Document zOpYkpLkQ50Vxk5M4xO2rZO7

y. 58 1 Sayers 2 Q. I'll go about it a little bit J differently. 4 A. Okay. 5 Q. During what period of time, as reported 6 in the article, were the people that developed 7 mesothelioma exposed to asbestos? 8 A. Do you mean how long or -9 Q. During what years. 10 A. What years, yeah. I'm finding that hard 11 to remember. 12 Q. They indicate it was over 50 years. 13 MR. BROWNSON: Object to form. 14 A. Yes, as it says. That's right. 15 Q. Let me turn your attention, Mr. Sayers, 16 to your report at page 4. 17 A. Yes. 18 Q. You indicated that Union Carbide had 19 been promoting the sale of Coalinga asbestos for 20 just over two years; is that right? 21 A. That's right. 22 Q. Your report was written in May of '67? 23 A. '67, yes. 24 Q. So when did Union Carbide then begin 25 promoting Coalinga asbestos? 60 1 Sayers 2 what did you draw from those statements? 3 A. That really there were no concrete 4 answers available at that time. 5 Q. That was October of'65? 6 A. That's right. 7 Q. 1 f we look in your report -- 8 A. Yes. 9 Q. -- at page 7. 1 read to you earlier in 10 paragraph 3.1.3 where it says the Pneumoconiosis II Research Unit "are currently attempting to seek a 12 solution to the problems of the aetiology of 13 mesothelioma, and also to discover whether only one 14 type of asbestos is responsible for the development 15 of these tumours"; is that correct? 16 A. That is correct 17 Q. And again, what interpretation did you 18 put in 1967 on this information that you had been 19 given from the Pneumoconiosis Research Unit? 20 A. That the work still continued. They 21 hadn't at that time reached any concrete 22 conclusions. 23 Q. What impression did you personally form, 24 you personally, from what you had read and heard 25 from the people you talked to regarding the 59 1 Sayers 2 A. The first mill trial took place in '65. 3 Q. To your understanding none of the people 4 in that article were exposed to Calidria? 5 MR. LANIER: Objection to form, 6 A. It wasn't Calidria asbestos; that's 7 for sure. 8 Q. In the Sunday Times article, 1 want to 9 direct your attention to what's actually the inner 10 pages. 1 think it's page 3 of that. There is a II statement there. It says, "An enormous amount of 12 experimental work on the biological effects of 13 asbestos has been going on quietly at the Medical 14 Research Council's pneumoconiosis unit at Cartiff, 15 where Dr. Wagner now works." 16 Is that correct? 17 A. That is so. 18. Q. Later on down it says, "Some of the 19 current studies are designed to find out which 20 variety of asbestos is the most noxious and the 21 minimum dose required to provide malignant 22 changes." 23 Is that correct? 24 A. Correct. 25 0- If we look as a layperson reading this. 61 1 Sayers 2 question of whether chrysotile asbestos could cause 3 mesothelioma? 4 A. That was less clear. The major felon 5 seemed to be chrysolite. That was well-reported. 6 Q. Did anybody suggest to you, among the 7 people that you talked with, that Union Carbide's 8 Coalinga product could cause mesothelioma? 9 MR. LANIER: Objection to form. 10 MR. BROWNSON: Objection, hearsay. 11 also leading and without foundation. 12 A. No. 13 Q. None of the dockers you talked to 14 suggested that? 15 A. No. 16 MR. LANIER: Objection to form. 17 MR. BROWNSON: Same objections. 18 A. Nobody could have known at that time. 19 MO MR. BROWNSON: I'm going to ask that the 20 answer be stricken as non-responsive. 21 Q. Let me ask you this differently. When 22 you spoke with Dr. Timbrell and the people at the 23 Pneumoconiosis Research Unit, did the topic of the 24 cause of mesothelioma come up? 25 A. 1 believe it did. SPHERION DEPOSITION SERVICES (212)490-3430 16 (Pages 58 to 61) j * I