Document kmxZ7OovMkpDdRKq4G0OYOqv0

1 Q Are you aware of the existence of any of the 2 Chinese communications from Dr. Zhang? Page 119 3 A Yes, I am as a matter of fact. I was shocked 4 at the amount of correspondence there was and that 5 Mr. Praglin failed to discuss it the many times he said 6 there wasn't any. He had been presented apparently 600 7 pages of Chinese and yet he continues to say it doesn't 8 exist. I don't quite understand what he's talking 9 about. But he has all 600 pages. : 10 Q You got involved in the asbestos litigation in 11 the middle of 2001? ; 12 A It must be very close to that. 13 Q That's sort of the- beginning of the j 14 chronology? 15 A Perhaps. 16 Q You get a call from Darrell Grams at Ford? 17 A Yes, I did. 18 Q And you'd worked with Mr. Grams previously 19 when he was at Dow or working for Dow? 20 A He was outside counsel. 21 Q And you were involved with him at the Silicon 22 breast implant litigation? 23 A That's correct. 24 Q Mr. Grams calls you up and he says are you 25 interested in looking at some papers regard regarding : ESQUIRE DEPOSITION SERVICES (415) 288-4280