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IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN

LEE COUNTY, FLORIDA

CIVIL DIVISION

John Szymanski,
Plaintiff,
vs

07-CA-015501

R.J. Reynolds Tobacco Company, et al

Defendants.

Deposition of MERRILL BIEL, M.D., taken pursuant

to Notice of Taking Deposition, and taken before Daniel W.
McMahon, a Notary Public in and for the County of Hennepin,
State of Minnesota, on the 6th day of May, 2011, via video
teleconference at 2200 IDS Center, 80 South Eighth Street,
Minneapolis, Minnesota, commencing at approximately 1:15
oclock p.m.

Source: http://industrydocuments.library.ucsf.edu/tobacco/docs/gmhl0191

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MR. BRAZZEAL: Sure. Chad Brazzeal for the
Chad B r a z z e a l , E s q u i r e , and C r a i g R.
3
plaintiff with also Craig Stevens for the plaintiff is
4
here as well.
S t e v e n s , E s q u i r e , of t h e f i r m of MORGAN & MORGAN, P o s t
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MR. DUNCAN: Tom Duncan representing Lorillard
O f f i c e Box 9504, F o r t M y e r s , F l o r i d a 3 3 9 0 6 , a p p e a r e d
6
Tobacco Company.
representing the P l a i n t i f f .
7
MR. MIZELL; Nick Mizell of Cheffy Passidomo out of
Thomas A.
Duncan, E s q u i r e , of t h e
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Naples for Lorillard.
9
MR. RILEY: Sean Riley for Philip Morris.
f i r m of SHOOK, HARDY & BACON, 2555 Grand B o u l e v a r d , Kansas
10
MR. WINDHAM; Chris Windham for RJ. Reynolds.
City, Missouri 64109-2613, appeared r e p r e s e n t i n g L o r i l l a r d
11 Q Okay. Doctor, can you please state your professional
Tobacco Company a n d L o r i l l a r d , I n c .
12
business address?
13 A It's 2211 Park Avenue South, Minneapolis, Minnesota
"Nicholas P. M i z e l l , E s q u i r e , of t h e
14
55404.
f i r m of CHEFFY PASSIDOMO, 621 F i f t h Avenue S o u t h , N a p l e s ,
15 Q And is that Ear, N o s e & Throat SpecialtyCaie of
F l o r i d a 3 4 1 0 2 , a p p e a r e d r e p r e s e n t i n g L o r i l l a r d Tabacco
16
Minnesota?
Company and L o r i l l a r d , I n c .
17 A Yes, it is.
18 Q How are you employed there?
Sean R i l e y , E s q u i r e , A t t o r n e y a t
19 A I am a full partner, part owner and physician, senior
Law, a p p e a r e d v i a t e l e p h o n e r e p r e s e n t i n g P h i l i p M o r r i s USA
20
physician actually in the practice.
Inc.
21 Q How long have you been employed there?
22 A Since 1987.
C h r i s Windham, E s q u i r e , A t t o r n e y a t
23
(interruption)
Law, a p p e a r e d v i a t e l e p h o n e r e p r e s e n t i n g R . J . R e y n o l d s
24
MR. DUNCAN: Yes, go ahead.
T o b a c c o Company.
25
MS. MILLOR: Hi, this is Sandra Millor from
26
Kasowitz Benson appearing on behalf of Liggett and
S a n d r a M i l l o r , E s q u i r e , of t h e f i r m
27
Vector. I apologize for joining you late. I've been
of KASOWITZ BEWSOH TORRES t FRIEDMAN, 1441 B r i c k e l l Avenue,
28
trying for the last ten minutes to figure out what
S u i t e 1420, Miami, F l o r i d a 3 3 1 3 1 , a p p e a r e d v i a t e l e p h o n e
29
number this was.
r e p r e s e n t i n g L i g g e t t Group, I n c . and V e c t o r Group, L t d .
30
MR. DUNCAN: No problem, we just got started.
*
*
+
*F % ^ "^Jr^fAQ ** * *

APPEARANCES:

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MS. MILLOR: Okay.
MR. BRAZZEAL: Yeah, this is Chad Brazzeal for the
WHEREUPON, the following proceedings were duly had: 2
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plaintiff, you didn't miss anything except his name and
3fc
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address and where he works.
5
MS. MILLOR: okay, thanks.
6 Q Doctor, I couldn't hear that. How long have you been
MERRILL BIEL, M.D.,
7
employed at that practice?
a witness in the above-entitled
8 A Since 1987.
action, after having been first duly
9 Q And what kind of physician are yon?
sworn, deposes and says as follows:
10 A I'm an otolaryngologist, head and neck surgeon.
ifc

sp

CROSS-EXAMINATION

11

Q Can you provide me with an overview of your educational

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background starting with medical school?
13 A Sure. I went to medical school at the University of
BY MR. BRAZZEAL:
14
Illinois in Chicago and graduated in 1981. And then I
did a residency in otolaryngology, head and neck surgery
Q Good afternoon, doctor, my name is Chad Brazzeal, I 15
16
at the University of Minnesota, which I completed in
represent the plaintiff in this case, John Szymanski.
17
1987.
Have y o u ever had a deposition taken before?
18
I also at the same time obtained a Ph.D. degree in
A I have.
otolaryngology with a minor in radiation biology and
Q Okay. I'm just going to remind you then to make sure 19
that you listen to my question and if you have any
20
anatomy at the University of Minnesota, also completed
questions regarding the question please let me know and
21
in 1987. And then I did a fellowship in head and neck
I'll try to rephrase it for you, okay?
22
oncology, reconstructive surgery at Washington
23
University in St. Louis, Barnes Hospital, in 1987.
A Very good.
MR. DUNCAN: speak up a little bit.
24 Q And what states are you licensed to practice medicine
A Very good.
25
in?
Q Are you able to hear me okay?
26 A In Minnesota.
A Yes. Can you hear me okay?
27 Q Do you hold any board certifications?
Q Yes, I can.
28 A I do. I'm board certified in otolaryngology head and
29
neck surgery.
30 Q Did you pass your board certification exam on the first
(Reporter asked for appearances)
** *** * "^Frti"^^!

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attempt?
A I did.
Q Have you ever been licensed in any other states?
A No.
Q I know we asked just a moment ago off the record about a
curriculum vitae. I understand we have an older one and
there may be a more recent one. Could you forward your
more recent copy to the attorney for Lorillard, please,
so that they can forward that on to us?
A I will be happy to do that.
Q Thank you. What type of patients do you treat in your
practice?
A About 85 percent of the patients I see are head and neck
tumor related. About 15 percent are general ENT. Ear
disease, sinus disease, et cetera.
Q Do you perform any surgeries?
A I do. That's a major part of my practice.
Q Okay. Do you perform laryngectomies?
A I do.
Q And do y o u perform neck dissections?
A I do.
Q If a patient were to need follow-up chemotherapy, would
you refer them to another physician?
A Yes. Yeah, we run a multi for our treatment of our head
and neck cancer patients. I actually am director of the
head and neck oncology program at the Virginia Piper
Cancer Institute. So we have a multi-specialty program
in which all the patients are evaluated not by people
like myself who are surgical oncologists in head and
neck but also medical oncologists and radiation
*

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five years prior.
Q How many cases do you think you've given a deposition in
over the past 15 to 20 years?
A Three. Three or four.
Q So in the past 15 to 20 years this is probably your
fifth deposition ever?
A Correct.
Q Have you ever testified at trial before?
A Once.
Q Okay. Where was that trial located?
A Bismarck, North Dakota.
Q What did that case involve?
A It involved an issue of the possible non-diagnosis,
non-early diagnosis of a cancer.
Q And who were you testifying at the request of, a
plaintiff or a defendant?
A A defendant.
Q Have you ever testified before either in a deposition or
in a trial for a, at the request of a tobacco company?
A No.
Q Have you ever been sued for medical malpractice before?
A I have not.
Q Do you know if the testimony you've given in any of
those cases over the years has ever been disqualified by
a court?
A No, not that I'm aware of.
Q Do you advertise for your services as an expert witness?
A I do not.
Q What is your understanding of how cases are typically
referred to you?

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oncologists.
Q Have you ever served as an expert witness in litigation
before?
A I have.
Q Okay. What percentage of your time currently is devoted
towards serving as an expert witness?
A I'd say well less than one percent.
Q D o you hold any academic positions?
A I do. I have an appointment as a professor at the
University of Minnesota.
Q What do you do in that capacity? Are you teaching
students, are y o u conducting rounds with them?
A I teach students and residents both in family practice
and in surgery. And I'm also advisor to the residentsat the present time one resident in the University of
Minnesota Department of Otolaryngology Program in the
research.
Q When did you first start serving as an expert witness in
medical/legal cases?
A Probably 15 to 20 years ago.
Q And has your expert testimony always been limited to the
field of being an ENT?
A Yes.
Q During the last five years how would your, the
percentage break down for testimony that you've given at
the request of a plaintiff versus at the request of a
defendant in litigation?
A The last time I actually did a deposition was four or
five years ago for a plaintiff And the only other time
before that was for a defendant, but it was probably

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MR. DUNCAN: object to form. You mean legal or
medical?
Q Legal cases.
A I think they're just referred via attorneys asking other
attorneys who they should call to get an opinion on a
case. As far as I know.
Q What percentage of your income today is derived from
serving as an expert witness in litigation?
A Well, certainly this year zero. In the previous year,
it's well less than one percent.
Q Do you have a fee schedule for your work as an expert
witness?
A Yes.
Q Okay. Can you tell me what that is?
A I don't know the whole thing offhand. My business
office would have that.
Q Okay.
MR. DUNCAN: He wasn't quite finished.
A The only thing that I know of is there's an hourly rate
for a review of records and that sort of thing, which is
$375 an hour.
Q Is your fee schedule, is it a written document?
A I believe it is somewhere at the business office.
Q Okay. Is that something you could forward on to defense
counsel as well?
A Sure.
MR. DUNCAN: We'll do that.
Q All right. You said your hourly rate for records review
is $375. How much do you charge for deposition
testimony?
*** *** *^

