Document k9npzROOLvKxwaJpBK6Mn16EV

14 16 1 1 Sayers 2 law firm called Pillsbury & Levinson. And 2 the -- as 1 understand the long-standing 3 he's in here also as part of my co-counsel 3 policy that Union Carbide will supply 4 in some other cases that I've got, and he is 4 counsel to former employees when they are 5 here to give me assistance should 1 fail in 5 asked to give testimony with respect to 6 my tasks. 6 matters that involve their employment at 7 I don't know who this young lady is. 7 Union Carbide, former employment at Union 8 and 1 don't know anybody else in here other 8 Carbide. 9 than those. But I'm glad to make those 9 MR. LANIER: Thank you for clarifying 10 introductions for you, Peter, either on the 10 it. II record or off; it didn't matter to me. 11 MR. WILL: Happy to do it. Ready to 12 MR. BICKS: That's very kind of you. 12 go? 13 Thank you. 13 MR. LANIER: I was bom ready. 14 MR. GOLDMAN: And I'm Michael Goldman, 14 MR. WILL: Would you swear the 15 also on behalf of Conwed Corporation, from 15 witness, please. 16 Chicago. 16 IAN C. SAYERS, called as a witness, 17 MR. BICKS: This nice lady that 17 having been duly sworn by the Notary Public, 18 Mr. Lanier referred to is one of our legal 18 was examined and testified as follows: 19 assistants, Lulanne Jacobs, who's going to 19 EXAMINATION BY 20 be helping us today. 20 MR. WILL: 21 MR. LANIER: Is he working for your 21 Q. Would you tell us your name, please? 22 law firm today or is she working for the law 22 A. Ian Christiansen Sayers. 23 firm of the fellow that's taking the 23 Q. And when were you bom, Mr. Sayers? 24 questioning, because it looks like she's 24 A. 10th of May 1939. 25 handing him stuff? So could 1 know who she 25 Q. So if my math is right, that makes you 15 17 1 1 Sayers 2 works for? 2 about 63 years old? 3 MR. BICKS: We all work together. 3 A. That's so. 4 MR. LANIER: Okay. Soallofy'all 4 Q. Where do you live? 5 represent this witness individually as his 5 A. 1 live in a small village called 6 individual lawyer or do some of you 6 Ribchester, not far from Manchester, in Lancashire 7 represent Union Carbide and some of you 7 in England. 8 represent this fellow? 8 Q. At one point did you work for 9 MR. BICKS: 1 think we're ready to go. 9 subsidiaries of Union Carbide in Europe? 10 Those are some of your favorite 10 A. Yes, 1 did. 1 1 cross-examination questions. II Q. During what time period did you do that? 12 MR. LANIER: No, I'm asking you. 1 12 A. From August 1964 through to July 1969. 13 would like to know as an appearance today 13 Q. And were there more than one subsidiary 14 who is appearing today as this man's 14 for whom you worked? 15 personal lawyer, and 1 am entitled to know 15 A. Yes, indeed. The London office, U.K., 16 that appearance. 16 and later UCBEL, Union Carbide Belgium Limited. 17 You expressed that you are, but now 17 Q. Mr. Sayers, during what period of time 18 you've told me that your coworker here is 18 did you work for Union Carbide U.K.? 19 helping this fellow, who never said he was 19 A. Between '64 and '67. 20 this guy's lawyer. And I need to know who 20 Q. And then you worked in Belgium from '67 21 is this guy's lawyer on the record. 21 through July of'69? 22 MR. WILL: That's fine. 22 A. That is correct. 23 For the record, both Mr. Bicks and I 23 Q. Are you the author of a document titled 24 are representing Mr. Sayers as well as 24 "Asbestos as a Health Hazard in the United 25 representing Union Carbide pursuant to 25 Kingdom"? SPHERION DEPOSITION SERVICES (212)490-3430 5 (Pages 14 to 17)