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.
