Council for Tobacco Research
Deposition of Richard E. Kouri [Deposition of Kouri in the Matter of the State of Texas]
Fields
- Master ID
- Ctrmn00043385-4499
Related Documents:- CTRMN043652-3668 Deposition of Richard E. Kouri [Deposition of Kouri in the Matter of the State of Texas]
- CTRMN043669-3670 Consultancy Agreement [Agreement to Provide Analysis of Certain Aspects of Research Performed by Microbiological Associates Inc Under Contract with Ctr]
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- CTRMN043711-3720 Chronic Inhalation Studies in Mice. II. Effects of Long-Term Exposure to 2r1 Cigarette Smoke on (C57bl/Cum X C3h/Anfcum)F, Mice Jnci Vol 77 No 1 [St 2r1 Cigarette Smoke Has Weak Carcinogenic Activity in Mouse Lung Tissue]
- CTRMN043721-3721 Ctr Meeting - October 18, 19, 20, 1978 [Controversial Contract Work Conducted by the Microbiological Associates Terminated]
- CTRMN043722-3778 Evaluation and Characterization of An Alkaline Elution Assay As A Measure of Pulmonary Dna Damage Induced by Chemical Carcinogens or the Chemicals in Cigarette Smoke [Outline of Proposed Research Includes Resume and Bibliography]
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- CTRMN043954-3954 Deposition of Richard E. Kouri [Deposition of Kouri in the Matter of the State of Texas]
- CTRMN043955-4294 "Final Report "Smoke Inhalation Studies in Mice"" [Describes Facilities, Equipment, and Results]
- CTRMN044295-4296 Executive Committee and Contract Committee Meeting [St]
- CTRMN044297-4336 Proposed Studies for Ctr 0030 - Smoke Inhalation Carcinogenesis Studies in Mice [Describes Facility for Determination of Effects of Cigarette Smoke]
- CTRMN044337-4464 Progress Report for Ctr-0030 - Smoke Inhalation Studies in Mice [Describes Procedures and Findings]
- CTRMN044465-4473 [Summary of Current Research on Smoke Inhalation in Mice]
- CTRMN044474-4487 Progress Report for Ctr-0030---Smoke Inhalation Studies in Mice [Describes Recent Findings]
- CTRMN044488-4488 Official Abstract Form the Effect of Lifetime Exposure to Whole Cigarette Smoke in Bc3f1/Cum Mice [St Describes Changes in Lungs]
- CTRMN044489-4489 [Confirms Meeting to Present Final Report for Ctr Contract 0030]
- CTRMN044490-4496 [Proposal Regarding Completion of Manuscripts From Chronic Smoke Inhalation Study]
- CTRMN044497-4497 [Requests A Special Project to Provide Support for Preparation of Manuscripts Resulting From Smoke Inhalation Study]
- CTRMN044498-4499 [Transmittal of Manuscript Regarding Chronic Inhalation Studies in Mice]
- Author
- Kouri, R.E.
- Depository Date
- 30 Sep 1997
- Box
- 268
- Type
- TRANSCRIPT
- UCSF Legacy ID
- zpt30a00
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undergraduate. My Ph.D. is in ra-liation biology from the
University of Tennessee working a: the Oak Ridge National
Laboratory, and I did a postdoctcral fellowship at the Roche
Institute for Molecular Biology in , Nutley, New Jersey, and in
the area of biochemical genetics.
Q Do you belong to any L--ofessional associations?
A Quite a few.
Q Can you name a few of :~hem for us, please?
A Human Genome Organization, American Association for
Cancer Research, the American As-so-ciation for the Advancement
of Science, probably five others.
Q Okay. Doctor, I'd like to show you a document
which I believe is your current CV and I would like you to
identify it for the record. I wcn-der if
you could look
throuah it, sir, and then tell me whether or not it is your
current CV.
A Yes, the first two paces is a summary version of
the CV and then the bibliography and the biographical sketches
is actually the latter half of t'r:is. Yeah, this is mine.
Q
It is current as of today, Doctor Kouri?
A It is current.
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MS. NIAL: I am going to make this the first
exhibit to the deposition.
(Document was marked Kouri
Deposition Exhibit No. 1).
Q (By Ms. Nial) Doctor Kouri, who first contacted
you with regard to CTR's involvement in tobacco litigation?
A Mr. Alan Scheiner.
Q And is Mr. Alan Scheiner employed by the law firm
of Debevoise & Plimpton?
Q
Yes.
Who does he represent?
A CTR.
Q And how did that first contact occur?
A He called me and asked if I would help organize
some of the files related to the numbers of-contracts that
Microbiological Associates performed under the auspices of CTR
from mostly the 1970s.
Q Did you meet with Mr. Scheiner?
A Yes.
Q How many times did you meet with Mr. Scheiner?
A Once.
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Q I wonder, Doctor, if I could show you a document.
A Yes.
Q Do you recognize that document?
A Yes.
Q It's a consultancy contract, is it, sir?
A Yes.
Q F-nd what is the date on that consultancy contract?
A February 21st, 1997.
Q P_rd have you signed that consultancy contract, sir?
A Yes.
Q With whom was that consultG~cy arrangement?
A tiv_th Debevoise & Plimpton.
MS. NIAL: I wonder if we could make that an
exhibit.