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Page 10
I don't know that offhand.
1
Do you know how much you charge for trial testimony?
2
No, I don't.
3
4
This case is set in Lee County Florida, which is in
southwest Florida. If you come down and testify, do you
5
k n o w how much y o u ' l l charge?
6
No. It would be based off the fee schedule.
7
Okay. It would b e an hourly rate plus expenses? 8
I think there's a charge for in court appearances and 9
expenses.
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How much have you billed for reviewing this matter to
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date?
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Nothing.
Okay. How many hours of review time or preparation time 14
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have you p u t into this case?
16
About four hours.
17
Are you intending to submit a bill any time soon for
18
y o u r work in this case?
I am.
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When you were initially contacted by defense counsel to
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serve as an expert witness, what were you asked to do in
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this case?
I was contacted to well, I was asked to act as an 23
24
expert witness based on my clinical expertise and
25
knowledge as a head and neck specialist, head and neck
cancer specialist, to evaluate the risk of smoking as 26
related to the possibility of development of laryngeal 27
cancer.
28
29
D o you recall w h o contacted you?
Mr. Michelman.
30
* * * Notes

Page 11
1
Q And do you know what law firm Mr. Michelman is with?
2
A Yes. Shook, Hardy & Bacon.
3
Q Have you ever worked as an expert witness in litigation
at the request of any attorneys from Shook, Hardy &
4
Bacon in the past?
5
6
A I have reviewed records for them in the past.
Okay.
H
o
w
m
a
n
y
cases?
7
Q
8
A I think three that I can recall.
9
Q Have they all been at the request of I didn't write
down his name. Mr. McMillan I think.
10
11
MR. DUNCAN: Michelman.
12
A Michelman. No. His name is Michelman.
13
Q W h a t attorneys have y o u reviewed cases for?
14
A Let's see if I can remember actually. Since I'm
terrible with names. Actually, I've reviewed a case for
15
Mr. Duncan in the past. And I'm blanking on the other
16
names.
17
Q Okay. In the cases that you've reviewed at the request 18
of an attorney from Shook, Hardy & Bacon, have you ever 19
given a deposition in those cases?
20
21
A I have not.
Q All right. What materials have you reviewed in this 22
23
case?
24
A The only thing that I reviewed was some portions of the
surgeon general's report from 2004 entitled "The Health
25
Consequences Of Smoking".
26
Q Okay. Is that a document that you obtained, or is that 27
a document that was provided to you by an attorney? 28
29
A It's a document that I obtained.
Q Have you reviewed any of the depositions taken in this 30
* * * Notes

Page 12
case of John Szymanski?
A No.
Q Have you reviewed any of Mr. Szymanski's medical
records?
A No.
Q Have you written any reports
A I have not.
Q for this case?
A No.
Q Have you made any notes for this case?
A No.
Q Did you have to talk to any of your colleagues in order
to form your opinions i n this case?
A No, I did not.
Q Did you have to do any medical research in order to form
y o u r opinions?
A No. The only thing that I looked at was some components
of the surgeon general's report in order to confirm what
I recalled as both in my experience and what I had read
in the past was consistent with risks of smoking.
Q Now, can you give me the title of that surgeon general's
report?
A Sure. It's "The Health Consequences Of Smoking: A
Report Of The Surgeon General". It's 2004. It's
published by the U.S. Department Of Health And Human
Services, Public Health Service, Office Of The Surgeon
General.
Q Okay.
A You can get it off the CDC website.
Q Did you make any notes on that report that you have in
H=**

Page 13
front of you?
A I did not.
Q Now, this health consequences of smoking report, are
there previous versions of this report available?
A My well, I don't know for sure. My guess is there
probably are.
Q Okay. So what I'm trying to understand is perhaps in
the year 2000 was there a similiar report called health
consequences of smoking?
A There may be. I don't know.
MR. DUNCAN: Excuse me. I apologize for this but
I've got to take a really short comfort break. Do you
mind?
MR. BRAZZEAL: That's fine.
MR. DUNCAN: Like a minute. I'll be right back.
(At this time a recess was taken)
CONTINUED BY MR. BRAZZEAL:
Q Doctor, do you know if there's any more recent versions
of this report, perhaps i n 2 0 0 5 through 2011?
A Not that I'm aware of.
Q H o w is it that you came to obtain this report?
A I believe I printed this off a few years ago.
Q Okay. What caused you to print this off a few years
ago?
A I was asked to look at risk factors of smoking in a
previous case with Shook, Hardy & Bacon.
Q Okay. That was a case where a plaintiff was suing for a
smoking related illness?

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Correct.
1 A No.
D i d y o u testify in that case?
2 Q that w e h a v e n ' t already discussed?
No.
3 A No. I have been provided with no other materials.
When you pulled the report off the Internet a few years
4 Q Sure. Is there any information that the attorneys have
ago for that case, was that research that you performed
5
provided you in this case that forms the basis of any of
on your own, or was that a document that the attorney 6
your opinions?
7 A No.
directed you to?
8 Q Okay, doctor, what are your opinions in this case?
No, that's research I did on my own.
9 A Can you give me a more specific question?
Do you agree with everything that's in the report?
I can't say whether I do or don't because I haven't read
10 Q Sure. I mean, your disclosure says you're expected to
11
testify regarding the etiology, risk factors and
the entire report.
diagnoses regarding the cause and development of certain
Okay. Are there any particular portions of it that you 12
13
diseases and conditions, including the role as reported
disagree with?
in medical and scientific literature of cigarette
Not of the portions I looked at. I was basically ~ I 14
15
smoking.
pulled the report because it has nice summaries of
16 A Okay.
studies. And so I was looking at the study summaries.
Okay. Can you tell me what studies you were looking at? 17 Q There's a lot in that sentence. What I'm trying to
18
understand is what testimony arc you going to provide to
Sure. It's a study by Maier, M-a-i-e-r, et al, 1992.
19
the j u r y regarding the etiology, risk factors and
And a study by Tavani, T-a-v-a-n-i, et al, 1994. Study
20
diagnoses regarding the cause and development of certain
by Maier, M-a-i-e-r, and Tisch, T-i-s-c-h, 1997. I
21
diseases?
think those are the main ones.
Okay. What were the conclusions of the first Maier's 22 A So risk-wise that cigarette smoking is a known
23
contributor to the development of laryngeal cancer. And
study, the 1992?
it occurs pretty much in a dose response dependent
The conclusion of that study was that there's a dose 24
fashion. And largely, you know, dependent on the
response relationship between the amount and duration of 25
26
intensity of smoking.
smoking as a risk factor for developing laryngeal
So that would be the number of cigarettes smoked per
cancer. So that as you increase both the intensity and 27
28
day, for instance. Or packs of cigarettes per day. As
time that you smoke your risk goes up, but in a
29
well as the length of time that that intensity of
nonlinear fashion.
smoking is ongoing. So we usually refer to that as pack
Okay. And what was the results or the conclusions drawn 30
% % H1 "Mfyi f* o * * *

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b y the Tavani 1994 study?
A That - well, it was basically the same.
Q Okay. And finally the Maier/Tisch 1997 study, what were
their conclusions as you understand them to be?
A Their conclusions were the same as well, dose response
relationship to the number of cigarettes per day and
duration of smoking and pack years. In a nonlinear
fashion.
Q Do you have any opinions about John Szymanski's smoking
history in this case?
MR. DUNCAN: object to form.
A I don't know what his smoking history was since I have
not reviewed the records.
Q Okay. So you don't have any opinions then about whether
or n o t Mr. Szymanski w a s addicted to cigarettes
containing nicotine?
A No, I do not. I haven't had a chance to review his
records.
Q I understand that you have your expert witness
disclosure in front of you?
A Yes.
Q All right. Did you draft the language that's in this
disclosure?
A I approved of the language.
Q Okay. A n d that was going to be one of my next
questions. Is there anything in the actual language of
the disclosure that you disagree with?
A No.
Q Okay. Are there any other materials that the attorneys
h a v e provided you in this case ~

Page 17
1
years. You know, in a way to designate amount of
2
smoking clinically. So we typically ask people how much
3
they smoke, how much they're actively smoking, how much
4
they smoked in the past and for how long they've been
5
smoking.
6
And the risk actually changes depending on both the
7
intensity and duration of smoking. So, for instance, if
8
someone is smoking five pack years their risk of
9
developing laryngeal cancer in particular is really no
10
greater than that of a nonsmoker. When you go from five
11
to ten pack years of smoking, there' s a very minimal
12
risk associated with smoking over someone who doesn't
13
smoke as developing laryngeal cancer.
14
So very slow, minimal difference to insignificant
15
difference between five and ten pack years of smoking.
16
From ten to 20 there is an increase in risk. But it's
17
only really after 20 pack years that the risk starts
18
dramatically increasing, and substantially increases at
19
30 years and above, and then dramatically at 40 pack
20
years and above.
21 Q A l l right. L e t ' s take five t o ten years. If an
22
individual smokes cigarettes for five to ten years, do
23
they have an increased chance of developing cancer?
24
MR. DUNCAN: Object to form.
25 Q Okay, let m e rephrase that. If someone smokes
26
cigarettes for five to ten years, are they at greater
27
risk of developing any type of cancer than a nonsmoker
28
who never smoked a cigarette at all?
29 A Well, I can't speak to any other type of cancer. I can
30
speak to laryngeal cancers.

