Document gawYdnzkXwb5aZEy6R8kobBwV

190 1 Sayers 2 Q. Was there any discussion that Union 3 Carbide has witnesses or experts who might testify 4 that Union Carbide Calidria asbestos might not be 5 as toxic as other kinds of asbestos? 6 A. Are you talking current knowledge or 7 past knowledge? 8 Q. Current knowledge. 9 A. That has been imparted to me. 10 Q. Who imparted that to you? II A. Mr. Bicks. 12 MR. WILL: Wait. I'm going to interpose 13 an objection here because at a certain point 14 an attorney-client relationship was 15 established. 1 think we have not gotten to 16 that point. 17 MR. POLK: ldisagree, (disagree. 18 The testimony of the witness is the 19 attorney-client relationship was established 20 yesterday. If the conversation took place 21 prior to yesterday, then I'd like to have 22 that. 23 THE WITNESS: That was yesterday. 24 Q. So let's establish that. Yesterday 25 you and Mr. Bicks had some discussions about 192 1 Sayers 2 was the content of this document. 3 Q. Did he show you any of the material from 4 Conwed in Minnesota? 5 A. No. 6 Q. Did he tell you anything about Conwed's 7 plant in Colquet, C-O-L-Q-U-E-T, Minnesota? 8 A. No. 9 Q. Had you ever heard of Conwed before you 10 met Mr. Will? II A. No, I hadn't. 12 Q. Was there any discussion at all between 13 you and Mr. Will or between you and anyone 14 representing Union Carbide before yesterday about 15 the fact that Union Carbide claims it was dusty in 16 the Conwed plant? 17 A. No. 18 Q. Was there any discussion between you and 19 anyone from Union Carbide or representing Union 20 Carbide about the issue of whether or not the 21 workers in the Conwed plant wore masks or 22 respirators? 23 A. No, not at all. 24 Q. Now, as long as I'm on that topic, let 25 me ask you a little bit. ,lf we go back to when you 191 1 Sayers 2 current knowledge? 3 MR. WILL: Now the problem is he said 4 the conversation was yesterday. The 5 privilege is attached, and therefore you're 6 not entitled to ask anything further about 7 it. 8 Q. Before yesterday did anyone 9 representing Union Carbide or from Union Carbide 10 tell you anything about what their thinking was II concerning current knowledge of Calidria 12 asbestos -- 13 A. No. 14 Q. -- or asbestos health hazards? 15 A. No. 16 Q. Now, when you met with Mr. Will at the 17 airport in England, did you question him about what 18 position Union Carbide was taking in the case? 19 A. Generally, yes. 20 Q. Do you recall what it was that you asked 21 him? 22 A. Nothing in great detail, no, 1 don't. 23 Q. Do you recall what it was that he told 24 you? 25 A. Not appreciably, no. The focal point 193 1 Sayers 2 worked for Union Carbide U.K. -- can 1 just call 3 that Union Carbide for discussion? 4 A. Yes. 5 Q. Back at the time you worked for Union 6 Carbide in the 1964 to 1967 time frame, when you 7 would visit these Union Carbide customers in 8 England, would you actually go into their paper 9 mills and look around? 10 A. Yes, as a prelude to a trial you would 11 often go to the machine and see how the asbestos 12 material could be best added to the papermaking 13 slurry. 14 Q. As 1 understand it, the customers that 15 you called upon in those years on behalf of Union 16 Carbide were principally papermaking companies; is 17 that right? 18 A. In the early days that is true. 19 Q. Can you tell me about how many 20 papermaking companies you called on on behalf of 21 Union Carbide in England? 22 A. We concentrated on the paper that 23 contained high-priced fillers, primarily titanium 24 oxide. So that limited the number of mills to 20, 25 25. SPHER10N DEPOSITION SERVICES (212)490-3430 49 (Pages 190 to 193)