19.
Monsanto Scientist Admits to Ghostwriting Cancer Review Paper
No: MONGLY01723742
Date: 8/4/2015
Documents Released: 8/1/2017
Description
This document is from the custodial file of Dr. David Saltmiras and is
titled “Glyphosate Activities”. Dr. Saltmiras’ activities
for 2015 included: “IARC prep: AHS Sorahan reanalysis for multiple
myeloma presented at EUROTOX 2012, Kier & Kirkland (2013), ghost wrote
cancer review paper Greim et al. (2015), coord Kier (2015) update to K&K,
pushed for Sorahan (2015).”
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it demonstrates Monsanto’s involvement in ghostwriting studies
discussing the carcinogenic potential of glyphosate which is subsequently
relied upon by the scientific community in determining general causation
issues such as the biological plausibility of glyphosate as a carcinogen.
The reliability and consensus of scientific literature is directly relevant
to general causation. This document also goes to witness credibility.
20.
Email Showing Monsanto Paid Multiple Individuals on Expert Panel Prior
to and During Review on Glyphosate
No: MONGLY02816607
Date: 8/6/2015 – 8/14/2015
Documents Released: 8/1/2017
Description
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.
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