32:6 1:1,1,1,1,1 26:3 48:11 39:25 40:1,4,5 45:16,17,19 40:13 41:5,6,20 45:22 47:9 50:25,25,25,25,25,25,25,25 46:4,10 47:8,10,14,18 telling stamped 48:18 49:19 29:20 50:25 subacute tells standard 19:12,15,21 20:10,17 21:3 16:21 14:24 16:2 subject temporarily stapled 10:4,4 11:6 20:4 50:25 29:2 32:3 submitted ten staplings 32:25 41:24 29:5 subscribed term start 50:11 11:1849:13 13:6 29:13 subsequent terms started 38:15,21 15:9 20:16 24:6,12,16 subsequently testified starting 38:24 4:9 6:6,9 7:4,13 8:17 27:14 23:16 subspecialty 28:7 48:18,22,23 49:5 starts 21:25 testify 22:7 suffered 50:25 state 14:11 testimony 1:1,1,1 50:25,25,25,25 suggest 6:12 36:4 44:19 45:16,22 statement 38:4 46:9,15 49:18 50:25 18:4 21:25 37:10,14 38:4 suite testing 44:9 1:1,1,1 50:25,25,25 12:6 13:18 statistically suppose tests 33:21 35:2 26:15 27:8 14:1,3,10 39:21 stay sure tetra 21:21 24:23 2:24 13:4 20:3 21:13,17,20 23:9 Stephen 22:13,14 39:2041:15,19 tetraethyl 1:1,1 45:7 49:7,20 23:10,13,15,25 24:6,25 stethoscope sworn texas 13:21 14:1 1:1 2:11 50:11,25 2:21 stipulated t themself 2:1 taken 36:14 stop 1:1 2:3 30:16 50:25,25,25 thing 9:7 street talk 4:185:1 12:9 19:1347:5 7:3 21:2 46:13 47:5 things 1:1,1 50:25,25,25,25,25 students 11:7 talked 20:21 38:25 41:25 talking 3:2 29:24 31:6 34:8 45:1 think 5:5 6:5 7:2 8:5,21 9:6 10:17 studies 4:3 11:1 12:25 14:13,16 15:1,5,9 16:9 17:3 18:13,22 20:23 27:7 36:15,16 37:15 10:19 17:3 26:4,18 31:20 32:9 34:18 35:5,19 36:17 15:10,12,14 16:10,10,15,17 45:19,23 46:5,11,18 47:19 37:25 38:23 39:13,16 40:9 17:4,6,8,8,10 18:15,18,24 40:12 44:23 45:7,20 47:15 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9894 [think - wsj] think (cont.) 48:13,20,25 49:1,21 thomas 1:1 thought 39:1941:1348:18 three 27:9 time 3:21 8:16,20 10:24 11:9,20 12:25 14:14,23 15:2,3,16 16:4,8,10,16,18,19 18:1,2 18:19,25 19:4,14,22 23:21 24:9,15 39:17 40:7 41:21 41:23 42:17 44:22 46:2 48:14 49:9 timely 50:25 times 6:6 7:4,6,7,13 27:9 tips 40:22 today 13:3 told 25:12 tolerate 19:17,1720:13,15,16 tolerates 19:21 20:20 tomorrow 43:13 tools 13:20,25 top 39:10 42:6 50:25 total 50:25,25,25 touching 50:25 tough 7:3 towers 25:1 toxic 9:15 13:7 toxicities 38:8 toxicity 5:12 11:2 37:13 toxicological 4:3 5:20 6:17,18 12:7,9 18:23 22:3 toxicologist 30:15 toxicology 30:22 training 10:25 22:1,2 transcribed 2:5 transcript 50:25,25,25,25 transcription 50:25 transcripts 50:25 transfer 37:2 trial 27:14 49:2 trials 48:23 tried 25:23 trisler 1:1,1,1,1 troubles 22:4 true 12:13 50:25 truth 50:25,25 try 3:1 20:2 trying 11:24 16:1,18 17:11 18:1 20:7 23:18 29:17,18 34:4 37:22 46:2 48:25 tulane 24:21 twice 27:9 type 14:24 15:11 34:1 38:19 46:13 types 11:1 33:9 typewriting 2:6 typical 11:9 u ultimately 30:16 um 23:19 uncertain 49:8 understand 8:22 10:6 16:14,18 17:2,11 understand (cont.) 18:1421:1323:1225:18 28:1 29:16,18,25 34:22,22 37:5,17,22,23 40:2,4 41:8 46:1 understanding 23:2 university 9:3 12:2 unusual 25:23 29:14 ups 50:25,25 urge 43:6 use 13:20 usually 6:2 21:9 26:15 V vague 5:22 6:19 valuable 44:20 various 11:2 12:7 14:10 15:11 18:23 38:5 verbally 3:7 version 3815 versus 1117 193 visited 23:25 visits 24:3 vs 1:1,1 50:25 w waller 1:1,1,1 50:25,25,25,25,25 50:25,25 wann 1:1 2:4 50:25,25,25 want 21:10,15 31:3 35:9 40:15 42:22,24 43:24 44:2 wanted 33:8,13 34:8 41:13,14 49:7 Washington 37:25 wasting 24:9 watch 18:12 wayne 38:18 week 17:19 19:7 went 18:16 23:24 24:7 35:6 39:23 westinghouse 1:1,1,1 50:22,25,25,25 we've 16:14 36:15 46:23 whereof 50:25,25 wife 1:1,1 withers 38:18 witness 2:6,7,8 4:23 28:19 33:18 50:25,25,25,25,25 work 5:10 11:19 12:4 21:21 22:2 22:8 25:7,13,14,15 26:7 worked 24:9 30:10 32:19 34:21 35:2 worker 4:4 workers 9:23 10:9 23:8 29:22 46:10 48:1 working 9:11,11 11:8 22:1426:1,24 29:9 48:6,8 works 22:6 worrying 11:9 worse 38:3 write 17:17,18 writing 45:17 47:8 50:25 written 37:6 wrong 48:19 ws 39:12 wsj 39:17 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9895 [xyz - zack's] x xyz 10:7 y yeah 6:1 15:9 25:20 29:12 42:13 year 9:3 21:9,14,18 24:13 27:9 39:21 40:1,4 years 8:19 21:24 24:6 27:8 41:24 z zack 30:19 35:6,11,21,24 44:25 45:18 48:5,6,18 zack's 47:12 Roush, George M.D. (fmr Mons Medical Director) in BECHTOLD HARTOLDMONOOQ9896