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Okay, then we'll address laryngeal cancer.
1 Q Yes.
Okay. Sothe-2 A Okay. So if they have -- and are we assuming that they
If someone smokes yeah, if someone smokes five to ten 3
have no other risk factors for developing laryngeal
years, are they at a greater risk of getting laryngeal
4
cancer?
cancer than a nonsmoker?
5 Q Yeah, just for laryngeal cancer just simply from smoking
Depends how much they're smoking during that five to ten 6
100 pack years.
7 A So they don't have any other history of alcohol use or
years.
8
chronic reflux or HPV exposure or environmental
Okay. What if they're smoking two packs a day?
9
exposures that are risk factors for laryngeal cancer.
So if they're smoking two packs per day for ten years,
that's 20 pack years. So yes, they are at a probably 10
So I just want to make sure I get the hypothetical
11
correct.
two to three times risk over a normal person of
12 Q That's correct. Only smoking.
developing laryngeal cancer.
13 A Okay, so they only smoke. They actually have a very
And that would be for five to ten years of smoking two
14
substantial risk of developing laryngeal cancer. It's
packs a day?
about 15 to one. Or greater depending
So, no, as I said, if they were smoking, giving your 15
example that you said they were smoking two packs per 16 Q Does that mean they're 15 times more likely than a
17
nonsmoker then to develop laryngeal cancer?
day, and so I said two packs per day for ten years,
18 A Yes.
that's 20 pack years.
So for somebody who's smoking 20 pack years, they've got 19 Q You mentioned a few other factors such as HPV status and
alcohol use. Are you going to express any opinions at
a two to three times increased risk over a nonsmoker. 20
trial regarding the relationship between those things
Because actually nonsmokers can develop laryngeal 21
and development of laryngeal cancer?
cancers. So they have a two to three times risk over 22
23 A I can if I'm asked.
nonsmokers of developing laryngeal cancer.
What about someone who smokes five years? Is someone 24 Q Okay. All right then, let's go ahead in case you're
25
asked. What is the relationship then between alcohol
who smokes five years more at risk for developing
26
use and laryngeal cancer, if there is any?
laryngeal cancer than a nonsmoker?
27 A Alcohol use actually in combination with smoking
MR. DUNCAN: object to form. Are you meaning to
increases the risk of laryngeal cancer twofold.
say five pack years, or five years at some amount? 28
I'm saying five years. Five years at one pack per day 29 Q Okay. What do you mean by increases the risk twofold?
30 A They have a double chance over smoking alone of
would be five pack years.
"^ ^ * "Nft1 P*i

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A Okay. So thank you. Thank you for making that clear.

So if you're talking about five pack years of smoking,

they are at no more increased risk of developing
laryngeal cancer than someone who does not smoke.
Q Are you saying that there's no health consequences at
all from smoking five pack years?
MR. DUNCAN: object to form.
A That's not what I said at all. What I said was that
they are at no more increased risk over someone who
doesn't smoke in developing laryngeal cancer if they
smoke five pack years.
There's all sorts of other potential health consequences
and I tell patients not to smoke because of that. But
they're not at increased risk with five pack years of
smoking of developing a laryngeal cancer.
Q Okay. You agree that smoking is unhealthy, though,
don't you?
A Absolutely.
Q All right. And you do agree that smoking increases a
person's chance of developing laryngeal cancer?
MR. DUNCAN: object to form.
A That's related to time and duration of smoking.
Q Now, are you going to have any opinions in this case as
to whether or not the plaintiff, John Szymanski,
developed cancer from smoking cigarettes?
A No, because I haven't reviewed the records at all.
Q Now, if an individual has a 100 pack year history what
is that person's risk for developing laryngeal cancer
compared to that of a nonsmoker?
A If that's a so is that a hypothetical question?

Page 21
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developing a laryngeal cancer.

Q Does it depend upon how much alcohol that person has

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drank?
A Yes, it does. Correct.
Q Are there ~
MR. DUNCAN: He was still talking. Sorry.
A It's how much and what type of alcohol they drink.
Q All right. Are there certain alcohols that are I guess
more related to causing laryngeal cancer than other
types of alcohol?
A Yeah, alcohol by itself is not known to increase the
rate of laryngeal cancer. Studies are disputed on that
so there's not a clear relationship. But there actually
is a clear relationship between particularly drinking
hard alcohol and smoking increasing the rate of
laryngeal cancer in those people who smoke.
Q What about drinking beer and smoking, is there any
relationship that you know of there?
A Well, the studies that I've seen, that I recall, the
relationship is not nearly as clear as with hard
alcohol. And the amount of beer that you'd have to
drink would be substantial. So it's not a beer a day.

23

Q Okay. I mean, what do you mean by substantial? Is that

24
less than three beers a day?
25 A It's probably five or more. But, again, the data is not
26
clear with beer.
27 Q Why is it that alcohol by itself I guess is not as
28
strongly correlated to causing laryngeal cancer as
29
alcohol and smoking are?
30 A That's not actually fully understood.

* ^**** ^^01 PQ

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Q Okay.
A It is an irritant. But clearly in many studies there
actually hasn't been a demonstration of alcohol alone
substantially increasing risks of head and neck cancers.
Q All right. Your expert witness disclosure says, Dr.
Biel may testify regarding the accrual of risk for the
diseases claimed by plaintiff. What is your testimony
in that regard?
A I think that's what we've been talking about with regard
to laryngeal cancer.
Q Can you tell me what risk factors Mr. Szymanski had far
developing laryngeal cancers?
A I have no idea since I've not reviewed his records.
Q Are you going to offer any testimony regarding the
relationship between positive HPV status and the
development of laryngeal cancer?
A I could if asked.
Q Okay. Is there a relationship between HPV status and
the development of laryngeal cancer?
A There is a relationship between - well, let me put it
this way. Laryngeal cancers can be caused by an HPV
viral infection. They are not very common.
HPV in head and neck cancer is much more common in the
tonsil and tongue base. But they are a known cause of
laryngeal cancers in both smokers and have been found in
nonsmokers, too.
Q Are you going to offer any specific opinions about the
facts of this case -- well, let me rephrase that. Are
you going to offer any case specific opinions related to
Mr. S z y m a n s k i ?

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Q Two to three beers per day, is that person's alcohol use
a contributing factor to them developing laryngeal
cancer?
MR. DUNCAN: object to form.
A Hypothetically and if they had no other risk factors
associated with ~ that could be associated with
laryngeal cancer the two to three beers per day would
not substantially increase their risk, in m y opinion.
Q Okay. So if you take a smoker and that smoker has a 100
pack year history and they also drink two to three beers
per day, then i t ' s your opinion that their alcohol
consumption would not cause them to have a greater
chance of developing laryngeal cancer?
MR. RILEY: Object to form.
A Not substantially. If they have no other risks.
Q Okay. What other risk would you want to know about in
order to completely answer that?
A Well, they can have other risks, as we talked about
before, with regard to HPV status, with regard to
history of reflux, which the alcohol use is a
contributor actually. Any environmental exposures at
work, any history of previous radiation to the area.
Those types of risks.
Q Would drinking two to three beers per day for
approximately 40 years increase a person's chance of
developing laryngeal cancer?
A I would say in my opinion not substantially. There may
be a slight increased risk.
Q Dr. Biel, your expert disclosure says that you may also
offer opinions about risk avoidance and reduction in

******* ^^Frii'pQ

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MR. DUNCAN: if 1 could just interrupt here and say
2
that we have not put him up for any case specific
3
opinions other than what he's already stated, which are
4
general opinions applied in this case. But we gave him
no materials on Mr. Szymanski. So go ahead, doctor. 5
6
A Ditto.
7
Q Okay.
A Yeah, I haven't seen the records and so I can actually 8
9
state nothing really related to this specific case.
Q Right. And that's why I'm just looking at your expert 10
disclosure, though. You know, it says, whether 11
plaintiff s alleged use of cigarettes manufactured by 12
Lorillard Tobacco Company was sufficient to constitute a
13
substantial contributing factor to his injuries.
14
15
I mean, as you sit here today you can't tell me how many
Lorillard cigarettes Mr. Szymanski smoked, can you? 16
17
A I have no idea.
Q So you wouldn't be able to tell me then whether or not 18
19
Mr. Szyraanski's smoking of cigarettes manufactured by
20
Lorillard caused him any injuries whatsoever?
A No. I think what I can tell you is what I stated in
21
general from the standpoint of the risk of development
22
of laryngeal cancer with the degree of smoking. But I
23
24
don't know anything about Mr. Szymanski's smoking
25
history or what he smoked.
Q All right. I want to give you a hypothetical question 26
then. If you assume for me that someone's had a 100 27
28
pack year history and they also drank two to three, four
29
beers a d a y ~
30
MR. DUNCAN: Did you say two, three, four?

Page 25
risk for the development of cancers.
A Correct.
Q Are you able to tell me what specifically you're going
to inform the jury of regarding risk avoidance and
reduction?
A Well, if one stops smoking and alcohol use. But if
someone stops smoking, and particularly with regard to
laryngeal cancers and actually other head and neck
cancers, if they have stopped smoking for most
literature and most experience would say ten years, then
their risk of developing a laryngeal cancer becomes the
same as someone who has not smoked in the past There
are some studies that go out to 20 years but most of
them are around ten.
Q Does it depend upon how much the person had smoked in
the past?
A No. According to previous studies that's not a major
factor.
Q So if a person had smoked for 30 years two packs a day,
that would be a 60 pack year history, if that person
stopped smoking it's your opinion that ten years after
stopping that person would have the same risk for
developing laryngeal cancer as someone who had never
smoked a cigarette in their life?
A Yes, that's what population studies have demonstrated.
Again, some
Q D o you believe that
MR. DUNCAN: He's still talking.
A Again, some studies actually go out to 20 years. But
most of them actually refer to ten.

