Deposition 3 - deposition of doctor in products liability case - Part 4

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BY MR. GLOOR:

Q What time is that? Give me a year, if you can, roughly.

A Probably the beginning of 2003, end of 2002.

Q And whatever con -- whatever observations you were making about your patient population had not brought you to that concern, suspicion, conclusion, opinion prior to 2003?

MR. McCOY: Well, I think he had already stated -- You answered that part. He can answer, if he can.

THE WITNESS: You see, the problem in our clinic is that the patients have already been preselected by virtue of the medical system. They had to know there was something wrong with them, they had to go to a doctor, and they had to have a diagnosis of Parkinson's to end up in our clinic.

To then go back and say, well, how many of those guys were welders begs the question, well, how often does parkinsonism occur in welders? We don't know. We know how often a diagnosis of Parkinson's disease is associated with welding.

When we were down in the Gulf, what we became aware of is most of these guys never go to a doctor. Most of them accept a lot of the symptoms as the normal part of the job because that's just the culture of the job.

And even when they went to the doctor, they got the wrong diagnosis because the nature of the tremor is such that in many of them, the physician is obviously confused by whether it's an action tremor or a parkinsonian tremor.

BY MR. GLOOR:

Q In terms of your patient population, --

A Yes.

Q -- what year -- what years were you first aware that there was a difference of significance between the incidence or prevalence -- again, whatever word is correct -- of neurological problems among welders compared to the population in general?

A Probably not until 2002, 2003.

Q Let me go back, and I'll revisit one issue again, and if I have no success, I'll move on.

I'm not an epidemiologist, Doctor, but is there something called a bias which is important in drawing conclusions based on what you study?

A Of course.

Q And I'm aware of a phrase called a selection bias. I've been told there's something called an ascertainment bias. Are there other biases that someone should be concerned about before he or she drew conclusions about what they were studying?

MR. McCOY: Object to foundation because, I mean, your question presumes he has an understanding of selection bias, ascertainment bias, recognizes those. I mean, he can answer.

THE WITNESS: I have talked to enough people about this to know that I don't think like an epidemiologist, and that to try to control all the biases that come into soliciting people for a medical screening is beyond my expertise. So --

BY MR. GLOOR:

Q But you're aware of the idea that -- I'm going to show you a picture in a second, but, I mean, you are aware of the idea that if there is a selection bias in the group you look at, that can affect conclusions that can be drawn from examination of that group, correct?

A Sure. It can skew your data.

Q And you are aware that all of the people you looked at, I think, in Gulf Coast were referred by lawyers, correct?

A No, that's not true.

Q Lawyers or unions who are working with lawyers?

A Well, it ends up -- they ended up coming from a whole bunch of strange locations. Many of them came in -- Well, I suppose unions -- Yeah, that would be pretty much all-inclusive, unions, unions working with lawyers, or lawyers. Yeah, that covers the gamut.

Q Doesn't that have the potential to bring about a bias in the group that you are looking at that might make conclusions, based on that group, skewed or risky at best?

A I think that's purely -- that's entirely speculative on the part of the person who analyzes how that was done. Some people say there's probably no bias; other people say that there's tremendous bias. I think it depends on the bias of the person who's analyzing the bias.

MR. GLOOR: I'm going to show -- You've seen that before. Would you just mark that as an exhibit, please.

THE WITNESS: Can I see it?

MR. GLOOR: Yeah, absolutely.

THE WITNESS: Oh, is that Milwaukee?

MR. McCOY: Yeah.

THE WITNESS: Is that the one on 43 or 45?

MR. GLOOR: I don't know where it is.

THE WITNESS: I heard about this one.

MR. GLOOR: Why don't you mark this one as an exhibit. It's a copy. I'll be quiet so you can actually do it.

THE WITNESS: The ones in Texas are much worse.

MR. McCOY: I think the defense attorneys put that one up, actually.

MR. GLOOR: She can't mark this as an exhibit till we're all quiet.

THE WITNESS: Okay.

(There was discussion off the record.)

(Exhibit 3 marked for identification.)

BY MR. GLOOR:

Q Let me show you Exhibit No. 3. You have it in front of you, Doctor.

A Yes.

Q It's the same thing. Okay. And that is an ad in Wisconsin seeking people to call who may have been -- think they might have been injured by welding rods, correct?

