Monsanto Papers | Secret Documents | Page Four

Issue: Ghostwriting, Peer-Review & Retraction…continued

26. Internal Emails Show Monsanto Made Substantial Contributions to Published Expert Panel Manuscript
No: MONGLY00998682, MONGLY00998687
Date: 1/9/2016 – 1/13/2016
Documents Released: 8/1/2017

Description
The documents contain email correspondence between Dr. William Heydens and Ashley Roberts (Intertek) wherein Dr. Heydens heavily edits (“here are my suggested edits to the Draft Combined Manuscript” at *1) the Expert Panel’s manuscript drafted in opposition to IARC’s classification of glyphosate. The edited draft is also attached and challenged for confidentiality.

Relevance
The documents are relevant and reasonably likely to be used in this litigation as they demonstrate that the manuscript published under the authorship of the Expert Panel was composed with substantive contributions by Monsanto. Monsanto did not disclose its role in drafting the manuscript which directly challenged the general causation “2A probable carcinogen” conclusion by IARC. Indeed, Monsanto own experts rely on the “Expert Panels” analysis. The reliability and consensus of scientific literature is directly relevant to general causation. These documents also go to witness credibility.

27. Internal Email Further Demonstrating Heydens’ Involvement in Drafting Expert Panel Manuscript
No: MONGLY02085862
Date: 2/4/2016
Documents Released: 8/1/2017

Description
This document contains an email from Dr. Heydens to Ashely Roberts regarding the introduction to the Expert Panel Manuscript. Among other features, Dr. Heydens’ draft attempts to convey “that glyphosate is really expansively used.” at *1.

Relevance
It is relevant and reasonably likely to be used in this litigation for the same reasons as the above (MONGLY01000676) document. The reliability and consensus of scientific literature is directly relevant to general causation. This document also goes to witness credibility.

28. Monsanto Executive William Heydens’ Edits and Comments on Expert Consultant Manuscript
No: MONGLY01000676, MONGLY01000680
Date: 2/8/2016 – 2/9/2016
Documents Released: 8/1/2017

Description
This document contains correspondence between Dr. William Heydens and Ashely Roberts regarding the Expert Panel Manuscript. Dr. Heydens went “through the entire document and “indicated what I think should stay, what can go, and in a couple spots I did a little editing. I took a crack at adding a little text: on page 10 to address John’s comments about toxicologists’ use of Hill’s criteria … see what you think; it made sense to me, but I’m not sure if it will to others – please feel free to further modify and/or run by Cary.” at *1. The edited draft is also attached and challenged for confidentiality.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it demonstrates Monsanto’s significant role in drafting and editing the manuscript by its expert consultants without disclosing its contributions. The document is related to how the inherent conflict of interest may affect the credibility of manuscript which refuted IARC’s general causation conclusion. The reliability and consensus of scientific literature is directly relevant to general causation. These documents also go to witness credibility

29. Editor of Journal That Published Expert Panel Manuscript States Intention of the Panel was to Discredit IARC
No: MONGLY02356274, MONGLY02356209
Date: 6/19/2016 – 7/7/2016
Documents Released: 8/1/2017

Description
This document contains email correspondence between Roger McClellan (editor of the journal which published the Expert Panel Manuscript) and Ashley Roberts regarding the Expert Panel Manuscript. Mr. McClellan notes several issues with the initial daft of the Manuscript and states: “These reports are essentially a rebuttal of IARCs process and conclusions. There appears to be a reluctance to be absolutely clear in presenting exactly what IARC concluded, the Panels conclusions and how they differ.” at *4. The attached initial draft of the manuscript is also challenged for confidentiality.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it contains an opinion by the editor of the journal which published the Expert Panel Manuscript that the Manuscript essentially sought to discredit IARC and IARC’s methodology which offered a general causation conclusion regarding glyphosate carcinogenicity that was adverse to Monsanto’s commercial agenda. The reliability and consensus of scientific literature is directly relevant to general causation. These documents also go to witness credibility.