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Multi-Page 1
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Page 28
1
cancers, too. So you're Q Do you believe that in your own experience?
A Yes, I do.
2 Q Let me ask you this, is a patient that develops
laryngeal cancer, are they more at risk of developing a
Q Is it your opinion that that person's risk in regards to 3
developing laryngeal cancer from smoking actually goes
4
recurrence of that laryngeal cancer than someone who has
to zero?
5
never had laryngeal cancer in the first place?
6 A Anybody that has any cancer is at risk of developing a
MR. DUNCAN: object to form.
7
recurrence typically within a five-year period than
A Well, the risk of developing laryngeal cancer in the
base population of nonsmokers is not zero. Ten percent
8
anyone who has not had a cancer.
of the people that we see with laryngeal cancers have 9 Q Your expert witness disclosure says that you may also
never smoked. So there's an incidence of laryngeal 10
offer opinions and testimony in response to issues
cancers that exists as a baseline in nonsmokers due to 11
raised by plaintiff and plaintiff's experts. And may be
other risk factors.
12
asked to comment upon the testimony opinions of other
13
witnesses and expert reports. Do you have any such
Such as the things we talked about before. So it
doesn't go down to zero. It goes down to the baseline
14
opinions today?
of the normal population.
15 A No, because I've been provided no information.
16
MR. BRAZZEAL: Can we take a break?
Q Are you able to tell me what a nonsmoker's chances are
of developing laryngeal cancer absent any risk factors 17
MR. DUNCAN: Yeah, that's great.
such as HPV status, alcohol use, acid reflux?
18
19
(At this time a recess was taken)
A They're very low.
20
Q A l l right. What do you mean by that?
MR. DUNCAN: object to form.
21 Q Doctor, have you ever received any research money from a
tobacco company?
A It would be not common. Uncommon but not rare. 22
23 A No, I have not.
Q You treat laryngeal cancer in your practice, don't you?
24 Q Have you ever been employed by a tobacco company?
A That's correct.
Q And in the majority of the patients that you treat for 25 A No, I have not.
26 A Have you ever participated in any research that was
laryngeal cancer what was it caused by?
27
funded by a tobacco?
MR. DUNCAN: object to form.
28 A No, I have not.
A About 90 percent of them are in patients who are active
29 Q Have you ever been affiliated with the Roswell Park
smokers typically with alcohol use and may have other
risk factors, particularly reflux as well. Ten percent 30
Institute?
*** * *** ^^rtl f*Q

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Page 27
of them are nonsmokers. Most of those have some other
risk factor, the most common being reflux. Chronic
reflux.
Q Now, I know we talked about if a person, if a smoker
stopped smoking after ten years their risk of developing
laryngeal cancer goes to that of a nonsraoker. My
question is does that change at all if the person has
already developed cancer before they quit smoking?
MR. DUNCAN: object to form.
A I'm sorry, can you restate the question?
Q Yeah. Sure. We talked earlier about if a person that
smokes quit smoking ten years later their risk of
developing laryngeal cancer returns to that of a
nonsmoker.
My question is does that hold true if the smoker has
already developed laryngeal cancer? If they stop
smoking for ten years after they developed it and it's
diagnosed, does their risk of developing laryngeal
cancer go back to that of a nonsmoker even though
they've already been diagnosed in the past?
MR. DUNCAN: Object to form.
A So, well, I guess I need some clarification. So if the
person has a history of laryngeal cancer have they been
treated?
Q Yes.
A Okay. And how have they been treated?
Q Well, that's not the question.
A That makes a difference as to the answer. Because if
they received radiation, which would actually be
commonly done, there are radiation induced laryngeal

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A I actually am on a National Institutes of Health grant
with them.
Q Okay. What does that grant involve?
A The grant involves treating patients with a treatment
called photodynamic therapy. With patients with head
and neck cancer they have photodynamic therapy. And
Roswell Park has a certain drug, it's a photosensitizer.
So this is a treatment that's a light activated drug
treatment that selectively kills tumor cells. And so
I'm a co-investigator on a National Institutes of Health
funded clinical trial.
Q There's an individual there named Michael Cummings. Do
you happen to know Mr. Cummings?
A No, I don't.
Q We talked about the 2004 surgeon general's report. Are
there any other areas in that report that are important
for you in formulating your opinions in this case?
A The ones I mentioned were the ones that I had examined.
Q Are there any other materials you'll be relying on in
support of your opinions?
A Not that I'm aware of certainly at this time.
Q Is nicotine in cigarettes addictive?
A As I understand, it is in some people.
Q D o you think in some people it is not?
A That would be my clinical impression.
Q The 2004 surgeon general's report, does it discuss
whether or not nicotine in cigarettes is addictive?
A I did not read that section. I'm not an expert on
addiction so Q It is your understanding, though, that nicotine in

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Page 30
cigarettes can be addictive, correct?
A Yes, it does have addictive potential, as I understand
it.
Q I know we touched on this as well but I just kind of
want to get the question a little more clear. What are
the risk factors for developing laryngeal cancer?
A What are any risk factors?
Q Yeah, what are the risk factors for developing laryngeal

cancer?
A Okay. So they would include smoking. They would
include chronic reflux. They would include HPV exposure
disease. Previous radiation to the area. Toxic
environmental exposures. Those would be the common
ones.
And alcohol is a contributing one. So it's a risk
factor in combination with smoking. And clinically
certainly it aggravates reflux, which is a risk factor.
So it's a contributor. Family history would also be
another contributor.
Q Doctor, are there any other opinions that you intend to
express at trial that we haven't covered today?
A Not that I'm aware of at this time.
Q Okay. I don't have any other questions. Thank you.
MR. DUNCAN: Anyone on the phone? I don't have
any. Nick, do you have any?
MR. MIZELL: No, I don't have any questions.
MR. RILEY: This is Sean. I have no questions.
MS. MILLOR: This is Sandra. I have no questions,
either.
MR. BRAZZEAL: Doctor, you can read ~
* * * ]^Q

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Page 31
MR. DUNCAN: Wait a minute, wait a minute. Chris?
MR. WINDHAM: I'm going to hold off.
MR. DUNCAN: All right. So no questions. All
right.
MR. BRAZZEAL: Doctor, you can read a copy of your
deposition if you like.
MR. DUNCAN: He will. He'll read and sign.
MR. BRAZZEAL: okay. Court reporter, I would like
to take a copy. Or actually I'm ordering it since I'm
taking it.
*

Page 32
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CERTIFICATE OF READING AND SIGNING

I, MERRILL BIEL, M.D., have read the foregoing
transcript of rny deposition, taken by Daniel W. McMahon,
Court Reporter, and believe the same to be true and correct
(or except as follows listing the page and line number and

the reason):

Date

Signature

es ***
Page 33
l
2

STATE OF MINNESOTA )

) ss.
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COUNTY OF HENNEPIN

Be it known that I took the deposition of

MERRILL BIEL, M.D., on the 6th day of May, 2011, at 1:15

p.m.;

That I was then and there a notary public

in and for the County of Hennepin, State of Minnesota, and

that by virtue thereof I was duly authorized to administer

an oath;
That the witness before testifying was by
me first duly sworn to testify to the truth and nothing but
the truth relative to said cause;
That the testimony of said witness was
recorded in computerized Stenotype and thereafter
transcribed by myself, and that the testimony is a true
record of the testimony given by the witness to the best of
my ability;
That I am not related to any of the
parties herein nor interested in the outcome of the action;
That the reading and the signing has been
executed as evidenced by the previous page.
WITNESS MY HAND AND SEAL THIS 6TH DAY OF MAY, 2011.

*** Notes *H**

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Multi-Page
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21:21
23:29

21:22
24:1

5:19
8:11

3:24
11:16
5:28
2:9

4:26

5:30

B o x [l] 2:5

Brazzeal [13]
4:2
28:16

break p] 7:25
Brickell [i]
business [3]
cancer [66]
10:26 10:28
17:13 17:23
18:5
18:12
19:10 19:15
20:4
20:5
20:22 20:26
21:12 21:16
22:19 22:23
24:13 24:26
26:7
26:17
27:8
27:13
28:3
28:4
29:6
30:6
cancers [12]
22:12 22:21
25:9
26:9
capacity [i]
case [29] 3:16
10:15 10:18
12:1
12:8
13:29 14:2
16:5
16:8
22:29 23:2
cases [9] 7:19
9:3
11:7
caused [4]
26:26
causing [2]
CDC[i] 12:29
cells [l] 29:9
Center [i]
certain [4]
29:7
certainly p]

2:3
5:2
30:30
13:12
2:27
4:12
6:25
14:27
17:27
18:23
19:20
20:9
20:28
21:28
23:23
25:11
26:23
27:16
28:5
30:9
17:30
22:25
26:11
7:11
8:12
10:22
12:10
14:5
19:23
23:4
8:2
11:13
13:25

3:13
5:2
31:5
28:16

3:15
13:14
31:8

9:15
6:27
16:23
17:29
18:26
19:25
20:14
21:1
22:10
24:3
25:23
26:26
27:19
28:6

9:23
8:14
17:9
18:1
19:4
19:28
20:17
21:9
22:16
24:7
26:4
27:6
27:23
28:8

18:22
25:1
28:1

22:4
25:8

9:6
11:15
12:13
15:10
20:24
23:9
8:24
11:18
22:21

10:4
11:23
13:28
15:30
22:28
29:17
8:29
11:20
23:20

21:9

21:28

1:23
16:12

16:20

21:8

29:21
32:2

30:17

9:9

certification^] 5:30
certifications [i]
certified [i]
5:28
cetera [i]
6:15
C h a d [4] 2.3

chance [6]
20:30

4:26
2:27

20:21
22:20
24:29

10:11

CERTIFICATE^]

21:26
24:7

17:15
22:18
22:6

/"

blanking [i]
board p] 5:27
Boulevard [i]

4:2
13:19

17:1

1 1

32:4
33:6
bill Li] 10:17
billed [ii
biology [i]
Bismarck [i]
bit[i]