A It's kind of an ambiguous ad, I think; don't you think?

Q No, I don't think there's anything ambiguous about it at all, 1-800-INJURED.

A Do you mean hit over the head with a welding rod, smacked across the back with a welding rod? It doesn't make --

Q Can you and I agree that if people respond to ads, whether they're like Exhibit 3 or other ads that I know you've seen down in the south, that that has the potential for creating a selection bias among the people you're going to study?

A I assume it does, but I have no idea what it would be.

Q If the people who are sent to you and that you are examining were only those people who were obtained through lawyer advertising, would that concern you at all in terms of the conclusions that could be drawn from the group you were studying?

MR. McCOY: Let me object again. Are we talking now about just general principles, statistical concepts, and selection, or are we talking about the Gulf Coast study? I'm not clear on your questions. But subject to that, he -- he can answer.

THE WITNESS: Well, I mean, of course this is a concern, and that's why we try to obtain information about how the individuals were solicited, who contacted -- the word “solicited” was objectionable to most people -- how they were contacted, and I was confused because some of the people would come in and tell me about a litany of things about headache and double vision and ringing in their ears and tingling in their back, and it's, you know, like great, but like what's that got to do with why you're here? And it was based on what they had read. It was -- This is the list of what was supposedly being looked for. It was all-inclusive. It covered every ailment known to the human -- human frame.

And other people came in, and they said, oh, we don't know why we're here. And then I said, well, you must have had something wrong. And they said, no, the guy screened me, and he said there was something wrong with me, but I don't know what it was.

BY MR. GLOOR:

Q How did he get to the screener?

A Because the union told him to come in. They told everybody to come in. And -- and then other people came in, and I said, well, like, what's supposed to be wrong with you? I don't know. And I said, well, why are you here? Why did you come to this screening? They said, well, I got a letter, and I'm represented for asbestosis, I've got asbestosis, and I got this letter saying I had to show up for this exam, and I didn't realize it was an exam for something else. I don't know what they found.

And so the ultimate bias becomes, I think, impossible to determine, which is why we didn't claim that this was epidemiologic. We looked at the absolute numbers of cases and the age of onset.

Q If, hypothetically now, Doctor, there was bias in the selection of the group that you examined, if you assume that hypothetically, could you and I agree that it would be impossible to draw conclusions based on that particular group you studied?

A Um-hum.

Q Protocol. When you did the Gulf Coast study, did you have a written protocol?

A We had a written protocol for the exams and the questioning, yes, but -- yeah, but a written protocol for each step that was -- no, not for each step of the whole process.

Q Is protocol important for a study in order to be it -- the study to be one that someone can rely on?

A No. I think it -- You have to rely -- Because you got a tight protocol, you can still have terrible data. I think tight protocols are kind of nice things for Type A people who are submitting this as a grant proposal, where you have to explain every step of what you're going to do, or when you're using untrained individuals to do the work.

Q In the Gulf Coast, were there any videos taken in the Gulf Coast study, Doctor?

A Yeah, we have videos. They weren't systematically done, but we have videos of a selected group of patients.

Q Do you have them here?

A I'm sure we do. I mean, we've got -- Those have been subpoenaed under various other court orders before.

Q And they've been produced --

A Yes.

Q -- pursuant to subpoena?

A Yes.

MR. McCOY: And Judge Byron in this case said they don't have to be -- they don't have to be produced.

MR. GLOOR: When did he say that?

MR. McCOY: That was part of his ruling.

BY MR. GLOOR:

Q In any case, you have videos here of people you examined in the Gulf Coast study, correct?

A We have videotapes of people who are identified as having manganism here at the clinic.

Q But it was part of the group that you examined, correct, --

A Yes.

Q -- in the Gulf Coast study?

A Yes.

Q When you started doing the Gulf Coast study, what was your intent when you first started doing that? What was your intent of looking at the people?

A Well, it was to answer the question that got raised in the early ‘90s when we looked at the number of welders in the Parkinson's population and found that welders ident -- welders constituted a group of severe Parkinson's patients with very early onset disease.

The question then became how often does Parkinson's occur in welders? Because our observation had no meaning, at least I didn't think it did at the time.

