Abstract
Outlines direct examination, cross-examination, and redirect examination of Clarence Cook Litte, taken on behalf of plaintiffs, and includes the page numbers where complete responses can be found in the deposition transcript. Includes brief summaries of Little's responses to questions regarding his role on the Scientific Advisory Board (SAB) of the Tobacco Industry Research Committee (TIRC). Includes summary responses to questions regarding Little's awareness of the existence of various animal and human studies which have linked smoking and cancer and his assessment of the conclusions to which these studies arrived. Notes Little's statement that none of the statistical studies done have demonstrated a causational relationship between smoking and cancer. Mentions Hill & Knowlton's relationship to TIRC.
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pp,
189
192
192
Outline of Deposition of
oaken on behalf of pleintiffe
on ~ovenber $, 1959
not a medical doctor
Scientific Director of Scientific
~ob
formerly Cha/n~an of Scientific
Advieory Board
purpose of TZ~C to advise tobacco
industry on vorthy research pro~ects,
to try to fled out more about causcs
of lung cancer, heart disease and other
ailments supposedly related to use
tobacco
?;RC includes ell tobacco co~penAes
except Liggett s ~yers
has vcrked on cancer in mice for $2
years but has not published original
research
some people cle£= • stettst~cal
lationsh/p be~een smoking and l~ng
cancer
facte s~ov that in ~ out ~f ~0 people
a~ age ~0 and i~ out of 50 the:e As
no rela~ionship because they don~t have
cancer when they smoke
none of etatist~cal s~udtes shov
causation
"every stetisticel paper sho~ed
ebsonce of relationsh~p in ~he r~a~orlty
o~ people included An the study"
Some people claim an increase An lung
cancer among s:okera but no one knove
boy .uch As real. Het~o~ o~
greatly improved
Not true that percentage of people getting
cancer la higher among emokers ~han non-
s~okere according ~o preaent
ATIklXPRIVO01303g
Subject to Claims of Privilege and Confidentiality:
Produced Pursuant to Court Orders in State oflViinnesota, et al. v. Philip Morris, et al.

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200-201
201
2O2
203
204
207
hSgher percentage o! e~okers getting
cancer in so~e age groups - qualifies
his answer in Ble~nik hearings
~lliSr w~Ch studies Of Ha~ond end
born; he has no training in statistics
He~'~ond end florn ltltiltiCl purport to
higher risk he h~s of ~eveloplng lun~
cancer but H~r~nd and Horn have never
p~lished thelr prt~ data
Drs. Lu~ard and Sneglref~ in Boston
do no~ believe ~ere £s s steady p~-
g~ess ~n E~sk -- ~n can smoke
affec~ing statistics at all up to
certain ~int and then something hap-
pens
Lu~ard's original study Ilyl age of
greates~ ~nc~dence of lung cancer
fr~ 40 or S0 to ~5
Does no~ recall ~he~her L~ard
higher incidcnce of lung cancer
L~a=d d~d so ~nd ~or middle age
group
Dorn's s~dy shows higher incidence ~o~
"lung cance~ a~e" group a~ng smokers
association between smoking a~d
cancer in people in the lung cancer age
thinks constitutional predisposition
the ~portant factor ~n dcte~ining
whet~er a shaker vii1 get lung cancer
in early stages o~ X-ray, skin cancer
~n doctors who used It without
the~clves
e~ect between short w~ve
an~
m~ny people have been s~Jecte~ to X-rays
X-raM lpeciaZist has higher chance Of
deveZop~ng Zeuke~la than person ~ho
no~ In X-ray ~ork
kn~s of no greater Incidence o~ leukemia
~ng radiologists th~n a~ng g~ne:al p~l£c
-2-
ATMXPRI\'O013039
Subject to Claims of Privilege and Confidentiality:
Produced Pursuant to Court Orders in State of Minnesota, et al. v. Philip Morris, et al.

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Direc._____t
207°20|
208-209
210-212
212-213
225-226
216
228-229
219-220
220
222
222
was • study ehowAn9 higher incidence of
cancer of scrotum among £nglish chimney
sweeps than a~ong general
lower incidence of cancer of the penie
a~ong ~evs than among Gentiles: car-
cumcision ~a¥ be a
~ewish yemen have Zess cancer of the
uterus than noa-~evAsh wo~en
Does not know whether those with 9renter
contact vAth tuberculosis have higher
incidence of At than those not connected
with At
exposure to tuberculosis or influenza
does not create the susceptibility to
the disease. Whether person who is exo
posed to At gets the disease depends
on his own
su~ceptlble ~eople ~aM pack up a disease
earlier.than they o~herwise would have
by intense exposure to it
can't get tuberculosis without being
exposed to At but everybody who ls ex-
posed to i~ does not get It~ At depends
on whether the person As susceptible
An ~944 as managin9 ~irector of AC$ he
advised people not to inhale naterAaZ
which was irrltatAng to their lungs,
cludin9 s~oke, exhaust, cold air
his IS44 statement was not ln~ended to
show any cause and effect relatlonshAp
of any de£inable nature
1~44 statement said At would be
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 partlcles to
which he referred have anything to do
~Ath cancer
he has defAnltely stated that he does not
thank smoking is the cause of lung cancer.
Xf lc contributes anything, At As a manor
factor
fact that 9 out o~ 10 smokers don't get
At shows that smoking As not the cause
-3-
ATMXPRIVO013040
Subject to Claims of Privilege and Confidentialit),:
Produced Pursuant to Court Orders in State of I~4innesota, et al. v. Philip I~4orris, et al.

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Direct
223-224
224-225
226
226-227
229
23O
231
233
23,5
Dr. Hsm~ond's' opinion dlf[ers from his
~a~ond first implicated smoking and lung
cancer end later £mpl~cetes smoking with
a general debility because he found
h~ believed to be • valid statistical
cancer, cancer of prostate, cancer
stomach, duodenal ulcers and cirrhosis
of liver
wan~s lung cancer study to continue
has not made suggestions to A~o
reducing ~,ounts of tar and nicotine or
abou~ usln9 filters
has not told Henmer eb~ut research oh
relationship of smok£nq tO cancer and
heart d~sease or tried to influence any
of the tobacco ¢~mpsnlos' research
benzpyrene Is carcinc~enic to animals but
has never been found In • cancer in
scientists on one of TZ~C qrsnts claimed
n~co~ne affected cardiovascular system
o! rabbits
animal tests Indicate a line of work to
be ~olloved with humans b~t results are
not alveys transferable
doesn't recall any york on lowering
temperature of co:~ust£on in cigarettes
~or TI~C
TIRC has been absolutely free from in-
dustry opinion and prsssura
Little's previous training and experience
included 50 years of research on cause
and nature of cancer in animals
in his work he examined tissues but also
had a ~ull-time trained pathologist tO
do it
-4-
ATMXPRIV0013041
Subject to Claims of Privilege and Confidentiality:
Produced Pursuant to Court Orders in State of Minnesota, et al. v. Philip Morris, et al.
