Bliley American Tobacco Co
Confidential outline prepared by American outside counsel containing outside counsel's analysis and opinions regarding deposition testimony.
Fields
- Privilege
- AC/WP
- Type
- Outline
- Request
- A,B,C
- 02,03,06,09
- Date Loaded
- 22 Apr 1998
- Author (Organization)
- Chadbourne & Parke 1
- Folder
- Smoking & Cancer
Annotations
- 1. Chadbourne & Parke Author (Organization)
inferred
Document Images
Outline of Deposition of
ROBERT CASAD HOCKETT
Taken on behalf of plaintiffs on
November 3, 1959
Direct
Page No.
116-118
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produces documents of TIRC called for by
subpoena duces tecum
he is a Ph.D. and Associate Scientific
Director of TIRC; not an M.D.
TIRC first organized in 1954; believes Hahn
was one of organizers. TIRC organized because
of concern over smoking - health reports
claims made of statistical association between
smoking and lung cancer
very little relevant evidence has come from
clinical or experimental work
have been animal studies with condensed cigar-
ette smoke -- mice, rabbits, hamsters, fowl,
rats, dogs
are claims that skin cancer has been produced
in mice by application of cigarette smoke con-
densate
TIRC has sponsored similar mice studies; TIRC
does not do original research, but it provides
money so that research may be conducted by
others
TIRC's principal grant to Dr. Bock of Roswell
Mem. Inst. in Buffalo who reported that he had
produced tumors on skin of painted mice
thinks there are 3 or 4 studies which reported
tumors in animals
most of tumors produced were benign; a few
malignant
Wynder and Bock produced tumors in mice; he
has conferred with them
has read reports that tumors have appeared on
ears of rabbits painted with tobacco smoke
condensate

Page No.
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he has not examined Wynder's or Bock's slides
concept of "pre-cancerous state" is contro-
versial and unclear
several statistical studies report an asso-
ciation between smoking and lung cancer but
these are disputed by some outstanding statis-
ticians
his committee has not taken any position
there is a statistical association between
smoking and stomach ulcers but he believes it
is non-causal
does not know if there is any statistical
study that says there is no correlation be-
tween cancer and smoking but there is one that
throws doubt on this assertion
there are studies.which show a low degree of
correlation and others that show a high degree
of correlation. This quantitative difference
throws doubt on meaning of relationship
not all who have reviewed this subject have
claimed there is a relationship
Eastcott found lung cancer more prevalent in
English emigres to New Zealand than in New
Zealanders but study did not go into smoking
habits
cannot cite any study that .positively dis-
proves a possible statistical relationship
between cancer and smoking
statistical correlation creates a presumption
of causal relationship, which is the reason
for the research program
animal experiments of some assistance
skin is not the right tissue to test in order
to get information about effect on lung
knows of 4 tests sponsored by TIRC to see
effect of smoke on animal lungs and 6 or 8
such tests abroad
Dr. Cecelie Leuchtenberger got no cancers in
animals' lungs but did get sporadic bronchitis.
Also slides revealed conditions which some
pathologists might interpret as pre-cancerous
(metaplasia and carcinoma in situ)
70% of all people whose lungs are examined at
autopsies show metaplasia

Page No.
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if animals continued smoking they did not be-
come cancerous and if smoking discontinued
metaplasia went away
definition of carcinoma in situ; pathologists
disagree about it
Leuchtenberger report referred to condition in
mice similar to carcinoma in situ in man
subsequent Leuchtenberger report showed dis-
plasias stopped when smoke exposure stopped, i.e.,
not precancerous
most squamous metaplasia never becomes cancer-
ous
TIRC sponsored study by 12 pathologists who
studied cancer specimens from human patients
and tried to find out smoking history
Auerbach studied lungs to compare lungs of
smokers and non-smokers and reported more meta-
plasias in smokers. He found frequent carcinoma
in situ, but this was not confirmed in the TIRC
study which found only 3 or 4 or 6 specimens of
carcinoma in situ in the i000 - 2000 cases
examined
Hammond says chances of developing cancer are
less when you give up smoking but Hockett ques-
tions statistical soundness
does not claim to be an expert in statistics
does not know how many retrospective studies
have claimed correlation between smoking and
lung cancer
knows there have been 3 or 4 prospective statis-
tical studies
does not agree with conclusion of "study group"
does not think question is settled by opinion
of British Government
does not know whether there is a causal rela-
tionship between smoking and cancer because no
experimental evidence of any real consequence
fact that people who are smokers die of lung
cancer could be due to common factor rather than
cause and effect
some people may be predisposed to cancer
likely that the association is accidental in
cardiovascular disease
3

Pa@e No.
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Cross
agrees with Little that question of smoking -
lung cancer is still scientifically open
never discussed with Auerbach his work but did
invite him to meeting which he did not attend
TIRC has not recommended to ATCo. that it reduce
amount of tar in Lucky Strikes
TIRC has sponsored a few projects on basic
knowledge of cancer which had nothing to do
directly with cancer's relationship to smoking
TIRC has not made research grants in field of
filter cigarettes
TIRC has not studied possibility of reducing
tar -- it has been trying to devise better
methods of testing the sort of smoke people
were inhaling from 1913-1950
Hill and Knowlton does work for TIRC
TIRC does not publish "Tobacco and Health". It
did put out two issues through a subcommittee
called the Committee on Information but then
publication was discontinued as a TIRC function
"Tobacco and Health" designed to call attention
to findings of legitimate scientists on effect
of tobacco on health
no reference in the two issues sponsored by
TIRC to the conclusions of the "study group",
British Government, or Surg. Gen'l
168-171
171
causes of cancer are
still unknown
organization and functions of
TIRC; Scientific Advisory Board
consists of a committee of i0
scientists who determine the TIRC's
research program and allocate funds
TIRC instituted in 1954
Redirect
173
presumes tobacco smoke and particles are in part
eliminated from lung by ciliar activity

Page No.
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there are experiments on isolated animal
tissue (but none on living human lung tissue)
which show that cigarette smoke inhibits
ciliary action
does not recall any evidence showing that cilia
are shorter in smokers than in non-smokers
considers Dr. Little an expert in general field
of cancer, particularly genetic aspects
Little's 1944 speculative statement on lung
irritation from smoking is not a statement of
any direct conclusions from scientific evidence
smoke has 2 phases: one a suspension of fine
particles, the other a gas or vapor phase
does not think smoke particles will lodge in a
healthy lung
a probability that smoking causes certain amount
of irritation to some degree in the lungs
Recross
178
179
Dr. Little is Scientific Director
of TIRC
other members of board
Redirect
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Dr. Kotin, who is on Board of TIRC, said that
results of animal experiments do not suggest a
like relationship in man but greater signifi-
cance attaches if there is a demonstrable
parralelism between epidemiologic data and
laboratory findings
Hockett does not think skin studies on animals
are relevant to effect of smoke on human lungs
medical history is replete with cases where
there seemed to be a statistical relationship
between A and B which was later not sustained
many medicinal salves that have been used harm-
lessly for humans which will produce cancer on
animal skin
his field has been in nutritional problems in
chemistry and biochemistry
has had no formal medical training