And so the question was, if we just looked at a lot of welders, is Parkinson's disease a more common disease in that group? That was the -- that was the entire intent of the original involvement with this.

Q So the observations you were making, based on your clinic, in your opinion, had no meaning until you actually looked at the Gulf Coast group; is that --

MR. McCOY: Object.

BY MR. GLOOR:

Q -- an accurate statement?

MR. McCOY: Object to restating his -- his testimony.

THE WITNESS: Well, the problem in the clinic was that when we attempted to find where -- How would you identify how many welders there were in Milwaukee? And the answer was, boy, there's a hard one for you because it's an ubiquitous job. Is there a union that represents all welders? No. And so short of going door to door and asking if you have any welders in the building and can we look at them, there didn't seem to be any systematic way to do this.

In the Gulf, because of the fact that the major employer in a lot of those areas is an industry that employs welders -- And this was all discussed way before I got involved. In fact, it was the basis of the discussion. I said, this might be the place to try to answer this question, because if that's what most of the people do, maybe we can clarify the relationship, if one exists, by just looking at large numbers of people.

BY MR. GLOOR:

Q And as far as your patient population was concerned, am I correct in saying that that had no meaning because of the concerns you just talked about in terms of how many welders are there in Milwaukee or in Wisconsin?

A And being able to identify why people seek out a doctor. When we do screenings in the population, we find significant numbers of people who have Parkinson's disease who don't know they've got it. They have no diagnosis.

Q In terms of the screening down in the Gulf Coast, do you know whether or not those who were coming in to be prescreened or screened, I suppose, after they had made the first cut, were being paid?

A My understanding was nobody was -- was reimbursed to participate in the screening.

Q In terms of the form that was made -- And I'm talking about the Gulf Coast again, Doctor. In terms of the forms that were prepared, I've seen some of those forms, and there were check -- there were boxes to be checked. I think one was manganism; one might have been idiopathic Parkinson's disease. Do you recall that -- that setup on the form?

A The diagnosis area.

Q Diagnosis. Sometimes both boxes were checked. Did you ever look at someone and decide to check both manganism and idiopathic Parkinson's disease?

A No.

Q In your opinion, should it be one or the other in terms of what you're making as a diagnosis?

A Usually in a case where there was -- And, again, life should be so wonderful that we could make an absolute diagnosis in everybody. If there's ambiguity, we usually indicate that.

I don't remember ever seeing anybody with both boxes checked, but frequently it would be marked Parkinson's disease, which was always the default. Somebody had extrapyramidal symptoms, Parkinson's was the default, and then a comment would be next to it.

You were saying unable to clearly differentiate from manganism because some factors favor manganism, some favor Parkinson's, and neither predominant, and it's impossible to tell.

Q Did you make any attempt to evaluate the exposure a welder had as part of the Gulf Coast study?

A Other than years of exposure, no.

Q Other than years of working as a welder, you mean?

A Well, we talked about the type of work, location, ventilation, provision of respiratory protection, subjective assessment of work conditions.

Q Were those questions, like respiratory protection, type of ventilation, were those on the form?

A No. They're usually written in if there was an issue with them.

Q So if there was a concern about sufficiency of the ventilation, that would be written in?

A I mean, it wasn't always written in. I mean, a lot of cases poor ventilation is commented upon. That portion of information was being covered in a separate document that we did not have access to. When we saw the patients, we didn't have access to the information about their work. There's a detailed questionnaire that's been maintained about the type of materials and rods and whatever. I'm no -- I'm not a metallurgist; I don't know how to interpret it. The other data was from the first screening, which we never saw.

Q So the one data from the first screening we talked about before, you never saw that, and then there's also information about work environment and things like that you didn't see.

A And we -- And I -- We've talked about that, and I felt that that was not a smart thing to do, that I preferred to see the patient without any of that information and make a decision based on the examination because I thought it would introduce too much bias. It would be too hard to --

Q Did you think it was important at any point in time, up till the time you submitted the article for publication, to know what was on those two forms, the one the form at the prescreening, and the one the form about his work history?

A No.

Q His or her work history.

A No, I didn't think there was an issue.

Q Was the amount of exposure or the degree of exposure or, I guess, the severity of exposure important to any conclusions you might have reached on the Gulf Coast study?

