Monsanto Roundup Case Depositions (State and Federal Court)

John Acquavella (Former Monsanto Epidemiologist, Consultant)

Kirk Azevedo (Former Monsanto Sales Representative)

Charles Benbrook (Plaintiff Expert Witness, Former Executive Director National Academy of Sciences Board on Agriculture)

Aaron Blair (Plaintiff Expert Witness, Scientist Emeritus at the National Cancer Institute Division of Cancer Epidemiology & Genetics, Occupational and Environmental Epidemiology Branch)

Christopher Corcoran (Defense Expert Witness, Professor of Mathematics and Statistics and Director of Data Management and Statistics Core, Center for Epidemiologic Studies, at Utah State University)

Donna Farmer (Monsanto Product Protection and Nutrition Lead)

William Fleming (Defense Expert Witness, Professor of Pediatrics, School of Medicine at Oregon Health & Science University)

Warren Foster (Defense Expert Witness, Professor, Reproductive Biology Division in the Department of Obstetrics & Gynecology at McMaster University)

John R. Fowle III (Defense Expert Witness, Former Deputy Director, Health Effects Division, Office of Pesticide Programs, U.S. Environmental Protection Agency)

Daniel Goldstein (Monsanto Lead Medical Sciences and Outreach)

Jay Goodman (Defense Expert Witness, Professor of Pharmacology & Toxicology

at Michigan State University)

Hugh Grant (Monsanto Chairman and Chief Executive Officer, 2003-2018)

James Guard (Global Roundup Lawn & Garden Lead, Bayer Crop Science)

Neel Gupta, M.D. (Treating Physician for Plaintiff Alberta Pilliod)

Edwin Hardeman (Plaintiff in Hardeman v. Monsanto Co.)

William Heydens (Monsanto Regulatory Product Safety Assessment Lead)

Charles Jameson (Plaintiff Expert Witness, Former Senior Chemist for the National Cancer Institute’s Rodent Bioassay Program)

Daniel Jenkins (Former Monsanto US Agency Manager for Regulatory Affairs)

Dewayne “Lee” Johnson (Plaintiff in Johnson v. Monsanto Co.)

Larry Kier (Monsanto consultant)

Michael Koch (Product Safety Team Lead, Bayer Crop Science) – Edwin Hardeman v. Monsanto

Mark Martens (Former Monsanto Executive, Toxicology Agriculture Research & Development Director for Monsanto Europe) Re: Dr. Parry Report – Edwin Hardeman v. Monsanto Co.

Doreen Manchester (Deputy General Counsel for CropLife America)

Roger McClellan (Editor in Chief at Critical Reviews in Toxicology)

Lorelei Mucci (Defense Expert Witness, Associate Professor of Epidemiology at Harvard T.H. Chan School of Public Health)

Samuel Murphey (Head of Global Issues Management, Bayer Crop Science)

Chadi Nabhan (Plaintiff Expert Witness, Chief Medical Officer for Cardinal Health, Chicago)

Alfred Neugut (Plaintiff Expert Witness, Medical Oncologist and Professor of Cancer Research and Professor of Medicine and Epidemiology at Columbia University)

Christopher Portier (Plaintiff Expert Witness, Former Director of the Agency for Toxic Substances and Disease Registry)

Kavitha Raj, M.D. (Treating Physician for Plaintiff Alva Pilliod)

Todd Rands (Global Corporate Strategy, External Advocacy Lead & Strategic Transactions Counsel, Monsanto/Bayer)

William Reeves (Global Health and Safety Issues Management Lead, Bayer Crop Science)

Jennifer Rider (Defense Expert Witness, Adjunct Assistant Professor in the Department of Epidemiology at Harvard T.H. Chan School of Public Health)

Beate Ritz (Plaintiff Expert Witness, Chair of the Epidemiology Department at the University of California, Los Angeles)

Matthew Ross (Plaintiff Expert Witness, Associate Professor at the College of Veterinary Medicine, Mississippi State University)

James Rubenstein, M.D. (Treating Physician for Plaintiff Alberta Pilliod)

Andrei Shustov (Plaintiff Expert Witness, Oncologist at Seattle Cancer Care Alliance)

Richard Turley (Edwin Hardeman’s Physician)

Roger Turk (Edwin Hardeman’s Physician)

Dennis Weisenburger (Plaintiff Expert Witness, Chairman of the Department of Pathology at City of Hope National Medical Center)

Jeffrey Ye (Edwin Hardeman’s Physician)

Court Papers from Monsanto Roundup MDL

Hundreds of Monsanto Roundup lawsuits have been consolidated into a multi-district litigation (MDL-2741 In Re: Roundup Products Liability Litigation) before U.S. District Judge Vince Chhabria in the Northern District of California in San Francisco. Below are court documents pertaining to the Monsanto Roundup MDL (federal litigation).

