VO I Pp. 1-87 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION MARY A.

FILENAME: Flintkote (FLK) DATE: 1984 DOC#: FLK080 & 081 DOCUMENT DESCRIPTION: Legal - Exhibits from Deposition of Arthur R.

As you can see in this 50-state summary, doctors, local governments, bars, boards of directors, and volunteers lead the list of those getting concerted help from state legislators by a combination of political clout and compelling horror stories.

Tha corraapondlng oortallcy in the UK study, which waa preferentially deacrlbed aa bronchitis, la laas than axpactad (SMI S2) aa la tha mortality from pneumonia (SMI SO) and other reaplratory dlaaaaaa (SKI 4$) in tha US study* Thara la no conalataot evidence that tha mortality frou emphysema or bronchitis was spaclfleally occupational and it seems possible that tha reported excess la tha US study Is aa artefact due to nosological diffleultlte In the use of tha 7th revision of the International Classification of Diseases* levlew of tha nasties data oow available relating to tha long tarn health of non oceuaptloaally exposed to VC leads to two clssr conclusions.

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R&S 002975 1 Hillhouse Site PO Box No 4 Thornton - Cleveleys Blackpool FY5 4QD Telephone (0253) 861 63Direct line (Secretary '861370) (0253) 861444 Switchboard 6 632Extension Number Facsimile (0253) 864687 Telex 67483 Iciplast Clvlys Imperial Chemical Industries PLC MEDICAL DEPARTMENT CONFIDENTIAL To all recipients of ASL Register Your ref Our ref 3B/BGS Date 6 March 1986 Dear Colleague REGISTER OF CASES OF ANGIOSARCOMA OF THE LIVER DUE TO EXPOSURE TO VINYL CHLORIDE - REVIEW DATE 1 JANUARY 1986 I regret that due to a typing error an amendment is needed in Table 1 (Page 30) of the Register recently sent to you.

Fm..n MMEMsmimm, asasras gohbql anawt 3W OOTOORISE SKFBK GPFXGB 3*3B 1984 CONFIDENTIAL 005575 Field Administration Asbestos Control Program Contents 1.

ISSN 0355-3140 n Volume 14, number 2, April 1988 CONTENTS Reviews 61 Effects of exposure lo vinyl chloiliide: An assessment of the evidence Sir R Doll Original articles 79 Associations between several sit is of cancer and fen types of exhausl and combusllon products: Results Iron a case-relerenl study in Montreal J Siemiatycki, M Grin.

Jennings Gregory, at the 7 law offices of Fite & Miller, Anniston, Alabama 8 on the 1st day of December, 1999. 9 10 11 IT IS FURTHER STIPULATED AND AGREED that 12 the signature to and the reading of the 13 deposition by the witness is waived, the 14 deposition to have the same force and effect as 15 if full compliance had been had with all laws and 16 rules of court relating to the taking of 17 depositions. 18 19 20 IT IS FURTHER STIPULATED AND AGREED that 21 it shall not be necessary for any objections to 22 ho roscle by counsel to eny questions, except es to 23 form or leading questions, and that counsel for 6 FOSHEE & TURNER COURT REPORTERS 1 the parties may make objections and assign 2 grounds at the time of trial or at the time said 3 deposition is offered in evidence or prior 4 thereto. 5 6 7 IT IS FURTHER STIPULATED AND AGREED that ADAD21-007652 HARTOLDMON0036120 8 the notice of filino of the deposition is waived. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 7 FOSHEE & TURNER COURT REPORTERS 1 STATE OF ALABAMA, CITY OF ANNISTON, O 3 9:10, A.M., 4 5 TOM LACKEY, 6 having been first duly sworn, was examined and 7 testified as follows: 8 9 COURT REPORTER: Usual stipulations 10 okay?

Scard J Work Environ Health 14 (1988) 61--78 ki 608 644 (redactory number .00 air mail ddress above, tged issues unless t Clearance Center nternal or personal cr's Transactional ge. is paid directly ons that have been fee code for users Effects of exposure to vinyl chloride An assessment of the evidence by Sir Richard Doll, FRS' ^ DOLL R.

Jennings Gregory, at the 7 law offices of Fite & Miller, Anniston, Alabama, 8 on the 21st day of October, 1999. 9 10 11 IT IS FURTHER STIPULATED AND AGREED that 12 the signature to and the reading of the 13 deposition by the witness is waived, the 14 deposition to have the same force and effect as 15 if full compliance had been had with all laws and OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036676 16 rules of court relating to the taking of 17 depositions. 18 19 20 IT IS FURTHER STIPULATED AND AGREED that 21 it shall not be necessary for any objections to 22 be made by counsel to any questions, except as to 23 form or leading questions, and that counsel for 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 6 FOSHEE & TURNER COURT REPORTERS 1 the parties may make objections and assign 2 grounds at the time of trial or at the time said 3 deposition is offered in evidence or prior 4 thereto. 5 6 7 IT IS FURTHER STIPULATED AND AGREED that 8 the notice of filing of the deposition is waived. 9 10 11 12 13 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036677 14 15 16 17 18 19 20 21 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 7 FOSHEE & TURNER COURT REPORTERS 1 STATE OF ALABAMA, CITY OF ANNISTON, 2 OCTOBER 21, 1999, 3 10:00 AM., 4 5 JERRY SANFORD, 6 having been first duly sworn, was examined and 7 testified as follows: 8 9 COURT REPORTER: Usual stipulations 10 okay?

DuPont objects to Plaintiffs definition of "Defendant", `"You", "Your", and "Your company" to the extent that it includes "subsidiaries, foreign subsidiaries, foreign subsidiaries of predecessors, and/or affiliates" because the definition is overbroad and seeks information that would be irrelevant and not calculated to lead to the discovery of admissible evidence in this case.

DuPont objects to Plaintiffs' definition of "Defendant", "You", "Your", and "Your company" to the extent that it includes "subsidiaries, foreign subsidiaries, foreign subsidiaries of predecessors, and/or affiliates" because the definition is overbroad and seeks information that would be irrelevant and not calculated to lead to the discovery of admissible evidence in this case.

REVIEWS Stand J Work Environ Health 14 (1988) 61--78 f I Effects of exposure to vinyl chloride RECEt UtE'ff An assessment of the evidence '* m by Sir Richard Doll, FRS*1 X NEVEIUSKt f l JDOLL R.

w / Y >-A, s ^ I I ^ EY W O R K PRODUCT A TTO R N EY-O JEN T PRIVILEGE MONSANTO COMPANY Environmental Policy Staff SPECIAL REPORT ON PENTACHLOROPHENOL PRODUCTS/PROCESSES INFORMATION FOR USE IN LITIGATIONS Report No.