A Only in the sense that the total number of years of exposure didn't appear to be as important as we initially thought. That some cases of very severe neurologic disease occurred in people who appeared to have fairly short exposures, but the more restricted the space was in which the work occurred, the more cases we seemed to be encountering.

Q How did you conclude whether someone -- you should check the box for someone with idiopathic Parkinson's disease or manganism?

A Well, in the, again, in the discussion of the paper, what we -- what we -- the way we approached this was from a literature and historical standpoint. We went back into the old literature going back to the turn of the century about what constitutes manganism in the early industrial reports and what constitutes Parkinson's, and what we came up with was kind of a weighed scale, like you would use for many dis -- Like the old scale for rheumatic fever, you needed certain -- a certain number of points that favored it to make that diagnosis.

So the presence of an action tremor, rather than a resting tremor, for instance, favored Parkinson's.

The presence of bilaterally symmetric disease, as opposed to unilateral isolated disease, favored manganism.

An age of onset under the age of 45, 50, was more likely to be manganism than not.

A minimum work exposure history of five years was felt to be mandatory. That less than that one would have difficulty assuming this was manganism, though I think that's probably generous.

And history of psychiatric disease pre-existing or concomitantly appearing with the appearance of movement symptoms was felt to be more likely that -- it was more indicative of manganism Especially depression we've weighed low, but manic-depressive disease we thought was certainly uncommon to occur at the age of 40. But at any rate, prominent psychiatric history seemed important in manganism, as opposed to Parkinson's.

A prompt and significant improvement with L-dopa was thought to be more likely to reflect Parkinson's than manganism.

A family history of Parkinson's disease had some positive weighing factors for parkinsonism.

And the presence of a peculiar sleep-wake cycle disturbance and night sweats -- night sweats and sleep fragmentation, without daytime sleeping, is -- was reported so frequently, even though we -- it's not a question you normally ask. That symptom is reported in such a high percentage of welders with neurological symptoms that I think it must have something to do with that syndrome. We didn't count that as an independent variable, but I suspect that could serve as one.

And then the fact that the tremor doesn't even look like a Parkinson's tremor. The frequency is all wrong. The metal -- The freq -- The tremor looks more like the tremor you see with mercury poisoning, at least what's been reported in mercury poisoning.

So that taken as a group, somebody who had all of those features, I wouldn't have any question about telling you that that patient had manganese poisoning.

Q You had five of them or four of them?

A Well, and, you know, and as the patient gets older, it starts to favor Parkinson's disease. So you'll get patients who just have enough -- they got three points for, three points against, and the answer is I don't know.

Q I'm writing down when you're talking. I have these that you were looking at, age of onset, whether it's bilateral or one-sided, amount of exposure, psychiatric problems, a response to L-dopa -- a good response to L-dopa, family history, the sleep-wake cycle disturbance, and then the type of tremor, those are the ones I have.

A Right.

Q And my question is this. Did those -- there happens to be eight, the number eight -- were those on the form that was being used in examining the people who were part of the study?

A Right. Every one of those particular topics is in there. Now, the problem is some of them aren't readily quantifiable, like the -- like the psychiatric cognitive problem. That's a subjective report. I mean, you can't -- there's no veneer caliper for schizophrenia. You can't measure it. So it's a historical point.

Q But were these listed on the form is all I'm after. Were those listed on the form for somebody --

A They're all in there but --

Q -- who's examining?

A They're under -- they're -- The form follows the standard format of a neurologic exam, and so they're under the various headings, cognitive function, psychiatric function, cranial nerve function.

Q In the Gulf Coast study, were there any -- this is a -- I think a phrase of art I'm told -- statistically significant findings?

A I'm not a statistician. I think that there are -- I think statistics are what you need when the numbers are -- don't tell you anything when you look at them. When the numbers are grossly out of -- disproportionate to what's been reported, I don't think you need statistics.

Q Does the phrase “statistically significant” have any particular meaning to you?

MR. McCOY: He's already answered.

THE WITNESS: Yeah, I think it's a technique for analyzing data where the -- where the -- where the obvious isn't obvious.

BY MR. GLOOR:

Q Is something being statistically significant, in this case the amount of neurological problems you saw among the people you examined, does that have to be statistically significantly above the population in general to have meaning?