Supplemental Science Week Testimony, Dr. Beate Ritz(176 pages) (4.4.18)

Supplemental Science Week Testimony, Dr. Christopher Portier(190 pages) (4.6.18)

Monsanto Daubert Hearing Oral Argument Transcript(pages 1-97) (3.14.18)

Science Week Hearing Transcript Day 1(213 pages) (3.5.18) – On the first day of Science Week, U.S. District Court Judge Vince Chhabria heard from Dr. Beate Ritz Chair of the Epidemiology Department at UCLA, of Occupational and Environmental Health (COEH), and Dr. Dennis Weisenburger, Chair of the Pathology Department of the City of Hope Medical Center, Omaha, Nebraska.

Science Week Hearing Transcript Day 2 (pages 214-370) (3.6.18) – On the second day of Science Week, the court recalled Dr. Dennis Weisenburger, Chair of the Pathology Department of the City of Hope Medical Center, Omaha, Nebraska. Judge Chhabria also heard from Dr. Alfred Neugot, a Professor of Cancer Research and Professor of Medicine and Epidemiology at Columbia University, and Associate Director for Population Sciences for the Herbert Irving Comprehensive Cancer Center.

Science Week Hearing Transcript Day 3(pages 371-595) (3.7.18) – The third day of Science Week, included testimony from Dr. Alfred Neugut, a Professor of Cancer Research and Professor of Medicine and Epidemiology at Columbia University, and Associate Director for Population Sciences for the Herbert Irving Comprehensive Cancer Center; Dr. Charles Jameson, who worked for the National Institute of Health’s National Cancer Institute and was a member of the IARC Working Group for Monograph 112; and Dr. Christopher Portier, formerly of the National Institute for Environmental Sciences National Toxicology Program, the National Center for Environmental Health, Center for Disease and Prevention, and the Agency for Toxic Substances and Disease Registry.

Science Week Hearing Transcript Day 4(pages 596-770) (3.8.18) – The fourth day of Science Week, included testimony from Dr. Christopher Portier, formerly of the National Institute for Environmental Sciences National Toxicology Program, the National Center for Environmental Health, Center for Disease and Prevention, and the Agency for Toxic Substances and Disease Registry; Dr. Aaron Blair and Dr. Matthew Ross, both of IARC Working Group 112 (by deposition); Dr. Thomas Rosol and Dr. Christopher Corcoran, both experts for Monsanto

Science Week Hearing Transcript Day 5(pages 771-1012) (3.9.18) – The fifth and final day of Science Week included testimony from Dr. Chadi Nabhan, a board-certified clinical medical oncologist and past Assistant Professor of Medicine at the University of Chicago; Dr. Christopher Corcoran, professor of Mathematics and Statistics and director of Data Management and Statistics Core, Center for Epidemiologic Studies at Utah State University; and Dr. Lorelei A. Mucci, associate professor of Epidemiology at Harvard T.H. Chan School of Public Health and assistant professor of Medicine at Harvard Medical School.

Supplemental Expert Report of Dr. Chris Portier (7 pages) (2.16.18)

Supplemental Expert Report of Dr. Dennis Weisenburger in Support of General Causation(5 pages) (2.16.18)

Supplemental Expert Report of Alfred Neugut (14 pages) (2.16.18)

Supplemental Expert Report of Dr. Beate Ritz(14 pages) (2.16.18)

Dr. Chris Portier Expert Report(97 pages) (10.28.17)

Expert Report Problems with AHS Study(14 pages) (10.28.17)

Deposition of Matthew Ross and related documents(398 pages) (10.28.17)

Plaintiffs’ (1) Response in Opposition to Monsanto Company’s Daubert and Summary Judgment Motion Based on Failure of General Causation Proof and (2) Daubert Motion to Strike Certain Opinions of Monsanto Company’s Expert Witnesses (79 pages) (10.27.17)– A Daubert motion is used to exclude expert witness testimony when an expert does not possess the requisite level of expertise or used questionable methods to obtain data. In response to Monsanto’s Daubert, attorneys for the Plaintiffs list the many reasons why there is no basis to exclude the Plaintiffs’ general causation experts’ opinions. In the Plaintiffs’ Daubert motion, attorneys argue that several of Monsanto’s expert witnesses do not apply reliable methodologies in reaching their opinions.