30:22

background [i] 5:12

Bacon [5]
2:9

14:25
22:15
3:6

24:13

chances 111
change [i]

3:15
15:17
24:25
26:16
27:7

5:27

4:2
17:23

5:2
19:20

Index Page 1

Source: http://industrydocuments.library.ucsf.edu/tobacco/docs/gmhl0191

Multi-Page TM
changes [i]
charge [4]

17:6
9:29

10:2

10:6

10:9
2:14
Chrffypj
chemotherapy [i]
5:14
Chicago [i]
C h r i s [3] 2:22

chronic p]
cigarette [4]

4:7
6:22
31:1
27:2
16:22

16:28
23:16

17:22
23:19

CIRCUIT m
C i t y m 2:10

15:6
17:26
29:22
1:2

15:15
19:25
29:27
1:2

1:3
22:7
claimed [i]
clarification [i] 27:22
clear [6] 19:1
21:13

27:2

2:24
28:24

4:6

27:30
1:11
8:19

19:29
compared [i]
5:16
completed [2]
completely p] 24:17
components [i] 12:17
computerized [i]
conclusion [i] 14:24
conclusions [4] 14:22

13:3

13:9

19:5
12:20
23:13

consistent [i]
constitute [i]
consumption [i] 24:12
10:20
contacted p]
containing [11 15:16
CONTINUED [i]
contributing [3] 23:14
contributor p] 16:23
30:19
COpy [3] 6:8

correct pj
20:12
32:6

21:4

correlated [i]

31:5
8:7
25:2
21:28

33:3
33:9
COUrt [5] 1:2
32:6

8:25

10:9

31:8

21:14

29:11
30:16
29:10

29:25

30:16

22:23

2:11
23:13

26:22

2:16
28:22

5:20

33:16
14:30

11:26
19:12

10:23

30:21
4:3

D a k o t a [i]
8:11
1:20
D a n i e l [2]
d a t a p ] 21:25
d a t e p] 10:12
32:29
d e f e n d a n t [4]
7:27
8:17
D e f e n d a n t s [i] 1:12
9:24
d e f e n s e p]
5:18
d e g r e e pi
demonstrated m
d e m o n s t r a t i o n [l]
D e p a r t m e n t p] 7:16
21:2
d e p e n d p]
16:24
d e p e n d e n t p]
17:6
d e p e n d i n g [2]
d e p o s e s [13
3:9
d e p o s i t i o n [123 1:19
7:28
8:2
8:6
11:20
31:6
32:5
d e p o s i t i o n s pj 11:30
d e r i v e d [i]
9:7
d e s i g n a t e p]
17:1
18:21
d e v e l o p [2]
19:25
d e v e l o p e d [4]
27:17
d e v e l o p i n g p2] 14:26
18:12
17:23
17:27
19:3
19:10
19:15
20:3
20:14
21:1
24:13
24:26
25:11
26:7
26:17
27:5
30:6
28:3
28:6
d e v e l o p m e n t p] 10:27
16:23
20:22
22:16
25:1
28:2
d e v e l o p s p]
7:5
d e v o t e d [i]
27:18
d i a g n o s e d p]
16:12
d i a g n o s e s [2]
8:14
d i a g n o s i s [i]
17:14
d i f f e r e n c e [3]
d i r e c t e d p]
14:7
d i r e c t o r p]
6:25
14:13
d i s a g r e e p]
15:20
d i s c l o s u r e pj
16:10
22:5
23:11
29:26
d i s c u s s [i]
16:2
d i s c u s s e d p]
d i s e a s e pi
6:15
16:13
d i s e a s e s p]
21:12
disputed p]
disqualified p] 8:24

21:20

15:4

12:23

10:29

13:19
24:2
24:21

30:15
30:18

31:9
14:1
26:24

20:11
30:1

D i t t o [l] 23:6

D I V I S I O N [i]

16:27
23:12
30:1

15:5

conditions [i] 16:13

conducting [i] 7:12
12:18
confirm [i]
consequences [6]

10:4

30:11
17:28

30:13

commonly [i]
company p]

10:20
1:21

CROSS-EXAMINATION m 3:11
Cummings p] 29:12 29:13
curriculum [i] 6:6

C I V I L [i]

21:26 30:5
22:2
clearly [i]
10:24
clinical p]
17:2
clinically [2]
co-investigator [i]
colleagues [i] 12:12
combination [23 20:27
13:12
comfort [i]
]
commencing [i 1:24
28:12
comment p]
22:22
common p]

9:25
1:3

C r a i g [2] 2:3

25:24

cigarettes p3]

dissections 111 6:20

counsel [2]
County p]

covered [i]

4:10
20:8
16:14

changes - experience

32:5

7:30

8:16

10:20
23:23
25:25
22:3
12:25
25:15
16:25
20:15
1:20
8:18
33:5

d o c t o r [io]
13:20
16:8
30:30
31:5
d o c u m e n t p]
11:29
14:6
d o e s n ' t p]
d o n e p ] 27:30
d o s e p ] 14:24
d o u b l e [i]
d o w n p] 7:25
26:14
D r p]
22:5
d r a f t [l] 15:22
d r a m a t i c a l l y p]
d r a n k p] 21:3
d r a w n p]
d r i n k p] 21:7

drinking p]
drug p] 29:7
d u e p ] 26:11
d u l y [4] 3:2

Duncan [33]
3:17
9:29

4:5
9:27
15:11
21:6
26:6
28:17

4:24
11:11
17:24
23:1
26:21
30:24

duration p]

1:3
3:15
23:5

4:11
28:21

5:6
30:20

9:22

11:27

11:28

17:12

19:10

26:14

15:5
20:30
10:5

16:24
11:10

26:14

24:29
17:18
23:28
14:30
21:22
21:14
29:8
3:8
2:8
4:30
11:16
18:27
23:30
26:27
31:1
14:25

17:19

24:10
21:17

24:24

33:10
3:24
9:1
13:11
19:7
24:4
27:9
31:3
15:7

33:13
4:5
9:18
13:15
19:21
25:28
27:21
31:7
17:7

19:22
20:17
27:8
17:9
18:23
19:20
22:12
25:23
27:13
30:8
16:12
22:19

27:16
17:13
18:25
19:28
24:2
26:4
27:18
16:20
23:22

7:24
during pi
6:14
E a r p] 4:15
educational p] 5:11
E i g h t h [i]

either p] 8:18
employed [4]
28:24
E N T p ] 6:14
entire p] 14:11
entitled p]
environmental

1:23
30:29
4:18

18:6

4:21

5:7

20:8

24:21

2:4
2:26
14:18
16:19

2:8

7:22
11:25
PI

30:13

Esquire pi
2:13
etp]

27:20
16:20
17:15

27:28

15:27
15:23
24:29

15:27
28:9

6:15
16:21

30:12
22:7

2:18
1:11

etiology [2]
evaluate pi
evaluated p]
evidenced [i]
e x a m p ] 5:30
examined [i]
example pi
except p]
Excuse [i]
executed p]
exists [i]
expected p]
expenses p]
experience p]

2:3
2:22
6:15
16:11
10:26
6:28
33:23
29:18
18:16
5:3
13:11
33:23
26:11
16:10
10:8
12:19

14:19

32:7

10:10
25:10

26:1

Index Page 2
Source: http://industrydocuments.library.ucsf.edu/tobacco/docs/gmhl0191

Multi-Page TM
7:2
9:8
15:19
28:13
10:24
28:11
20:8
20:9
20:20
14:26
30:16
13:27
20:19
26:30

e x p e r t [i7]
7:21
8:27
10:24
11:3
24:29
28:9
e x p e r t i s e [i]
e x p e r t s [i]
e x p o s u r e [2]
e x p o s u r e s [3]
e x p r e s s [2]
f a c t o r [7]
25:18
27:2
f a c t o r s [i4]
20:3
20:9
26:12
26:17
30:8
f a c t s [l] 22:28
7:13
f a m i l y [2]
f a r [l]
9:6
14:29
f a s h i o n p]
9:22
f e e p]
9:11
5:21
f e l l o w s h i p [i]
13:25
f e w [4] 13:24
f i e l d [l] 7:22
8:6
fifth[2] 2:14
4:28
f i g u r e [i]
15:3
f i n a l l y [i]
f i n e [ i ] 13:14
9:18
f i n i s h e d [i]
f i r m [5] 2:4
2:9
11:1
3:8
5:30
f i r s t [6] 33:13
28:5
7:24
7:29
f i v e [24] 17:15
17:21
17:10
18:6
18:13
18:3
18:28
18:28
18:29
19:6
19:11
19:2
28:7
f i v e - y e a r [i]
1:3
F l o r i d a [6]
10:5
2:28
10:4
6:22
f o l l o w - u p [1]
3:2
f o l l o w i n g [i]
3:9
f o l l o w s [2]
32:4
f o r e g o i n g [i]
12:13
f o r m [15] 9:1
19:7
17:24
18:27
26:21
24:14
26:6
16:5
27:21
29:17
f o r m s [i]
f o r m u l a t i n g [i]
6:7
F o r t m 2:5
22:25
f o r w a r d [3]
8:4
f o u n d [i]
f o u r [5] 7:28
23:30
15:20
f rR
o nI E
t [2]
F
D M13:1
A N [i] 2:27
f u l l [ i ] 4:19
f u l l y [l] 21:30
f u n d e d [2]
28:27
general p]
6:14
23:4
23:22
11:25
general's [5]