MR. McCOY: Let me object -- object to that question. It's vague, and also I don't think -- His testimony was that statistical significance had nothing to do with his conclusions here. He can -- he can answer. I mean, I'm --

THE WITNESS: I think just to change, I think it has meaning without ever having to relate it to statistics. I mean, I think that's the standard way you identify diseases.

I mean, no one -- no one did statistics to realize that bird flu was causing a problem. I mean, there were enough people walking around with it, you realized there was something -- there was a problem here. And I think that's the case we were seeing down there. Is it so commonly encountered that -- You can do statistics on it. It doesn't seem to me you need to. I've never seen anything quite like this.

BY MR. GLOOR:

Q Putting this aside, in studies in general on health issues, is a need for a statistical significance something that is required before a study can be relied on or have any particular significance in terms of patient care or any other kind of conclusions that might be drawn medically?

MR. McCOY: Can you read that back?

THE WITNESS: No, I understood what he said.

MR. McCOY: Okay.

THE WITNESS: I think the problem -- You know, and I understand what you're saying, but this is, you know, this is the problem of dealing with, say, a public -- a large -- Let me think, phrase this correctly.

I think it's a problem we had with submitting this data was that some people were more worried about form than fact. They said, well, you didn't do the form right. I says, well, you know, I grant you we didn't do the form right. This is not the strict epidemiologic study. The data didn't lend itself to that. But here's what we found. Isn't that worth looking at? And one journal said yes; one journal said no.

I mean, and I think that you have to view it for what it is. It's a set of observations, and it's a description. We didn't have the capacity to do the kind of study that the CDC would like us to do. It's not the kind of study I'd do with NIH funding, where I had the cooperation of the employers. This was a study funded by your profession.

BY MR. GLOOR:

Q Lawyers.

A Yeah. Which is the -- Which creates an incredibly weird situation because I've never -- I've never done a study funded by litigation. I mean, that's -- We're not supposed to -- I mean, everyone's dead set against this. But it was the only way to get the data, and I thought the data was important to get.

Q Couldn't you have done -- If you wanted to go back to square one. Lawyers aren't around; they've all been banished, as some people want, to banish us, and they come to you and say, okay, Doctor, we want to examine this to see if there, in fact, is a greater amount of neurological problems among welders than non-welders. If money was no object, how would you do it?

A You'd survey -- You'd do what they were going to do in Canada and Italy, where you'd go into a factory -- Or classic is Korea, when we talked to Dr. Kim in Seoul, is that what they did, that they go through the factory, and they'd examine every man, woman, and, you know -- And, of course, I used to -- we used to think we had children labor in Korea. Korea labor is pretty good shape these days.

But they examined everybody, the secretaries, the office workers, the janitors, and what they found was that manganese levels went up and up and up as you got closer to the welding area and the area where fabrication was being done, and the actual welders themselves and the helpers who worked with them, those guys had the highest manganese levels, and then the levels got lower as you looked at people in the work site and in the -- in the shops.

Q What would you do if I just gave you a lump of money, I'm not a lawyer --

MR. McCOY: Let me object. He was in the middle of his answer.

BY MR. GLOOR:

Q I was trying to --

A Well, I'd do the same study. I think that's the kind of study you'd want to do here.

Q Would you compare controls to a group you're studying? Would you have to have two groups you're comparing?

A You'd look at people -- The control group would be people working in the same location.

Q With no exposure to manganese, correct?

A With no -- with no welding exposure, correct.

Q So to do the study, you have a group of controls without the exposure, a group of people with the exposure, and then see if there is a difference between the two groups, correct?

A That's right, age match for control -- for a match for age and other -- and the differences in sex.

Q You mentioned that the article you submitted had some information about age in it; is that correct?

A Correct.

Q What was the information about age?

A Well, I mean, that the age -- the mean age of the patient population with neurological symptoms in this study was significantly younger than the average mean age of Parkinson's patients as a group.

Q Could that be the result of the fact that people who are working are younger than the people who would be getting Parkinson's disease normally?

A When people get diagnosed as Parkinson's, we don't ask them if they're working or not. They don't have to have Medicare to come here.

Q But would the group that you're looking at, in terms of welders, because they're still employed for the most part, be a younger group than a normal group taken from society in general or the population in general?

