Document gbxqyLymn8LrJK0xw8wGJ7p13

78 1 Sayers 2 Q. So you recommended that Union Carbide 3 participate? 4 A. 1 did. 5 Q. Did Union Carbide in fact participate? 6 A. Yes, they did. 7 Q. Who supervised the trace element 8 analysis? 9 A. Dr. Fred Mumpton. 10 Q. Were those results then conveyed to the II PRU? 12 A. Yes, they were. 13 Q. Who did that? 14 A. 1 took the results personally to 15 Penarth. 16 Q. And gave them to whom? 17 A. To Dr. Timbrell. 18 Q. Do you remember when it was that you did 19 that? 20 A. I believe it was November 1967. 21 Q. When you visited Dr. Timbrell, did you 22 have any discussion with him on the subject of 23 chrysotile and the cause of cancer? 24 A. Yes, 1 do recall a discussion on that 25 subject. 80 1 Sayers 2 very rapid. 3 Q. Did he say anything about what impact 4 that the geometry and the elimination had on the 5 ability of chrysotile to cause cancer in the real 6 world? 7 MR. LANIER: Objection to form. 8 MR. BROWNSON: Objection, leading. 9 hearsay and without foundation. 10 A. That this reduced tumor development in It rats. 12 Q. Did you pass the information that you 13 had obtained from Dr. Timbrell on to anyone at 14 Union Carbide? 15 A. Yes. I wrote a report, as usual. 16 Q. What was that report called? 17 A. I can't remember the exact title. 18 Q. Just generically what were the types 19 of -- that type of form called? 20 A. Call report. 21 Q. C-A-L-L? 22 A. Correct. 23 Q. Was that something that was handwritten 24 or typed up? 25 A. They were handwritten by me. 79 1 Sayers 2 Q. What do you recall Dr. Timbrell saying 3 to you at that time? 4 MR. LANIER: Objection to form. 5 MR. BROWNSON: Objection, hearsay. 6 Second of all, we don't know Timbrell is a 7 medical doctor. I'm not sure he is. 8 Q. Go ahead, Mr. Sayers. You were 9 telling us what Dr. Timbrell told you. 10 A. 1 remember that he told me that he II discovered that chrysotile tend to be curved in 12 geometry, which was very interesting. 13 Q. What impact did that - what was the 14 significance of that, as he related it to you? 15 MR. BROWNSON: Objection, hearsay, also 16 lack of foundation. 17 MR. LANIER: Objection. 18 A. That the fiber was less likely to 19 penetrate the trachea of a human being. 20 Q. Did he say anything else about -- that 21 he had discovered about chrysotile? 22 MR. BROWNSON: Hearsay, lack of 23 foundation. 24 MR. LANIER: Objection. 25 A. The elimination rate of chrysotile was 81 1 Sayers 2 Q. Do you still have that today? 3 A. Call reports are common across the 4 industry. 5 Q. No, I mean, did you personally keep a 6 copy of the call report that you wrote? 7 A. No. 8 Q. After November of 1967 did you 9 personally have any further communications with 10 Dr. Timbrell? II A. No, I didn't. 12 Q. Now, what I'd like you to do is look in 13 your report. Exhibit 1, at Figure 1. 1 believe 14 it's page 10 of the report. 15 A. That's right. 16 Q. Would you tell us what that figure 17 shows? 18 A. Well, it shows that rats were subjected 19 to dust clouds of equivalent masses and that very 20 clearly the amount of dust picked up -- chrysotile 21 dust picked up by rats was significantly less at 22 the outset and the elimination rate, as is 23 evidenced by the grading of the curve, is much. 24 much more rapid. 25 Q. Could you hold that chart up so we can SPHERION DEPOSITION SERVICES (212)490-3430 21 (Pages 78 to 81)