7:6
9:11
22:5
29:28

30:11
24:21
30:21
23:14
30:17
16:11
22:11
30:6

7:18
10:21
23:10

30:13
24:2
16:19
24:5
30:7

30:18
15:8
10:7
14:4

16:25

20:19

2:14

2:26

7:18

14:22

8:1
17:22
18:24
18:29
19:14

17:8
17:26
18:25
18:30
21:25

2:5

2:15

32:7

12:15
19:21
26:27

15:11
24:4
27:9

29:15
29:26
g i v e n p] 7:25
8:2
33:18
g i v i n g [i]
18:15
g o e s [4] 14:28
26:4
g o o d p ] 3:15
3:23
g r a d u a t e d [l]
5:14
G r a n d [i]
2:9
g r a n t p] 29:1
29:3
g r e a t [ i ] 28:17
17:10
g r e a t e r p]
20:15
24:12
G r o u p [2]
2:29
g u e s s [4] 13:5
21:8
HANDm
33:24
h a p p y [i]
6:10
hard[2] 21:15
21:20
H a r d y p]
2:9
11:19
13:28
head[i4]5:10
5:15
6:13
6:24
6:26
10:25
22:4
22:23
h e a l t h [io]
11:25
12:26
13:3
13:8
29:1
29:10
h e a r p ] 3:26
3:27
H e n n e p i n p]
1:21
h e r e i n [i]
33:21
Hip]
4:25
history[i2]
15:10
20:7
23:25
23:28
24:22
25:20
27:23
h o l d [4] 5:27
7:8
H o s p i t a l [i]
5:23
h0UT[i] 9:21
h o u r l y p]
9:19
h o u r s [2] 10:14
10:16
H P V [ 9 ] 20:8
20:19
22:21
22:23
24:19
H u m a n [l]
12:25
h y p o t h e t i c a l p] 19:30
H y p o t h e t i c a l l y [i]
i d e a p ] 22:13
23:17
I D S [ i ] 1:23
I l l i n o i s [i]
5:14

9:24

10:16

23:28

29:11
12:24

12:27

12:18

12:21

26:14
3:25

11:20

27:6

29:4
17:26

18:4

2:29
21:27

27:22

11:2

11:4

5:21
6:29
25:8
12:23
19:5

5:28
10:25
29:5
12:25
19:12

5:6
33:3

33:9

15:12
24:10
30:18
27:15

19:27
24:20

9:28

10:8

22:15
26:18

22:18
30:11

20:10
24:5

23:26

31:2

illness in
13:30
important [i] 29:16
impression [i] 29:25
Inc[4]

6:9

8:23

expert - light

2:11

incidence [i]
include PI
including [i]
income [i]
increase pj
24:8 24:25
increased [6]
19:9
19:14
increases [4]
20:29
increasing pj
individual pi
induced [i]

2:16
26:10
30:10
16:13
9:7
14:27

2:20

2:29

30:11

30:11

17:16

21:11

17:23
24:28
17:18

18:20

19:3

19:19

20:28

17:18
17:22
27:30

21:15
19:27

22:4
29:12

i n f e c t i o n [i]
22:22
i n f o r m [i]
25:4
i n f o r m a t i o n [2] 16:4
i n j u r i e s [2]
23:14
i n s i g n i f i c a n t [i] 17.14
i n s t a n c e [2]
16:28
I n s t i t u t e [2]
6:27
I n s t i t u t e s [2]
29:1
i n t e n d [i]
30:20
i n t e n d i n g [i]
10:17
i n t e n s i t y [4]
14:27
17:7
i n t e r e s t e d [ii
33:21
I n t e r n e t [ii
14:4
i n t e r r u p t [i]
23:1
i n t e r r u p t i o n [i] 4:23
i n v o l v e [2]
8:12
i n v o l v e d [i]
8:13
i n v o l v e s [i]
29:4
i r r i t a n t [i]
22:2
i s s u e [l] 8:13
i s s u e s [l]
28:10
i t s e l f [2] 21:11
21:27
J o h n p ] 1:8
3:16
19:24
I j o i n i n g [i]
4:27

28:15
23:20
17:7
28:30
29:10

16:26

16:29

29:3

12:1

15:9

JUDICIAL [i]

1:2

|jury[2] 16:19
K a n s a s [i]
Kasowitzp]
k i l l s [i] 29:9
k i n d [2] 5:9
k n o w l e d g e [i]
k n o w n [4]
33:5
l a n g u a g e pi
l a r g e l y [i]
l a r y n g e a l [62]
17:9
17:13
18:12
18:21
19:10
19:15
20:5
20:9
20:26
20:28
21:16
21:28
22:19
22:21
24:7
24:13
25:23
26:4
26:17
26:23
27:16
27:18
28:4
28:5
laryngectomies
l a s t p] 4:28
l a t e [i] 4:27
l a w p ] 2:19
L e e p] 1:3
l e g a l p] 9:1
l e n g t h [i]
l e s s [3] 7:7
l i c e n s e d \2\
l i f e [i] 25:24
L i g g e t t p]
l i g h t [i] 29:8

25:4
2:9
2:27

4:26

30:4
10:25
16:22

21:11

22:24

15:24

15:26

14:26
18:1
18:26
19:28
20:17
21:9
22:12
23:23
25:8
26:9
27:6
27:30
30:8
6:18
7:28

16:23
18:4
19:4
20:3
20:22
21:12

15:22
16:25
10:27
17:30
18:23
19:20
20:14
21:1
22:10
22:25
24:26
26:7
26:26
27:23
30:6
[i]
7:24

2:23
10:4
9:3
16:29
9:10
5:24

21:24
6:3

2:29

4:26

22:16
24:2

25:11
26:10
27:13
28:3

11:1

Index Page 3

Source: http://industrydocuments.library.ucsf.edu/tobacco/docs/gmhl0191

Multi-Page1
likely[i]
20:16
l i m i t e d [i]
7:21
l i n e [ i ] 32:7
l i s t e n [i] 3:20
l i s t i n g [i]
32:7
l i t e r a t u r e [2]
16:14
l i t i g a t i o n [4]
7:2
11:3
l o c a t e d [i]
8:10
l o o k [ i ] 13:27
l o o k e d [2]
12:17
l o o k i n g [3]
14:16
Lorillard[io]
2:10
2:16
4:5
4:8
23:16
23:20
L o u i s [i] 5:23
l o w [ i ] 26:19
L t d [i] 2:29
14:18
M-a-i-e-rp]
3:6
M . D [ 4 ] 1:19
14:18
M a i e r [2]
14:22
Maier's[i]
M a i e r / T i s c h [i] 15:3
m a i n [ i ] 14:21
6:17
major pj
26:25
m a j o r i t y [i j
27:28
m a k e s [i]
m a l p r a c t i c e [i] 8:21
.
m a n u f a c t u r e d [2]]
11:22
m a t e r i a l s [5]
23:5
29:19
10:11
m a t t e r [i]
6:7
m a y [ii] 1:22
26:29
24:27
24:29
33:6
33:24
McMahon[2]
1:21
McMillan^]
11:10
m e a n [8] 9:1
16:10
21:23
21:23
23:15
m e a n i n g [i]
18:27
m e d i c a l [s]
5:12
m8:21
e d i c a l / 9:2
l e g a l [i]12:3
m e d i c i n e [i]
5:24
m e n t i o n e d [2] 20:19
M E R R I L L [4] 1:19
33:6
2:28
M i a m i [i]
29:12
M i c h a e l [i]
M i c h e l m a n p i 10:30
11:12
11:12
M i l l o r [6]
2:26
30:28
5:1
5:5
m i n d [ i ] 13:13
17:11
m i n i m a l [2]
M i n n e a p o l i s [2] 1:24
M i n n e s o t a [ii] 1:22
5:20
4:16
5:16
33:9
7:16
33:2
5:19
m i n o r [i]
13:15
m i n u t e [3]
4:28
m i n u t e s [i]

25:10
7:27

14:14
14:17
2:11
6:8

14:20
32:4
14:20

m i s s m 5:3
M i s s o u r i [i]
M i z e l l [4]
30:26
m o m e n t [i]
m o n e y [i]
9:8

23:10
2:15
23:13

33:6

M O R G A N [2]
M o r r i s [2]
m o s t [6] 25:9
27:1
27:2
M S [4] 4:25
m u l t i [ i ] 6:24
multi-specialty
M y e r s [i]
n a m e [4] 3:15
n a m e d [i]
n a m e s [2]
I N a p l e s [2]
N a t i o n a l [2]
n e a r l y [i]
n e c k [15] 5:10
6:13

25:17

23:12
15:29

23:19
16:3

13:10
28:9

22:6
28:11

32:5
20:16
26:20

20:29

5:13
12:15
7:19

6:30
16:14

29:18
3:6

32:4

11:1

11:11

4:25

4:25

17:14
4:13
1:24
5:26

31:1

4:13
7:10

31:1

6:20

2:10
2:13
6:5
28:21
2:4
2:19
25:10

2:4
4:9
25:13

5:1

5:5

[i]
2:5
5:3
29:12
11:15
2:14
29:1
21:20
5:15

6:27

6:25
22:4

10:25
10:25
29:6
27:22
n e e d [2] 6:22
25:23
n e v e r [4] 17:28
n e x t [ i ] 15:25
n i c e [ i ] 14:15
2:13
N i c h o l a s [i]
30:25
N i c k [2] 4:7
15:16
n i c o t i n e [4]
29:30
n o n - d i a g n o s i s [i]
n o n - e a r l y [i]
8:14
n o n l i n e a r [2]
14:29
n o n s m o k e r [io] 17:10
18:20
18:26
19:29
27:14
27:19
n o n s m o k e r ' s [i] 26:16
n o n s m o k e r s [6] 18:21
26:8
26:11
27:1
nor[i]
33:21
n o r m a l [2]
18:11
N o r t h [i]
8:11
N o s e [ l ] 4:15
1:21
n o t a r y [2]
12:30
n o t e s [2] 12:10
10:13
n o t h i n g [3]
1:20
N o t i c e [i]
NOW [5] 12:21
13:3
27:4
4:29
n u m b e r [4]
32:7
1:25
o ' c l o c k [i]
o a t h m 33:11
O b j e c t [i3]
18:27
19:7
26:6
26:21
o b t a i n [i]
obtained p]
o c c u r s [i]
off [7]
6:5