(Document was marked Kouri
Deposition Exhibit No. 2).
Q (~y Ms. Nial) Now, Doctor, after you met with or
while you were meeting with Mr. Scheiner, did you in fact
organize documents for Mr. Scheiner?
A Yes.
Q
And what documents did you organize for
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Mr. Scheiner?
A Mostly the, the proposed studies and the progress
reports related to the various contracts and work that was
going on by Microbiological Associates for CTR.
Q Did Mr. Scheiner leave any documents with you?
A No.
Q Did Mr. Scheiner provide to you a copy of your 1986
article?
A Yes. I didn't have one.
Q Did you bill Mr. Scheiner for your time?
A Originally yes, I billed for, as per the consulting
agreement and then had second thoughts about not setting up
this sort of relationship with any sort of money changing
hands and so I asked Mr. Scheiner not to pay me and in fact he
did not.
Q Did Mr. Scheiner after your meeting ask for you to
testify for CTR in the tobacco litigation?
A No.
Q Now, Doctor Kouri, you've met with me and some of
my colleagues, have you not?
A Yes.
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Q And we've met several times; is that correct?
A Yes.
Q Have we given you any money?
A No.
Q Have you signed a consultancy agreement with us?
A No.
Q Doctor, are you here pursuant to a subpoena?
A Yes.
Q You're I-=re pursuant to a subpoena from the Arch
case --
A Yes.
Q -- now called the Barnes case that you received
from Thomas Mellon; is that correct?
A Yes.
Q Is this a copy of that subpoena?
A Yes.
MIR. NIAL: We are going to make that an
exhibit and Bruce, here is one for you.
Q (By Ms. Nial) You are also here pursuant to two
subpoenas issued irn the Texas matter; is that correct?
A Yes, I think so.
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Q One from Mr. Scheir.er at Debevoise & Plimpton?
A Yes.
Q And one from Grant Kaiser who is plaintiff's
counsel in that case; is that correct?
A Yes.
MS. NIAL: We're going to make those two
exhibits.
(Documents were marked Kcuri
Denosition Exhibit Nos. 3
through 5).
Q (By Ms. Nial) Pursuant to the Debevoise & Plimpton
subpoena, you were asked to provide certain documents to
Debevoise & Plimpton, were you not?
A Yes.
Q Doctor, I ask you to look at this group of
documents.
(Witness reviewing documents).
A Yes.
Q Are those the documents that you have in your files
that are responsive to the Debevoise & Plimpton subpoena?
A Yes, that's everything I could find.
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Q
Q
Including the deposition of Carol Henry?
Correct.
We are going to give those to Mr. Merritt.
A I should say parenthetically that the deposition
from Carol Henry does have some errors in it. The book, there
is a copy of actually the book that we're all going to
describe later in there and every other page
is missing in
that deposition. It just must have been Xeroxed improperly.
Q Now, Doctor, when you said Doctor Murray, Doctor
Henry's deposition had errors in it, you mean the exhibits
were in error?
A The exhibits, yes, I'm sorry.
Q That's okay.
MS. NIAL: Just as an aside, Bruce, we have
contacted the Court Reporter to determine whether or not the
exhibit itself is correct.
MR. NIERRITT : Okay.
Can we go off the record.
(Discussion off the record).
Q (By Ms. Nial) Now, Doctor, all of your
publications are listed on your current CV; is that correct?
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A Yes.
Q You have not provided copies of those publications
to Debevoise & Plimpton?
A No.
Q And Doctor, I would like to show you a copy of
another document. And this is a copy of an affidavit signed
by you, is it, sir?
A Yes.
MS. NIAL: If we can attach that as the next
exhibit.
(Document was marked Kouri
Der)osition Exhibit No. 6)
Q (By Ms. Nial) Doctor Kouri, did you draft this
affidavit?
A Yes.
Q And you had it notarized --
A Yes.
Q -- and forwarded to my office?
A Yes.
Q And it was initially drafted for the Florida case;
do you recall?
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A Actually I guess, I think so.
Q Now, Doctor, are you familiar with the firm of
Microbiological Associates?
A Yes.
Q And what does Microbiological Associates do?
A They're a contract research organization in
:
Bethesda, Maryland, that performs a variety of contract
responsibilities for funding agencies for both govern-ent and
nongovernment sponsors.
Q Is that what they do currently, sir?
A They've expanded that to include much more work for
private industry.
Q Doctor, did you work at Microbiological Associates?
A I did.
Q When did you begin working at Microbiolocical
Associates?
A I think 1971.
Q And how long did you work at Microbiological
Associates?
A Thirteen years.
Q What was your position during the time that you
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were at Microbiological?
A I began as Project Director for a variety of
contracts and eventuated as Director of Research for the past,
for the ten years, that's the post I held at Microbiological
Associates.
Q You're not currently workinc for Microbiological
Associates?
A No, I left in 1994.
Q Why did you decide to go to Microbiological
Associates?
A They had some interest in areas that were
consistent with my interests, specifically in the areas of
carcinogen metabolism. We had some interesting information
from my postdoc, the Roche Institute, and I could continue
that work at Microbiological Associates.
Q Do you know whether or not CTR, the Council for
Tobacco Research, had any contracts with Microbiological
Associates?
A Yes.
Q Did they have more than one contract?
A Oh, yes.
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