Document rB6v4085rbd6ZoK3M4D4x3DEG

354 1 Sayers 2 Q. Do you see that? The first sentence you 3 wrote says, "There has been a general recognition 4 that Union Carbide has shown a praiseworthy 5 responsibility in offering a pelletised product." 6 Did you write that? 7 A. 1 did. 8 Q. Do you see that statement appearing 9 anywhere in the 1969 toxicology report? 10 MR. BROWNSON: Objection. The document II speaks for itself. 12 A. No, 1 don't. 13 Q. Turning your attention to page 6, you 14 wrote in paragraph 2.3: "All manufacturers are 15 aware of the probable toxic hazards, especially 16 those already utilising asbestos in some of their 17 products." 18 Did 1 read that correctly? 19 A. You did. 20 Q. Do you see that statement appearing 21 anywhere in the 1969 toxicology report? 22 MR. BROWNSON: Objection, leading. The 23 document speaks for itself. 24 A. No, I do not. 25 Q. Mr. Sayers, do you think that, in 356 1 Sayers 2 found that information if they had looked for it? 3 A. In they looked hard enough, yes. 4 Q. You were asked a question earlier about 5 something 1 think it was phrased as the world's 6 largest industrial disaster. Do you remember that 7 question? 8 A. I do indeed. 9 MR. WILL: I'm stating for the record. 10 by asking this I'm not waiving my prior 11 objection to that line of inquiry. 12 Q. But when that question was asked of 13 you, what was your understanding to what Mr. Polk 14 was referring? 15 MR. BROWNSON: Well, the - I object to 16 the question as leading and also asking for 17 the state of mind of Mr. Polk. I object on 18 those bases. 19 Q. When you answered the question, to 20 what did you think the question was addressed? 21 A. I think he was trying to get -- 22 MR. BROWNSON: Objection, leading. 23 A. -- to get me to utter the words "Union 24 Carbide." 25 Q. What incident did you think he was 355 1 Sayers 2 looking at it today, that -- well, let me ask you a 3 different question. 4 Do you feel that from a medical 5 perspective you're in a position to evaluate 6 whether or not the 1969 toxicology report was 7 accurate or inaccurate as to what the state of 8 medical knowledge was at that point? 9 A. Well, with the preface that 1 was -10 never have been a medical person, it seemed to sum 11 up the -- 12 MR. BROWNSON: Objection. 1 object this 13 is without foundation. Go ahead. 14 Q. Go ahead. 15 A. The state of knowledge that 1 had 16 presented in my report. 17 Q. Were you relying on Dr. Demehl or other 18 people to make that assessment? 19 A. Yes, 1 was. 20 Q. Now, the information that you included 21 in your report. Exhibit 1, was that publicly 22 available information? 23 A. It most certainly was, yes. 24 Q. Are you aware of any reason why anyone. 25 customer of Union Carbide, anyone, couldn't have 357 1 Sayers 2 referring to? 3 MR. BROWNSON: Objection, leading and 4 seeking the state of mind of Mr. Polk, 5 without foundation. 6 A. That was reference to a serious 7 accident that occurred in India a few years ago. 8 Q. Do you remember the name of the town? 9 A. Bhopal. 10 Q. Do you personally have any knowledge 11 about what actually caused that accident? 12 A. No, none whatsoever. 13 Q. Do you know anything about it other than 14 Union Carbide or some subsidiary owned the 15 facility? 16 A. That's the extent of my knowledge. 17 Q. Is that the context in which you 18 answered Mr. Polk's question? 19 A. Exactly. 20 Q. You were asked some questions about 21 whether you were ever given the Mellon report. Do 22 you remember that? 23 A. Yes. 24 Q. In 1966 what was your title with the 25 company? SPHERION DEPOSITION SERVICES (212)490-3430 90 (Pages 354 to 357)