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Philip Morris

Cipollone V. Liggett Group, Inc., Et Al. In the Cipollone Civil Action No. 83-2864sa

Date: 1986 (est.)
Length: 4 pages
2024941548-2024941551
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Fields

Type
REPT, REPORT, OTHER
Named Organization
American Cancer Society
Ctr, Council for Tobacco Research
Library of Congress
Lm, Liggett & Myers
Lor, Lorillard
Natl Library of Medicine
Ny Academy of Medicine
TIRC, Tobacco Industry Research Comm
Litigation
Okag/Privilege Withdrawn
Okag/Produced
Site
N28
Named Person
Burnham, J.C.
Cipollone
Harris, J.
Area
LEGAL DEPT/CARLSTADT
Document File
2024941547/2024941575/Burnham, John Def. Exp. - Psychology, History
Date Loaded
14 May 1999
UCSF Legacy ID
uil87e00

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Page 1: uil87e00
- 1 - RE: Cipollone v. Liggett Group, Inc., et al. In the Cipollone Civil Action No. 83-2864SA Pursuant to the Court's Case Management Order of June 13, 1986, and pursuant to the agreement of counsel, please be advised that Defendants (Philip Morris, Inc., Liggett Group, Inc. and Lorillard, Inc.) may call Dr. John C. Burnham (c.v. previously provided) to testify concerning the analysis performed by Dr. Jeffrey Harris as set forth in his "State-of-the-Art" report of 8/1/85 and as discussed in his deposition, and to testify on subjects relating to the state of scientific/medical knowledge of cancer generally and an alleged link between cigarette smoking and lung cancer prior to the 1960's. Dr. Burnham is also expected to testify concerning the response of the tobacco industry to scientific claims that cigarette smoking may cause lung cancer. Dr. Burnham is expected to testify that the Harris report is a standard literature survey and, as such, is an "ahistorical" presentation of the state of scientific/medical knowledge in the 1920's, 1930's, 1940's and 1950's. Dr. Burnham will testify that Dr. Harris ascribes to research conducted in the 1920's, 1930's and 1940's a significance that it did not have to the community of scientific/medical experts at that g
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-a- time. Dr. Burnham is expected to testify that in order to assess the state of scientific knowledge at a point in history, the research must be viewed in its proper historical perspective. Dr. Burnham is expected to testify that the state of scientific knowledge, as measured by the scientific community of leading cancer researchers, was negative or strongly skeptical of any link between cigarette smoking and lung cancer prior to the 1950's. There are a number of factors that Dr. Burnham is expected to cite in support of his opinion including, but not limited to, the fact that scientific understanding of cancer generally and the statistical tools necessary to infer a link between smoking and lung cancer were in early stages of development and acceptance. Specifically, Dr. Burnham is expected to cite, for example, factors such as "noise" in cancer research generally; negative results achieved in attempting to produce tumors using tobacco tar; skepticism among medical/scientific experts _:61 about the usefulness/validity of statistics to establish a causal link between exposure and disease; and various theories of cancer causation held by the experts of the time. Dr. Burnham is also expected to testify concerning the response of the tobacco industry to scientific questions raised concerning a link between
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- 3 - cigarette smoking and lung cancer, including the formation of The Council for Tobacco Research (and its predecessor, Tobacco Industry Research Council). Dr. Burnham is expected to testify that the tobacco industry's response was both timely and appropriate and constituted a respectable/commendable scientific effort -- among other things it utilized peer review, co-funded research with other leading research institutions, developed a training grants program, was patterned after leading cancer research groups, and was headed up by a former president of the American Cancer Society. Dr. Burnham bases his opinion upon his life-long study of the history of American science and medicine, his professional experience and expertise, his review of pertinent literature and other information reasonably relied upon by experts in his field, and his continuing research. Specifically, Dr. Burnham has consulted, among other things, materials published in the 1920's through 1960 including medical and scientific textbooks, and monographs, articles and abstracts in technical and scientific journals, reports of scientific meetings and congresses, press reports of events in science, testimony and recollections of participants and witnesses concerning relevant research, and records of activities carried out by medical and scientific groups. -~ Dr. Burnham has conducted research at a number of
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4 institutions including the National Library of Medicine and the Library of Congress in Washington, D.C. and several other major library collections including the New York Academy of Medicine in New York City and has used materials from the Archives in Chicago, Minneapolis and Washington, D.C. Dr. Burnham may also be asked to comment upon the opinion and bases thereof expressed by Plaintiff's witnesses in this matter.

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