Day 254 - 22 May 96 - Page 67


     
     1   MR. JUSTICE BELL:  If he does not know?
     2
     3   MR. MORRIS:  He cannot really rely on it if he does not know can
     4        he?
     5
     6   MR. JUSTICE BELL: He says ----
     7
     8   MR. MORRIS:  I know it says it in the pamphlet number 7 by
     9        Mr. Hill, but you based your statement very much on what
    10        Mr. Hill was saying in his pamphlet, some of the wording
    11        seems to be?
    12        A.  Yes, I was actually quoting from the publication.
    13
    14   Q.   Right.  But there are no quotation marks in your report is
    15        there?
    16        A.  No.
    17
    18   Q.   You have relied really a lot on what he has said, his
    19        opinions?
    20        A.  No, I do not think that is fair.  I have tried to
    21        analyse what he has said and applied my own opinions to
    22        that.  But he has had the advantage of recently reviewing
    23        all the literature, and if you look at the list of ----
    24
    25   Q.   But you have not reviewed that literature yourself?
    26        A.  Not recently.
    27
    28   Q.   You have not looked at the international figures and
    29        reports that he quotes, so you are relying on his analysis
    30        and his research work?
    31        A.  If you look at the references that he quotes these are
    32        internationally accepted references.
    33
    34   Q.   Yes, but you are relying on his interpretation, his ----
    35        A.  No, no.  If you are talking about ----
    36
    37   Q.   If he has made mistakes, you would not notice because you
    38        had not done that research work yourself, you had not
    39        necessarily looked at the same papers he has looked at?
    40        A.  But this is a widely accepted fact, that the incidence
    41        of these cancers is less in these countries.
    42
    43   Q.   I am talking about in general in his report.
    44
    45   MR. JUSTICE BELL:   Is there anything you actually challenge in
    46        Hill that you are suggesting would be wrong?
    47
    48   MR. MORRIS:  I am trying to find out the source of the witness's
    49        facts and analyses?
    50        A.  As I already said in the report, many of the articles 
    51        that Hill quotes I have already reviewed and quoted in my 
    52        first report to the court.  So, I actually have read all 
    53        those references, yes.
    54
    55   Q.   You have.  That is before you came to court before?
    56        A.  Yes.
    57
    58   Q.   Right.  So, effectively, there is absolutely nothing that
    59        has changed in the last two years?
    60        A.  Well...

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