Monsanto Papers | Secret Documents | Page Three

This document contains email correspondence between various Monsanto employees wherein Dr. Donna Farmer comments with respect to the Expert Panel: “We have another consulting doing the same thing that John Acquavella is doing for the epidemiology area… Larry Kier is facilitating the gentox area of the expert, panel. We have had a contract with Larry Kier before. How do we get this set up for Larry so that he too can be paid – 12K in 2015? at *2.

Relevance
The document does not contain trade secrets, sensitive commercial information or privileged material. This document is relevant and reasonably likely to be used in this litigation as it demonstrates that Drs. Acquavella and Kier were hired Monsanto consultants prior to and during the expert panel- this inherent conflict of interest was not disclosed by the published manuscript which offered a rebuttal of IARC’s general causation opinion. The reliability and consensus of scientific literature is directly relevant to general causation. This document also goes to witness credibility.

21. Email Showing Monsanto Paid a Consultant on Expert Panel Believed to be Composed of Independent Scientists
No: MONGLY01680756
Date: 8/17/2015
Documents Released: 8/1/2017

Description

This document is a consulting agreement between Monsanto and Larry D. Kier, one of the individuals on the Intertek Expert Panel. Although the Expert Panel was supposed to be composed of scientists independent of Monsanto, the consulting agreement demonstrates that Dr. Kier worked directly for Monsanto and this relationship was not disclosed in the published manuscript.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it indicates the inherent conflict of interest between Dr. Kier as a consultant for Monsanto and his participation on the expert panel, which was concerned with addressing the general causation conclusion by IARC. The reliability and consensus of scientific literature is directly relevant to general causation. This document also goes to witness credibility.

22. Invoice Showing Monsanto Paid $20,000 to Expert Panel Member Dr. John Acquavella
No: MONGLY03934897
Date: 8/31/2015
Documents Released: 8/1/2017

Description
This document is an invoice dated August 31, 2015 from Monsanto to Dr. John Acquavella in the sum of $20,700 for “consulting hours in August 2015 related to the glyphosate expert epidemiology panel.” at *1.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it speaks to the inherent conflict of interest between Dr. Acquavella as a paid consultant for Monsanto and his participation on the expert panel, which was concerned with addressing the general causation conclusion by IARC. The reliability and consensus of scientific literature is directly relevant to general causation.

23. Monsanto Consultant Protests Ghostwriting – I Can’t be a Part of Deceptive Authorship…’
No: MONGLY01030787
Date: 11/3/2015 – 11/6/2015
Documents Released: 8/1/2017

Description
This document contains email correspondence between various Monsanto personnel and consultants wherein Dr. John Acquavella protests Monsanto’s ghost-writing activities: “I can’t be a part of deceptive authorship on a presentation or publication… We call that ghost writing and it is unethical.” at *2, 3.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it confirms Monsanto’s ghostwriting of scientific studies used by Monsanto to deny the biological plausibility of Roundup and/or glyphosate acting as a carcinogen. Regulators and scientists, relying up ghostwritten studies, cannot weigh conflicts of interest when using the data to determine causation between glyphosate and carcinogenicity. The reliability and consensus of scientific literature is directly relevant to general causation. This document also goes to witness credibility.

24. Internal Email: Monsanto Executive William Heydens Admits to Ghostwriting Introductory Chapter in Expert Panel Manuscript
No: MONGLY00999487
Date: 1/6/2016
Documents Released: 8/1/2017

Description
This document contains email correspondence between Dr. Heydens and Ashley Roberts (Intertek) wherein Dr. Heydens admits to writing “a draft introduction chapter back in October/November…[a]nd then comes the question of who should be the ultimate author … you or Gary? I was thinking you for the Introduction chapter and Gary for the Summary chapter, but I am totally open to your suggestions.” at *2.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it again indicates that Monsanto was a significant contributor to the Expert Panel Manuscript without disclosing its substantive role in the final publication which refuted IARC’s general causation conclusion. Dr. Heydens explicitly suggests that affiliated consultants appear as authors instead of himself. Indeed, Monsanto own experts rely on the “Expert Panels” analysis. The reliability and consensus of scientific literature is directly relevant to general causation. This document also goes to witness credibility.

25. Email Demonstrating Dr. Acquavella’s longstanding consultancy for Monsanto
No: ACQUAVELLAPROD00014559
Date: 1/7/2016
Documents Released: 8/1/2017

Description
This document contains email correspondence from 2016 between Drs. Acquavella and Heydens discussing Dr. Acquavella’s consulting for Monsanto “on glyphosate litigation.” at *2.

Relevance
The document does not contain trade secrets, sensitive commercial information or privileged material. This document is relevant and reasonably likely to be used in this litigation as it demonstrates Dr. Acquavella’s long-term consultancy for Monsanto on glyphosate-related issues, specifically with respect to the general carcinogenicity of glyphosate. The reliability and consensus of scientific literature is directly relevant to general causation.