4:7

9:1
19:21
26:27
13:23
5:18

11:10

likely - percent

4:7

25:30
30:28

11:12

11:17
4:8
29:10
5:21
6:26
22:23

26:10

29:22

5:29
6:30
25:8

28:5

29:27

8:13
15:7
17:27
20:17

18:23

18:5
27:6

22:26

26:15

33:8
23:9

33:13

19:23

19:27

15:6

16:27

15:11
24:4
27:9

17:24
24:14
27:21

11:27

11:29

12:29

13:24

16:24

10:7

13:25
14:4 31:2
Offer [5] 22:14
22:27
28:10
offhand[2]
9:15
o f f i c e [4]
2:5
12:26
o l d e r [i] 6:6
O n c e m 8:9
o n c o l o g i s t s [3] 6:29
o n c o l o g y [2]
5:22
o n e [io] 6:6
6:7
9:10
15:25
18:29
30:15
o n e s [4] 14:21
29:18
o n g o i n g [i]
16:30
o p i n i o n [6]
9:5
24:27
25:21
26:3
o p i n i o n s [19]
12:13
15:14
16:6
16:8
22:27
22:29
23:3
28:10
28:12
28:14
30:20
order[4] 12:12
12:15
o r d e r i n g [i]
31:9
o t o l a r y n g o l o g i s t [i]
o t o l a r y n g o l o g y [4]
5:28
7:16
o u t c o m e [i]
33:21
o v e r v i e w [i]
5:11
o w n [3] 14:6
14:8
o w n e r [i]
4:19
P[i]
2:13
p . m [ i ] 1:25
p . m . [i] 33:7
p a c k [22] 15:7
16:30
17:15
17:17
17:19
18:19
18:28
18:29
19:6
19:11
19:14
23:28
24:10
25:20
p a c k s [7] 16:28
18:8
18:16
18:17
25:19
p a g e [2] 32:7
33:23
Park[3] 4:13
28:29
p a r t [2] 4:19
6:17
p a r t i c i p a t e d [i] 28:26
p a r t i c u l a r [2]
14:12
p a r t i c u l a r l y [3] 21:14
p a r t i e s [i]
33:21
p a r t n e r [i]
4:19
p a s s [l] 5:30
P a s s i d o m o p i 2:14
p a s t [io] 8:3
8:5
11:16
12:20
17:4
27:20
p a t i e n t [2]
6:22
p a t i e n t s [9]
6:11
6:28
19:13
26:25
29:5
p e o p l e [6]
6:28
29:24
26:9
29:23
p e r [ i i ] 15:6
16:27
18:16
18:17
18:29
24:11
24:24
p e r c e n t [7]
6:13

22:29

24:30

10:1
9:16

9:23

6:30

7:1

6:26

7:7
20:15

7:15
25:6

29:18

30:14

24:8

24:11

12:16
19:23
23:4
29:17

15:9
20:20
24:30
29:20

12:18

24:17

5:10
5:15

5:19

26:1

17:8
18:10
18:30
19:27

17:11
18:18
19:2
20:6

18:9

18:14

29:7

17:9
25:7

26:30

4:7
11:5
25:12

11:6
25:16

28:2
6:13
26:28

6:25
29:4

17:2

21:16

16:28
24:1

18:9
24:7

6:14

7:7

Index Page 4
Source: http://industrydocuments.library.ucsf.edu/tobacco/docs/gmhl0191

Multi-Page1
9:10
26:8
percentage pj
p e r f o r m [3]
p e r f o r m e d [i]
p e r h a p s pi
p e r i o d [i]

26:28
7:5
6:16
14:5
13:7
28:7

p e r s o n [io]
18:11
25:19
25:20
25:22
27:11
27:23
p e r s o n ' s [5]
19:20
24:25
26:3
P h . D [ i ] 5:18
2:19
Philip p]
30:24
p h o n e [i]
p h o t o d y n a m i c [2]
p h o t o s e n s i t i z e r [i]
p h y s i c i a n [4]
4:19
6:23
P i p e r [i] 6:26
p l a c e [i] 28:5
p l a i n t i f f [13]
1:9
4:3
4:3
5:3
8:16
13:29
19:24
23:12
p l a i n t i f f ' s [2]
p l u s [i] 10:8
p o p u l a t i o n p ] 25:25
11:24
portions p]
p o s i t i o n s [i]
7:8
22:15
p o s i t i v e [i]
p o s s i b i l i t y [i] 10:27
8:13
p o s s i b l e [i]
P o s t [l] 2:4
19:12
p o t e n t i a l [2]
4:20
p r a c t i c e [7]
7:13
6:12
6:17
p r e p a r a t i o n pi 10:14
p r e s e n t [i]
7:15
16:24
p r e t t y [i]
9:9
p r e v i o u s [7]
24:22
25:17
30:12
p r i n t [i] 13:25
13:24
p r i n t e d [i]
p r o b l e m [i]
4:30
p r o c e e d i n g s [i] 3:2
p r o f e s s i o n a l [i ] 4:11
p r o f e s s o r [i]
7:9
p r o g r a m p]
6:26
p r o v i d e p]
5:11
p r o v i d e d pj
11:28
16:5
28:15
1:21
p u b l i c p]
12:25
p u b l i s h e d [i]
p u l l e d [2]
14:4
pursuant pi
1:19
p u t pi
10:15
22:20
3:21
q u e s t i o n s [7]
30:26
30:27
30:28
q u i t [2] 27:8
27:12
q u i t e [i] 9:18
R[i]
2:3
R.Jp]
1:11
2:23

26:30
7:25
6:18

9:7
6:20

13:21
21:2
27:4

25:15
27:7

19:28

24:1

4:9
29:5
29:7
4:20

29:6

2:6
7:26
22:7
28:11

3:16
7:29
28:11

26:8
14:12

26:15
14:14

30:2
5:7
26:23

13:4
33:23

5:9

5:24

13:28

6:27
16:18
15:30

7:16

12:26

33:8

16:3

14:15
23:2
15:26
31:3

4:10

30:23

r a d i a t i o n pi
5:19
27:29
27:30
30:12
r a i s e d [i]
28:11
r a r e [i] 26:22
r a t e [5] 9:19
9:28
21:15
r e a d pi 12:19
14:10
32:4
31:5
31:7
r e a d i n g pi
32:2
13:12
r e a l l y [4]
23:9
r e a s o n [i]
32:8
12:19
r e c a l l e d [i]
27:29
r e c e i v e d p]
r e c e n t p]
6:7
recess pj
13:17
r e c o n s t r u c t i v e [il
r e c o r d [2]
6:5
33:16
r e c o r d e d [ij
9:20
r e c o r d s p]
12:4
15:13
15:18
23:8
r e c u r r e n c e [2] 28:4
r e d u c t i o n pj
24:30
r e f e r p] 6:23
16:30
8:30
r e f e r r e d [2]
20:8
r e f l u x [si
26:30
27:2
27:3
r e g a r d [5]
22:8
24:19
25:7
3:21
r e g a r d i n g p]
20:21
16:19
16:20
25:4
26:3
r e g a r d s [i]
6:14
r e l a t e d pi
22:29
19:22
21:9
r e l a t i o n s h i p [ii] 14:25
21:14
20:25
21:13
22:15
22:18
22:20
r e l a t i v e [i]
33:14
r e l y i n g [i]
29:19
r e m e m b e r [i]
11:14
3:19
r e m i n d [i]
3:22
r e p h r a s e p]
11:25
r e p o r t [in
12:24
12:30
13:3
13:21
13:23
14:4
14:15
29:15
29:16
r e p o r t e d [i]
16:13
reporter PI
3:30
reports PI
12:6
r e p r e s e n t [i]
3:16
r e p r e s e n t i n g pi 2:6
2:19
2:23
2:29
r e q u e s t [7]
7:26
8:19
11:4
11:9
r e s e a r c h [6]
7:17
14:8
28:21
28:26
5:15
r e s i d e n c y [ii
r e s i d e n t [i]
7:15
r e s i d e n t s pi
7:13
r e s p o n s e pi
14:25
28:10

percentage - slight

6:30

24:22

10:8

21:12

29:28

30:30

33:22
17:9

17:17

28:21
6:8
28:19
5:22
33:18

13:20

9:28
19:26

11:6
22:13

28:7
25:5
25:30
9:4
24:20
30:11
22:9

26:18
30:17
24:19

16:11
22:6

16:12
22:14

10:27
23:9
15:6
21:18

13:30
33:20
20:21
21:20

17:25
12:18
13:4
14:9
29:26

22:28
12:22
13:8
14:11

31:8
28:13

32:6

2:10
4:5
7:26
11:18
12:15

2:15

7:14
15:5

8:15
14:5

16:24

r e s t a t e pi
r e s u l t s [i]
r e t u r n s [i]
r e v i e w [4i
15:17
r e v i e w e d [ii]
11:18
11:22
15:13
19:26

27:10
14:30
27:13
9:20

r e v i e w i n g [i]
R e y n o l d s p]
r i g h t [14] 9:28
17:21
19:19
23:10
23:26
R i l e y pi 2:18
30:27
risk [54] 10:26
16:11
16:19
17:16
17:17
18:20
18:22
19:14
19:28
20:28
20:29
24:5
24:8
25:1
25:4
26:7
26:12
27:5
27:12
30:6
30:7
r i s k - w i s e [i]
r i s k s p i 12:20
24:23
r o l e p ] 16:13
R o s w e l l p]
r o u n d s [i]
r u n [i] 6:24
S a n d r a pi
s a y s [6] 3:9
24:29
28:9
s c h e d u l e p]