Expert Report of Dr. Portier in Support of General Causation(250 pages) (10.6.17)

Expert Report of Dr. Dennis Weisenburger(150 pages) (10.6.17)

Expert Report of Dr. Alfred Neugut(127 pages) (10.6.17)

Expert Report of Dr. Chadi Nabhan(61 pages) (10.6.17)

Expert Report of Dr. Beate Ritz (73 pages) (10.6.17)

Expert Report of Dr. Charles Jameson(77 pages) (10.6.17)

European Parliament requesting U.S. court documents in Monsanto Roundup litigation (3 pages) (7.13.17) – Four members of EU Parliament wrote a letter to U.S. District Judge Vince Chhabria asking for access to court documents from the Roundup cancer litigation. The letter expressed “strong doubts” on the validity of EU glyphosate assessments.

Monsanto’s notice of appeal and representation statement (5 pages) (7.6.17)

Order granting motion to remand (3 pages) (7.5.17) – U.S. District Judge Vince Chhabria granted the motion of Plaintiffs to move their Roundup cancer case against Monsanto back to state court in Northern California, despite Monsanto’s efforts to keep the case in federal court. In his ruling, Judge Chhabria rejected Monsanto’s theory for keeping the case federal, and warned of fees if the court is “presented with similarly flimsy theories of removal in the future.”

Videotaped deposition of John Acquavella PhD, day 1 redacted (146 pages) (Discovery document not filed in court) (7.3.17)

Videotaped deposition of Matthew Ross PhD (315 pages) (Discovery document not filed in court) (7.3.17)

Aaron Earl Blair deposition (301 pages) and exhibits 1, 2, 3, 4, 5, 6, 7, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19A, 19B, 20, 21, 22, 23, 24, 25, 26, 27, 28. (6.16.17)

Remand hearing transcript (19 pages) (6.15.17)

Unredacted versions of plaintiffs’ motion to compel the production of kidney tissue slides and exhibits 1 and 4(18 pages) (6.8.17) – Roundup cancer attorneys have hired an expert pathologist to analyze the tissue slides from a 1983 Monsanto rodent study on Glyphosate. The analysis could help prove that Monsanto covered up known health risks associated with glyphosate.

Conditional transfer order (CTO-21)(2 pages) (6.1.17)

Miller FOIA lawsuit v. EPA(9 pages) (5.29.17)

Pretrial order no. 24: modified schedule for general causation phase(2 pages) (5.26.17)

Monsanto supplement to May 22, 2017 discovery letter(1 page) (5.26.17)

Plaintiffs’ supplement to May 22, 2017 discovery letter(2 pages) (5.26.17)

Letter on dispute over renal tissue slides from Study BDN-77-420 and schedule(5 pages) (5.22.17)

Plaintiffs’ opposition to continuance of hearing date for plaintiffs’ remand motion(5 pages) (5.19.17)

Monsanto motion to continue unilaterally-noticed hearing date for plaintiffs’ remand motion(5 pages) (5.18.17)

Bio/dynamics kidney slide memo to pathologist regarding glyphosate feeding study in mice(3 pages) (5.16.17)

Memo from Monsanto’s George Levinskas on kidney tumors(2 pages) (5.16.17) – In 1985, George Levinskas, Monsanto’s manager for environmental assessment and toxicology, sent an internal memo implying that a noted academic would review tissue slides from a 1983 glyphosate rodent study and present the evaluation to EPA “in an effort to persuade the agency” that tumors observed in the study weren’t related to glyphosate exposure. The memo was purportedly written before the academic, Dr. Marvin Kuschner, had even seen the slides.

Pretrial orders on motions to compel production and additional testimony(2 pages) (5.15.17)

Plaintiffs’ reply in support of remand(14 pages) (5.12.17)

Declaration of Pedram Esfandiary in support of reply and request for attorney fees and associated costs(4 pages) (5.12.17)

Transcript of court proceedings: May 11, 2017(64 pages) (5.11.17)

Plaintiffs’ reply in further support of motion to compel responses from Jess Rowland(9 pages) (5.10.17) – Former EPA official Jess Rowland is a central figure in the Monsanto Roundup litigation. Court documents show that Rowland allegedly had a cozy relationship with Monsanto while working at EPA.

Plaintiffs’ reply in further support of motion to compel slides of kidney tissue from mice in study BDN-77-420(10 pages) (5.10.17)

Monsanto motion to strike and response re: plaintiffs’ 4/28/17 motion to file under seal(5 pages) (5.10.17)

Email from plaintiffs re: deposition of Jess Rowland(3 pages) (5.9.17)

Jess Rowland’s opposition to motion to compel responses from Jess Rowland(23 pages) (5.9.17) – Former EPA official Jess Rowland, who allegedly had ties to Monsanto while working for the agency, asked the Court to deny Roundup cancer attorneys’ motion to compel further information, and to terminate his discovery obligation.

