Document gVxVbxmQYgxMz7rEdM5oaBVN

254 1 Sayers 2 know. You hadn't identified yourself 3 before. 1 think everybody agreed everybody 4 would say what we're doing. 5 MR. EGILMAN: No problem, no problem. 6 MR. BROWNSON: Are we ready? 7 Q. Let me just go back and I'll direct 8 your attention to Exhibit Number 20. 1 wasn't 9 clear, had you ever seen this before? You had not; 10 correct? II A. No. It was impossible. 12 Q. Well, you wouldn't have seen it at the 13 time because you weren't working for Union Carbide. 14 A. That's right. 15 Q. My question is you've never seen it 16 since, have you. 17 A. No. 18 Q. One of the people who got a copy of this 19 is John Myers in King City. Do you know Mr. Myers? 20 A. By name only. 21 Q. Did you know him to be the manager of 22 the asbestos mining and milling facility in King 23 City, California? 24 A. I know that he was manager at some time. 25 and I can't recall whether he was manager during my 256 1 Sayers 2 other kind of asbestos dust? 3 A. 1 didn't. 1 hadn't got the knowledge to 4 make that distinction. 5 Q. So at least in your career you never 6 made a distinction between precautions to be made 7 breathing Calidria asbestos dust versus any other 8 kind of asbestos dust? 9 A. No, 1 didn't. 10 Q. You recognized that the regulations in II effect in England in any event treated them all the 12 same? 13 A. That is so. 14 Q. Now, earlier today you were shown and 15 there was quite a bit of questioning about a report 16 by the Mellon Institute that Union Carbide had done 17 back in 1966. 18 Are you aware there was a second study 19 done at the Mellon Institute in 1970? 20 A. No, I'm not aware. 21 (Sayers Exhibit 23, Mellon Institute 22 report on Calidria Asbestos-Resin Grade RG 23 244, marked for identification, as of this 24 date.) 25 Q. I'm going to show you what's been marked 255 1 Sayers 2 duration with Carbide. 3 Q. You recognize that name -- 4 A. Yes, 1 do. 5 Q. -- as a man out -- in charge in some 6 capacity out at the Union Carbide asbestos mine in 7 King City? 8 MR. WILL: Objection. He didn't specify 9 as to what time. 10 Q. At the time you had worked at Union 11 Carbide, you had seen the name at that point. 12 hadn't you? 13 A. Yes. The name is familiar. 14 Q. At the bottom of the second paragraph of 15 this letter. Dr. Demehl says, "1 conclude that the 16 same precautions to avoid breathing asbestos dust 17 must be observed whether the dust be from Calidria 18 asbestos or from standard long fibre form." 19 Do you see that statement? 20 A. Yes, 1 do. 21 Q. And when you -- going back to when you 22 were calling on these paper mill customers over in 23 England in the 1960s, did you ever make any 24 distinction to them about precautions to be taken 25 when breathing Calidria asbestos dust versus any 257 1 Sayers 2 as Exhibit Number 23, which is a report of a study 3 at the Mellon Institute ofCamegie-Mellon 4 University entitled "Calidria. Asbestos-Resin Grade 5 RG 244 Tracheal Insufflation of Rat Lungs with 6 Interpretation of Pathology after 30, 60, 90 and 7 120 Days," and just ask you if you have ever seen 8 that. 9 A. No, I've never seen that. 10 Q. Again, until -- well, at your meeting II with Mr. Will or at any other time leading up to 12 your deposition today, were you ever shown that? 13 A. 1 believe not. 14 Q. Were you ever told about it at any lime 15 leading up to your deposition today, told about it? 16 MR. WILL; In answering that question. 17 don't relate to him anything that anybody 18 told you yesterday. 19 THE WITNESS: Right. 20 1 was not told about it at all. 21 MR. BROWNSON: Thank you, Mr. Sayers. 22 That's all the questions I have for you now. 23 1 may have some more later. 24 THE VIDEOGRAPHER: The time is 3:33 25 p.m. We're going off the record. SPHERION DEPOSITION SERVICES (212)490-3430 65 (Pages 254 to 257)