10:11
1:11
11:22
20:24
26:20
4:9

S c h o o l [21
s c i e n t i f i c [i]
SEALp]
S e a n p ] 2:18
s e c t i o n [i]
seep]
6:13
s e l e c t i v e l y [i]
s e n i o r [i]
s e n t e n c e [i]
s e r v e [i] 10:21
s e r v e d [i]
S e r v i c e [i]
s e r v i c e s [2]
s e r v i n g p]
set[i]
10:4
S h o o k [5j
11:19
13:28
s h o r t p ] 13:12
Sign[i] 31:7
Signature pi
s i g n i n g pi
s i m i l i a r pi
s i m p l y [i]
s i n u s pi 6:15
sit[i]
23:15
s l i g h t [l] 24:28

"

9:28

10:14

11:13
11:30

11:15
12:3

2:23
13:15
21:8
31:3
4:9

4:10
15:22
22:5
31:4
24:14

13:27
17:6
17:27
18:25
20:3
22:6
24:16
25:11
26:17
27:18
30:8
16:22
22:4

14:26
17:8
18:4
19:3
20:9
22:11
24:28
25:22
26:30
28:3
30:15

14:28
17:12
18:11
19:9
20:14
23:22
24:30
26:3
27:2
28:6
30:17

24:15

24:18

28:29
7:12

29:7

2:26
16:10

4:25
22:5

30:28
23:11

9:22

10:7

11:6
11:24
22:13

9:11
5:12
16:14
33:24
4:9
29:28
11:14
29:9
4:19
16:17

5:13

30:27
26:9

7:2
12:26
8:27
7:6

12:26
7:18

9:8

2:9

11:2

11:4

32:29
32:2
13:8
20:5

33:22

Index Page 5
Source: http://industrydocuments.library.ucsf.edu/tobacco/docs/gmhl0191

Multi-Page
sl0W[l] 17:14

smoke [9]
19:4
19:10
21:16
| smoked [IO]
23:16 23:25
25:24 26:10
| smoker [4]
27:15
smokers [2]
smokes [7]
18:3
18:24
smoking [59]
12:23 13:3
16:26
14:26 15:7
16:22 17:7
17:5
18:6
17:15 18:16
18:15 19:16
19:15 20:12
20:5
21:29
21:17 25:7
25:6
27:8
27:5
s 30:16
o m e o n e [13]

14:28
19:11

17:3
19:13

17:13
20:13

16:27
25:12

17:4
25:15

17:28
25:19

24:9

24:9

27:4

22:25
17:22
18:25
10:26
13:9
15:9
16:30
17:8
18:8
18:19
19:19
20:27
23:19
25:9
27:12

26:29
17:25
27:12
11:26
13:27
15:12
17:2
17:11
18:9
19:2
19:22
20:30
23:23
25:21
27:17

12:20
13:30
16:15
17:3
17:12
18:13
19:6
19:25
21:15
23:24
26:4
30:10

17:8
18:24
25:12
9:23

17:12
18:24
25:23

17:25
19:4
28:4

18:3
18:3
19:9
25:7
s o m e w h e r e [i]
s o o n [ i ] 10:17
27:10
s o r r y [2] 21:6
s o r t [l] 9:20
s o r t s [i] 19:12
1:23
South p]
10:5
s o u t h w e s t [i]
17:29
s p e a k p ] 3:24
10:25
s p e c i a l i s t [2]
S p e c i a l t y C a r e [i]
specific^]
169
23:2
23:9
s p e c i f i c a l l y [i] 25:3
SS [i]
33:2
St[i]
5:23
s t a n d p o i n t [i] 23:22
s t a r t [ i ] 7:18
4:30
s t a r t e d [i]
5:12
s t a r t i n g [i]
s t a r t s [i] 17:17
4:11
State[5] 1:22
4:11
33:9
6:3
s t a t e s [2] 5:24
20:19
s t a t u s [5]
24:19
26:18
33:16
S t e n o t y p e [i]
2:4
S t e v e n s [2]
25:28
Still [2] 21:6
Stop[i] 27:16
S t o p p e d [3]
25:9
S t o p p i n g [l]
25:22
Stops [2] 25:6
25:7
S t r e e t [l]
1:23
strongly[ij
21:28
s t u d e n t s [2]
7:12
S t u d i e s [9]
14:16

2:14
17:30
10:26
4:15
22:27

23:9

22:15

18:3

4:13

22:29

33:2

22:18

4:3

25:21

7:13
14:17

27:5

21:12

22:2
25:13
21:19
25:29
S t u d y m 14:16
14:18
14:23
14:24
15:1
s u b m i t [i]
10:17
s u b s t a n t i a l [4] 20:14
23:14
s u b s t a n t i a l l y [5] 17:18
24:15
24:27
Such [4] 20:19
26:13
s u e d [ i ] 8:21
23:13
s u f f i c i e n t [i]
s u i n g [i] 13:29
S u i t e [i] 2:28
s u m m a r i e s [2] 14:15
29:20
s u p p o r t [i]
5:10
surgeon m
12:26
12:21
12:24
6:16
s u r g e r i e s [i]
5:15
s u r g e r y [4]
7:14
6:29
s u r g i c a l [i]
3:9
s w o r n [2]
S z y m a n s k i [9] 1:8
22:11
15:15
19:24
23:16
S z y m a n s k i ' s [4] 12:3
23:24
14:19
T - a - v - a - n - i [i] 14:20
T - i - s - c - h [i]
2:15
T a b a c c o [i]
1:20
t a k i n g [2]
14:19
T a v a n i [2]
t e a c h [i] 7:13
7:11
t e a c h i n g [i]
t e l e c o n f e r e n c e [i]
t e l e p h o n e [3]
2:19
17:11
t e n [21] 4:28
17:26
17:21
17:22
18:17
18:9
18:13
26:8
25:21
25:30
27:12
27:17
11:15
t e r r i b l e [i]
8:8
t e s t i f i e d [2]
10:5
t e s t i f y p]
22:6
33:13
8:15
t e s t i f y i n g [2]
7:21
t e s t i m o n y [i3] 16:18
9:30
10:2
33:15
28:10
28:12
19:1
t h a n k [4] 6:11
5:5
t h a n k s [ij
:5
t h e r a p y [2]
29: 16
thereafter[i]
33: 10
t h e r e o f [i]
33::4
t h e y ' v e [3]
17:
T h o m a s [i]
2:8
t h r e e [i3] 8:4
8:4
18:20
18:22
21:24
24:1
24:7
24:10
T h r o a t [i]
4:15
t h r o u g h [i]
13:21
t i m e s [4] 18:11
18:20

slow - vs

25:17

25:25

14:19
15:3

14:19

21:22

21:23

22:4

24:8

26:18

28:13

T i s c h [ i ] 14:20
t i t l e [i] 12:21
t o b a c c o [9]
' 5
8:19
:27
t o d a y [4] 9:7
T o m [ l ] 4:5
t o n g u e [i]
t o n s i l [l] 22:24
t o o [2] 22:26
t 0 0 k [ i ] 33:5
T O R R E S [i]

1:11
23:13

2:11
28:22

2:24
28:24

23:15

28:14

30:21

22:24
28:1

2:27
30:4
7:6
T o x i c [i]
30:12
t r a n s c r i b e d [i] 33:17
t r a n s c r i p t [i]
32:5
t r e a t p] 6:11
26:23
t r e a t e d \i\
27:24
t r e a t i n g [i]
29:4
t r e a t m e n t [4]
6:24
29:9
t r i a l p] 8:8
8:10
30:21
20:21
29:11
32:6
t r u e [3] 27:15
33:14
t r u t h [2j 33:13

touched [i]
I towards [i]
14:16
11:25
29:15

12:18
29:26

5:22

5:29

33:13
3:16
22:30

12:1
23:5

15:9

23:19

t r y [i]
3:22
t r y i n g [3]
tumOT[2]

4:28
6:14

TWENTIETH [i]
31:10
15:1

1:23
2:23
17:15
18:3
25:10
26:30

tWO [15] 18:8

2:28
17:16
18:6
25:14
27:5

18:16
18:17
24:1
23:30
25:19
t w o f o l d [2]
t y p e [4] 6:11
t y p e s [2] 21:10
t y p i c a l l y [4]
28:7
U . S [ i ] 12:25

18:9
18:20
24:7
20:28
17:27
24:23
8:29

Uncommon [i] 26:22

understand [7] 6:6
8:18
14:2

16:11

33:12
7:25
22:7
33:17
19:1

8:23
22:14
33:18
30:23

29:6

18:19

27:20

11:8
23:28
24:24

18:11
23:30

18:22

20:16

15:19
16:18
u n d e r s t o o d [ 11
u n h e a l t h y [i]
U n i v e r s i t y [6]
5:23
7:10
u p [3]
3:24
U S A [ l ] 2:19
u s u a l l y [i]
V e c t o r [2]
v e r s i o n s [23
v e r s u s [i]
v i a [5] 1:22
9:4
v i d e o [i] 1:22
v i r a l [l] 22:22
V i r g i n i a [i]
v i r t u e [i]
v i t a e [ i ] 6:6
vs[i]
1:10

29:23
21:30
19:16
5:13
7:15
14:28
16:30
2:29
13:4
7:26
2:19

26:25
27:26
29:4

29:8

8:19

10:2

33:17

13:7
29:9
1:2
18:11
18:22
24:10

16:17

18:13
23:28
24:24

20:29
17:29

21:7

17:2

26:29

13:7
30:2

15:4

5:16

5:20

23:2

4:27
13:20
2:23

2:28

6:26
33:10

Index Page 6

Source: http://industrydocuments.library.ucsf.edu/tobacco/docs/gmhl0191

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W - zero

Index Page 7
Source: http://industrydocuments.library.ucsf.edu/tobacco/docs/gmhl0191