MR. McCOY: Let me object to the extent that I don't -- I don't -- I didn't hear it was ever established that most of these people were still working, but he can answer.

THE WITNESS: Some were working; some weren't. No, I don't -- I mean, that's like saying that -- I mean, people with Parkinson's disease reflect a fairly wide age -- age group, and we have patients --

BY MR. GLOOR:

Q I agree.

A And, I mean, the point is that this clinic -- I guess what you're saying, do younger people with Parkinson's disease ignore their symptoms more than older patients.

Q Let me ask it better. I didn't -- I wasn't asking that, and that's -- that's my fault on the question.

Would the group that you were being referred by lawyers, assuming they were employed, be a younger group than the population in general, in terms of the incidence of Parkinson's disease?

A Again, the point is many of the people, I think the vast majority of them, were on medical disability, and they were, in fact, unemployed at the time we saw them.

Q So the majority of the people you saw in the 2,000 were unemployed because they were on medical leave; is that right?

A Yeah, I mean, --

Q All right.

A -- the medical leave, it's amazing how young you can be and be on medical disability.

Q You talked to Dr. Kim.

A Yes.

Q In Korea. When did you do that?

A About seven weeks ago.

Q Who paid your way, or did you pay your own way?

A No, no, no. Seoul's much too expensive. I had no idea. No, the -- the Ranier, Gayle and Elliot, and whoever was assisting, arranged a meeting between Dr. Sanchez Ramos and me with Dr. Kim.

Q Any lawyers go along with you?

A Yeah, actually, they did, but they weren't involved in the conversation.

Q Who were they, lawyers who went along?

A Mr. Elliot went along and --

Q Where is he from? What firm is he from?

A He's with Ranier Gayle, and he's the Elliot of Ranier, Gayle and Elliot.

And Russ Ebby went along from -- he's from one of the Houston firms.

Q And how long were you with -- how long were you with Dr. Kim?

A Three days.

Q And any kind of letters back and forth, communications before you got there?

A No.

MR. McCOY: With -- with Dr. Kim?

MR. GLOOR: Um-hum, yes.

MR. McCOY: Okay.

THE WITNESS: No, this was all set up through them through some very circuitous route.

BY MR. GLOOR:

Q Did Dr. Kim -- Does he speak English?

A Yeah.

Q What did you talk about?

A About the Hyundai shipyards, about why his -- I mean, we talked about doing PET scans, doing, you know, MR scans in welders, and why he didn't seem to find a lot of cases of Parkinson's disease, in spite of the fact that many of his individuals in his studies had high manganese levels.

Q In fact, he wrote a report about that, didn't he, an article about that?

A Many. Yeah, there's a whole series of them.

Q But in terms of Parkinson's disease connection to welding, he wrote a report on that, didn't he, an article?

A There's a series of three. You know, the first one talks about one guy, then there's three guys. I mean, I don't know if the last paper, I think, has three people in it.

Q And what did Dr. Kim say about the relationship, if any, between Parkinson's disease and welding?

A That there was no question that there was a relationship, but that the Korean medical community and the industrial community, which it was an eye opener to me, they have great concern for their workers, they apparently have very strong unions, and they know that there's a risk from welding exposure, so that they screen their workers every six months, and they look at blood levels of manganese on a yearly basis, and if any worker shows any neurological symptoms, that worker is evaluated and taken off the work site.

They also have fairly stringent respiratory protective measures that are in effect in the shipyards themselves, and that's what he related the lower prevalence of parkinsonism to in their -- in their work force.

Q Lower rate of Parkinson's disease, in other words?

A Well, manganism. We had a long discussion about how you could tell manganism from Parkinson's. We had differing opinions about that. His opinions are well stated in his last paper, that you have to have a normal PET scan to have manganism.

Q Do you agree?

A No, I mean, for the reasons we outlined with regard to the pathological studies. And that was what we talked about, is our experience, and we showed him our vid -- a number of videotapes of patients and what kind of screening techniques we were using and talked about how their movement disorder specialists are trained, because they're obviously not trained here, and whether we -- although they use the same Parkinson's rating scale that we do, they don't do it quite the same way. And we looked at some interesting mainland Chinese video of a case of manganism that they had sent to him, actually two cases, and some very strange treatment that they had claimed --

Q Did you bring back documents or videos?