Jess Rowland’s motion to file under seal(3 pages) (5.9.17)

Monsanto motion to strike and response re: administrative motion to file under seal(4 pages) (5.5.17)

Monsanto’s opposition to motion to compel slides of kidney tissue from mice in study BDN-77-420(10 pages) (5.5.17)

Declaration of Jess Rowland’s lawyer regarding motion to file under seal(6 pages) (5.2.17)

Monsanto’s answer to plaintiffs’ complaint(26 pages) (5.2.17)

Goodbred v. Monsanto amended complaint(41 pages) (5.2.17)

Order denying Monsanto motion to increase page limit(1 page) (5.2.17)

Pretrial order no. 20: denying motion to de-designate Heydens deposition(2 pages) (5.1.17)

Pretrial order no. 22: Jameson and Ross depositions(1 page) (5.1.17)

Plaintiffs’ arguments over duration of Jameson & Ross depositions(2 pages) (5.1.17)

Monsanto letter on Jameson & Ross depositions(3 pages) (5.1.17)

Monsanto’s motion to increase page limit for opposition to plaintiffs remand motion(3 pages) (5.1.17)

Monsanto’s motion to strike plaintiffs’ reply exhibit 1 and unredacted version of reply(4 pages) (4.28.17)

Plaintiffs’ motion to compel responses from deponent Jess Rowland(11 pages) (4.28.17) – In his deposition, Jess Rowland confirmed to Roundup cancer attorneys that since leaving EPA, he has consulted for three chemical companies with “close ties to Monsanto.”

Judge Chhabria orders Jess Rowland to answer questions about his post-EPA work(1 page) (4.24.17)

Plaintiffs request for hearing to address Jess Rowland’s refusal to answer questions(2 pages) (4.24.17)

Plaintiffs motion to compel the production of all original and re-cut slides of kidney tissue from mice in study BDN-77-420(8 pages) (4.21.17)

Monsanto’s response to plaintiffs’ request for production of documents(14 pages) (4.21.17)

Plaintiffs reply in support of motion to strike confidentiality of Heydens deposition(5 pages) (4.20.17) – Per court documents, Monsanto started the aptly-named “Let Nothing Go” program to leave nothing, not even Facebook comments, unanswered. According to the motion, “through a series of third parties, it [Monsanto] employs individuals who appear to have no connection to the industry, who in turn post positive comments on news articles and Facebook posts, defending Monsanto, its chemicals, and GMOs.

Judge Chhabria’s order on pretrial redaction of identifying information(1 page) (4.18.17)

Judge Chhabria’s order on additional discovery about IARC(1 page) (4.18.17)

Monsanto letter on privacy of non-party individuals(6 pages) (4.14.17)

Plaintiffs’ amended notice to take videotaped deposition of Jesudoss Rowland(3 page) (4.6.17)

Plaintiffs: administrative motion to file under seal(25 pages) (4.6.17), see especially pp. 6-10 – According to the documents, Monsanto executive William Heydens “appears to have spent a great deal of his career ghostwriting ‘science’ papers to protect Roundup, those efforts rivaled in time and scope only by his colleague David Saltmiras, PhD. This has been an important subject of this litigation so far, and is central to general causation; Monsanto relies heavily upon the scientific literature and governmental approvals of glyphosate for its general causation defense; as the Court is aware, however, the discovery process is yielding substantial evidence that Monsanto is often the puppetmaster behind scientific articles that are positive for the company, as well as U.S. EPA deliberations and reports.”

Monsanto: discovery dispute(10 pages) (4.4.17)

Monsanto Company’s answer to plaintiff’s complaint(31 pages) (3.24.17)

Plaintiffs’ notice to take videotaped deposition of Jesudoss Rowland(4 pages) (3.23.17)

Plaintiffs submission in response to pretrial order no. 8(3.14.17)

Judge Vince Chhabria’s ruling to unseal documents(3.13.17) – U.S. District Judge Vince Chhabria, who is overseeing the Roundup cancer MDL in Northern California, threatened to sanction Monsanto if the agrochemical giant persisted in “overbroad” efforts to keep documents relevant to the litigation out of public view. Judge Chhabrias’s ruling allowed for the unsealing of thousands of court documents obtained in discovery.

Plaintiffs’ reply in support of motion to compel deposition of Jess Rowland(2.27.17). Key document: Marion Copley letter on p. 11(2.27.17) – Marion Copley worked at EPA for decades. She and Jess Rowland worked together. In a letter to Rowland, Copley urged him, “for once in your life, listen to me and don’t play your conniving games with the science to favor” the chemical industry. Copley’s letter goes on to say that Rowland and another EPA official “intimidated staff” into changing reports on glyphosate.

Pretrial order no. 8: order requesting briefing re relevance of EPA and IARC(1.25.17)

Summary of ORD comments on OPP’s glyphosate cancer assessment(12.14.15)