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16. Internal Email Showing Dr. Healy Asked Colleagues to Review Study That Found Roundup and Glyphosate Adverse Effects
No: MONGLY02286842
Date: 8/19/2008
Description
This document is an email from Dr. Charles Healy to Drs. Farmer and Saltmiras
wherein Dr. Healy requests that Drs. Farmer and Saltmiras review the article that Dr. Healy has been asked
to review: "you two would be the reviewers in fact and I would then collate your comments and be the reviewer
of record." at *1.
Relevance
This document is relevant and reasonably likely to be used in this litigation
for the same reasons as the above (MONGLY01238768) document. Dr. Healy is violating the standards of the
peer-review process by asking his Monsanto colleagues to review a study which observed the cytotoxic effects
of glyphosate. Drs. Healy, Farmer, and Saltmiras all have vested interests in the study not being accepted
for publication. The reliability and consensus of scientific literature is directly relevant to general
causation. This document also goes to witness credibility.
17. Internal Email Showing Monsanto's Effort to Silence Science Concluding Roundup Causes Adverse Health Effects
No: MONGLY01189468
Date: 9/9/2008
Description
This document is an email from Dr. Charles Healy to Drs. Donna Farmer and David
Saltmiras wherein Dr. Healy informs Drs. Farmer and Saltmiras that their decision regarding study sent to
Dr. Healy for peer-review will determine whether the study will be published.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it confirms Monsanto's efforts in ensuring that studies which reach conclusions of adverse health effects
associated with glyphosate avoid publication and do not contribute to the carcinogenic assessment of glyphosate.
The reliability and consensus of scientific literature is directly relevant to general causation. This document
also goes to witness credibility.
18. Monsanto Scientist Admits to Ghostwriting Cancer Review Paper
No: MONGLY01723742
Date: 8/4/2015
Description
This document is from the custodial file of Dr. David Saltmiras and is titled
"Glyphosate Activities". Dr. Saltmiras' activities for 2015 included: "IARC prep: AHS Sorahan reanalysis
for multiple myeloma presented at EUROTOX 2012, Kier & Kirkland (2013), ghost wrote cancer review paper
Greim et al. (2015), coord Kier (2015) update to K&K, pushed for Sorahan (2015)."
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it demonstrates Monsanto's involvement in ghostwriting studies discussing the carcinogenic potential of
glyphosate which is subsequently relied upon by the scientific community in determining general causation
issues such as the biological plausibility of glyphosate as a carcinogen. The reliability and consensus of
scientific literature is directly relevant to general causation. This document also goes to witness credibility.
19. Editor of Journal That Published Expert Panel Manuscript States Intention of the Panel was to Discredit IARC
No: MONGLY02356274, MONGLY02356209
Date: 6/19/2016 — 7/7/2016
Description
This document contains email correspondence between Roger McClellan (editor
of the journal which published the Expert Panel Manuscript) and Ashley Roberts regarding the Expert Panel
Manuscript. Mr. McClellan notes several issues with the initial daft of the Manuscript and states: "These
reports are essentially a rebuttal of IARCs process and conclusions. There appears to be a reluctance to
be absolutely clear in presenting exactly what IARC concluded, the Panels conclusions and how they differ."
at *4. The attached initial draft of the manuscript is also challenged for confidentiality.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it contains an opinion by the editor of the journal which published the Expert Panel Manuscript that the
Manuscript essentially sought to discredit IARC and IARC's methodology which offered a general causation
conclusion regarding glyphosate carcinogenicity that was adverse to Monsanto's commercial agenda. The reliability
and consensus of scientific literature is directly relevant to general causation. These documents also
go to witness credibility.
20. Monsanto Email from Donna Farmer Demonstrating Company Manipulation of Glyphosate Studies
No: MONGLY00919381, MONGLY00919400
Date: 11/18/2010
Description
This document is an email and from Dr. Donna Farmer wherein she informs John
DeSesso that she "added a section in genotox from the Gasnier study …see a attached a critique we did that
I took that from. Am working on a section for gasiner in the mechanistic section. Also we cut and pasted
in summaries of the POEA surfactant studies." at *1. The attachment is a draft of the Williams et. al. study
with significant edits by Dr. Farmer which is also challenged for confidentiality.
Relevance
Both documents are relevant and reasonably likely to be used in this litigation
as they demonstrate Monsanto's covert manipulation of the available scientific data on glyphosate. Scientists
reading this published and peer-reviewed article would be unaware that the data was furnished by a biased
contributor and the document is related to whether the inherent conflict of interest affects the merits of
the data when determining the biological plausibility of glyphosate as a carcinogen. The reliability and
consensus of scientific literature is directly relevant to general causation. These documents also
go to witness credibility.
