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Bliley American Tobacco Co

Confidential outline prepared by American outside counsel containing outside counsel's analysis and opinions regarding deposition testimony.

Date: 03 Nov 1959
Length: 5 pages
ATMNPRIV0009200-ATMNPRIV0009204
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A,B,C
02,03,06,09
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22 Apr 1998
Author (Organization)
Chadbourne & Parke 1
Folder
Smoking & Cancer

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1. Chadbourne & Parke Author (Organization)
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Page 1: ATMNPRIV0009200
Outline of Deposition of ROBERT CASAD HOCKETT Taken on behalf of plaintiffs on November 3, 1959 Direct Page No. 116-118 120 121 122 123 124 125 125 126 126 127 127 128 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 2: ATMNPRIV0009200
Page No. 130 130-131 133 133 134 135 135-136 136 136-137 138 138-139 139 139-140 140 141-142 143 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
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Page No. 143 144 145-146 146 147 147-148 149 151 152 153 154 155 156 157 157-158 158 159 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
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Pa@e No. 160 161 162 163 163-164 164 164-165 165 166 167 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 5: ATMNPRIV0009200
Page No. 173 174 174 175 176 177 177 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 180 182 183 185 186 187 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

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