Document zzgV64BXKDm8GVR2G7jZMr5zB

Page 3363 1 Q You are not a member of what is known as the 2 ACGIH, although you are familiar with that 3 organization? 4 A That is correct. 5 Q You have had no formal education or training 6 in industrial hygiene, correct? 7 A No formal education, that is correct. 8 Q Is it true that you have never testified at 9 the request of any plaintiff's lawyer about the 10 history of the knowledge of asbestos and hazards? 11 A That is correct. 12 Q That has been primarily at the request of 13 defendants? 14 A It has. 15 Q That request was made of you sometime in 16 1978? 17 A The time I was first asked to review the 18 older literature, prior to the time I got into lung 19 disease, yes. 20 Q Prior to that request -- first of all, that 21 was completely in connection with litigation; is that