Bliley American Tobacco Co
Confidential outline prepared by American containing outside counsel's analysis and opinions regarding deposition testimony.
Fields
- Privilege
- AC/WP
- Type
- Outline
- Request
- A,B,C
- 02,03,06,09
- Date Loaded
- 22 Apr 1998
- Author (Organization)
- Chadbourne & Parke 1
- Folder
- Smoking & Cancer
Annotations
- 1. Chadbourne & Parke Author (Organization)
inferred
Document Images
Outline of Deposition of
CLARENCE COOK LITTLE
taken on behalf of plaintiffs
on November 3, 1959
Direct
pp. 188
188
188-189
189
189
190
191
191-192
192
193
193
194
not a medical doctor
Scientific Director of Scientific
Advisory Board of TIRC -- part time
job
formerly Chairman of Scientific
Advisory Board
purpose of TIRC to advise tobacco
industry on worthy research projects,
to try to find out more about causes
of lung cancer, heart disease and other
ailments supposedly related to use of
tobacco
TIRC includes all tobacco companies
except Liggett & Myers
has worked on cancer in mice for 52
years but has not published original
research
some people claim a statistical re-
lationship between smoking and lung
cancer
facts show that in 9 out of i0 people
at age 80 and 49 out of 50 there is
no relationship because they don't have
cancer when they smoke
none of statistical studies show
causation
"every statistical paper showed the
absence of relationship in the majority
of people included in the study"
Some people claim an increase in lung
cancer among smokers but no one knows
how much is real. Method of diagnosis
greatly improved
Not true that percentage of people getting
cancer is higher among smokers than non-
smokers according to present statistics

Direct
195-197
198
198-199
199
200-201
201
202
203
204
205
205
206
207
207
higher percentage of smokers getting
cancer in some age groups - qualifies
his answer in Blatnik hearings
familiar with studies of Hammond and
Dorn; he has no training in statistics
Hammond and Horn statistics purport to
show that the more a person smokes the
higher risk he has of developing lung
cancer but Hammond and Horn have never
published their primary data
Drs. Lumbard and Snegireff in Boston
do not believe there is a steady pro-
gress in risk -- men can smoke without
affecting statistics at all up to a
certain point and then something hap-
pens
Lumbard's original study says age of
greatest incidence of lung cancer is
from 40 or 50 to 65
Does not recall whether Lumbard found
higher incidence of lung cancer in
smokers than in non-smokers but thinks
Lumbard did so find for middle age
group
Dorn's study shows higher incidence for
"lung cancer age" group among smokers
majority of statistical studies show an
association between smoking and lung
cancer in people in the lung cancer age
thinks constitutional predisposition is
the important factor in determining
whether a smoker will get lung cancer
in early stages of X-ray, skin cancer
in doctors who used it without shielding
themselves
effect between short wave irradiation
and leukemia
many people have been subjected to X-rays
without getting leukemia
X-ray specialist has higher chance of
developing leukemia than person who is
not in X-ray work
knows of no greater incidence of leukemia
among radiologists than among general public
-2-

Direct
207-208
208-209
209
210-212
212-213
215-216
216
218-219
219-220
220
221
221
222
was a study showing higher incidence of
cancer of scrotum among English chimney
sweeps than among general population
lower incidence of cancer of the penis
among Jews than among Gentiles; cir-
cumcision may be a factor
Jewish women have less cancer of the
uterus than non-Jewish women
Does not know whether those with greater
contact with tuberculosis have higher
incidence of it than those not connected
with it
exposure to tuberculosis or influenza
does not create the susceptibility to
the disease. Whether person who is ex-
posed to it gets the disease depends
on his own susceptibility
susceptible people may pick up a disease
earlier than they otherwise would have
by intense exposure to it
can't get tuberculosis without being
exposed to it but everybody who is ex-
posed to it does not get it; it depends
on whether the person is susceptible
in 1944 as managing director of ACS he
advised people not to inhale material
which was irritating to their lungs, in-
cluding smoke, exhaust, cold air
his 1944 statement was not intended to
show any cause and effect relationship
of any definable nature
1944 statement said it would be unwise
to fill lungs with fine particles in
tobacco smoke
1944 statement was wrong because experi-
ments of cause and effect relationship
don't believe the smoke particles to
which he referred have anything to do
with cancer
he has definitely stated that he does not
think smoking is the cause of lung cancer.
If it contributes anything, it is a minor
factor
fact that 9 out of i0 smokers don't get
it shows that smoking is not the cause
-3-

Direct
223-224
224-225
226
226-227
229
230
231
233
234
235
236
Dr. Hammond's opinion differs from his
Hammond first implicated smoking and lung
cancer and later implicates smoking with
a general debility because he found what
he believed to be a valid statistical as-
sociation between smoking and lung
cancer, cancer of prostate, cancer of
stomach, duodenal ulcers and cirrhosis
of liver
wants lung cancer study to continue
has not made suggestions to ATCo regarding
reducing amounts of tar and nicotine or
about using filters
has not told Hanmer about research on
relationship of smoking to cancer and
heart disease or tried to influence any
of the tobacco companies' research
benzpyrene is carcinogenic to animals but
has never been found in a cancer in man
scientists on one of TIRC grants claimed
nicotine affected cardiovascular system
of rabbits
animal tests indicate a line of work to
be followed with humans but results are
not always transferable
doesn't recall any work on lowering
temperature of combustion in cigarettes
Hill & Knowlton is Public Relations firm
for TIRC
TIRC has been absolutely free from in-
dustry opinion and pressure
Cross
237-238
Little's previous training and experience
included 50 years of research on cause
and nature of cancer in animals
Redirect
238-239
in his work he examined tissues but also
had a full-time trained pathologist to
do it
-4-