MR. McCOY: He's still discussing.

MR. GLOOR: I'm sorry. I thought he was done. I apologize. I'm trying to keep your time schedule, Bob.

MR. McCOY: That's okay, just let him talk about it.

MR. GLOOR: Well, as long as we can go beyond it, that's fine.

Q You go ahead.

A We brought back nothing, only because of the issue of what would be -- Dr. Kim was sensitive to having anything leaked to the legal community, and so we -- we traveled light, as they say.

Q So that you brought back nothing from Korea, correct, besides --

A I got a nice poster. It's in my office. It's --

Q Did Dr. Kim give you anything you brought back from Korea?

A His business card, that's it.

Q Dr. Kim, I take it, based on what you're telling me, didn't find much Parkinson's disease among welders, correct?

A Among shipyard workers, no.

Q Well, welders from the shipyards, correct?

A Correct.

Q And did Dr. Kim say that the amount of Parkinson's disease that he found among welders was higher than the general population, lower, or about at it?

A We didn't talk about that, but he states in his paper that it's no different than the general population in Korea.

Q So Dr. Kim is saying that there's no relationship between welding and -- and Parkinson's disease, and he said that in a paper, correct?

A That's what he said in his paper. We just were -- Yeah, and, again, it's based on his data. I think -- and it may be true -- but that there's -- there's underlying reasons for it that don't relate to the disease or the causality issue.

Q What are those? What are the underlying reasons?

A Better work hygiene, a younger work force, and the fact that major shipbuilding in -- in Korea has only been in -- it's barely got 20 years of exposure. That's a new industry in Korea. You don't see 40-year veterans. He was astonished at how long some of these men had been welding in -- in our group.

Q Were all the welders that Dr. Kim talked about when you were out there for the three days, do they have to wear respirators all the time, or does it depend on the kind of work they were doing?

A I got the feeling that it depended on the type of work, but we didn't -- You know, Dr. Kim is a -- is a bile -- is a medical researcher. He was too far up, you know, the hierarchical system. We needed to see the general medical officer, and we couldn't get -- our time frame was too restricted to allow us to go to the south, to the shipyards themselves, and do an inspection. We couldn't get an approval that fast.

Q Is there any peer-reviewed article or study that you're aware of that shows that exposure to welding fumes or manganese causes those exposed to have a greater prevalence of Parkinson's disease than the general population?

A The only indication of that in a -- in a controlled study in a peer-reviewed journal is probably, God, the guy at Henry Ford.

Q Gorell.

A Gorell. Gorell's first paper showed a relationship. Then there's a second paper where there's some question about whether that was a valid observation.

But it's interesting that in Gorell's analysis, you know, he excluded welders from the manganese group, which I think -- I mean, even with that exclusion, he thought there was a significant change.

Q Except for Gorell, would it be accurate to say that you're aware of no peer-reviewed literature that concludes that welders have a higher amount or rate or prevalence of Parkinson's disease than the general population?

A Yeah, at the moment, that's probably true.

Q Now Gorell, did you read all of Gorell's articles, where he eventually concluded that there was no relationship between welding and Parkinson's disease?

A Right. And I've -- I've heard people who -- whose job is -- is to play with biostatistics say that the first analysis was closer to being accurate than the second, and I can't speak to the validity of either one of those.

Q Can you and I agree that Gorell, in his series of papers, eventually concludes there is no relationship between welding and Parkinson's disease?

A Well, he never raised welding. He raised manganese as an issue, as I recall.

Q Okay. Let me rephrase it. Can you and I agree that Gorell, in his series of papers, eventually concludes there is no relationship between manganese and Parkinson's disease?

A That's how he interprets his data, correct.

Q So if Gorell doesn't conclude that, would it be accurate to say that as of this moment, there is no peer-reviewed article that says there is a relationship between manganese exposure, welding fume exposure, and Parkinson's disease?

MR. McCOY: Let me object to the -- now this term “relationship.” Does that conclude -- Well, I don't know the meaning of that word, “relationship,” but he can answer.

THE WITNESS: Why don't we -- I mean, we can agree to that. I mean, things take time. At the moment, there's no -- there's no study that's got overwhelming acceptance that says there's a relationship.

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