21. Internal Monsanto Email Detailing Company Effort to Preemptively Criticize IARC in the Press Ahead of Glyphosate Report
No: MONGLY01005425
Date: 2/23/2015 — 2/24/2015
Description
This document contains email correspondence between Eric Sachs (Monsanto) and
Henry Miller, a Forbes contributor and fellow of the Stanford Hoover institute. Mr. Sachs asks Mr. Miller:
"Are you interested in writing a column on this topic? Ideally, your article would precede the IARC decision.
Why not set the table with the weight of scientific evidence before IARC convenes? Then, regardless of what
they do, your article will set the stage for a science-based response." at *2. Moreover, Mr. Sachs informs
his Monsanto colleagues: "Henry agreed to author an article on Forbes.com. John will work with a team internally
to provide a draft and Henry will edit/add to make it his own." at *1.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it demonstrates Monsanto's effort to criticize IARC in anticipation of a general causation classification.
Monsanto is a significant contributor to the article without disclosing its interest and involvement. The
reliability and consensus of scientific literature is directly relevant to general causation. This
document also goes to witness credibility.
22. Internal Email Demonstrating Monsanto Ghostwriting Article Criticizing IARC for Press
No: MONGLY02063611, MONGLY02063572
Date: 3/12/2015 — 3/18/2015
Description
This document contains email correspondence between various Monsanto personnel
and Henry Miller. Mr. Miller is asked by Monsanto to write about the IARC decision and Mr. Miller responds
with a request for a "high quality draft." at *6. Mr. Eric Sachs (Monsanto) informs Mr. Miller that "We have
a draft nearly done and will send to you by tomorrow." at *5.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it demonstrates Monsanto ghostwriting an article criticizing and discrediting IARC following the latter's
general causation opinion that was adverse to Monsanto's commercial agenda. The attachment (MONGLY02063572)
is a publicly available article and is thus inappropriately labeled confidential by Monsanto. The reliability
and consensus of scientific literature is directly relevant to general causation. These document also
go to witness credibility.
23. Email Showing Monsanto Paid a Consultant on Expert Panel Believed to be Composed of Independent Scientists
No: MONGLY01680756
Date: 8/17/2015
Description
This document is a consulting agreement between Monsanto and Larry D. Kier,
one of the individuals on the Intertek Expert Panel. Although the Expert Panel was supposed to be composed
of scientists independent of Monsanto, the consulting agreement demonstrates that Dr. Kier worked directly
for Monsanto and this relationship was not disclosed in the published manuscript.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it indicates the inherent conflict of interest between Dr. Kier as a consultant for Monsanto and his participation
on the expert panel, which was concerned with addressing the general causation conclusion by IARC.
The reliability and consensus of scientific literature is directly relevant to general causation. This
document also goes to witness credibility.
24. Email Showing Monsanto Paid Multiple Individuals on Expert Panel Prior to and During Review on Glyphosate
No: MONGLY02816607
Date: 8/6/2015 — 8/14/2015
Description
This document contains email correspondence between various Monsanto employees
wherein Dr. Donna Farmer comments with respect to the Expert Panel: "We have another consulting doing the
same thing that John Acquavella is doing for the epidemiology area… Larry Kier is facilitating the gentox
area of the expert, panel. We have had a contract with Larry Kier before. How do we get this set up for Larry
so that he too can be paid — 12K in 2015? at *2.
Relevance
The document does not contain trade secrets, sensitive commercial information
or privileged material. This document is relevant and reasonably likely to be used in this litigation as
it demonstrates that Drs. Acquavella and Kier were hired Monsanto consultants prior to and during the expert
panel- this inherent conflict of interest was not disclosed by the published manuscript which offered a rebuttal
of IARC's general causation opinion. The reliability and consensus of scientific literature is directly
relevant to general causation. This document also goes to witness credibility.
25. Invoice Showing Monsanto Paid $20,000 to Expert Panel Member Dr. John Acquavella
No: MONGLY03934897
Date: 8/31/2015
Description
This document is an invoice dated August 31, 2015 from Monsanto to Dr. John
Acquavella in the sum of $20,700 for "consulting hours in August 2015 related to the glyphosate expert epidemiology
panel." at *1.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it speaks to the inherent conflict of interest between Dr. Acquavella as a paid consultant for Monsanto
and his participation on the expert panel, which was concerned with addressing the general causation conclusion
by IARC. The reliability and consensus of scientific literature is directly relevant to general causation.
26. Email Demonstrating Dr. Acquavella's longstanding consultancy for Monsanto
No: ACQUAVELLAPROD00014559
Date: 1/7/2016
Description
This document contains email correspondence from 2016 between Drs. Acquavella
and Heydens discussing Dr. Acquavella's consulting for Monsanto "on glyphosate litigation." at *2.
Relevance
The document does not contain trade secrets, sensitive commercial information
or privileged material. This document is relevant and reasonably likely to be used in this litigation as
it demonstrates Dr. Acquavella's long-term consultancy for Monsanto on glyphosate-related issues, specifically
with respect to the general carcinogenicity of glyphosate. The reliability and consensus of scientific literature
is directly relevant to general causation.
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