Issue: Surfactants, Carcinogenicity & Testing

27. Internal Monsanto Email: ‘You Cannot Say That Roundup is not a Carcinogen'
No: MONGLY00922458
Date: 11/21/2003-11/24/2003

Description
This document contains email correspondence between Donna Farmer and Sekhar Natarajan, in which Dr. Farmer discusses the potential adverse effects of the formulated Roundup product, conceding that "you cannot say that Roundup is not a carcinogen…we have not done the necessary testing on the formulation to make that statement." at *1-2.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it evinces knowledge by a Monsanto toxicologist regarding the biological plausibility of the Roundup formulation, as opposed to glyphosate by itself, to act as a human carcinogen.  This is also relevant to Dr. Farmer's credibility, who is one of Monsanto's primary expert witnesses at the company.

28. Internal Email: Monsanto Employee Admits Company Has Not Tested Carcinogenicity of Roundup Formulation
No: MONGLY01155974
Date: 12/10/2010-12/14/2010

Description
This document contains email correspondence between various Monsanto personnel wherein Stephen Adams addresses the issue of testing Roundup formulations: "With regards to the carcinogenicity of our formulations we don't have such testing on them directly…" at *1.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it contains admissions by a Monsanto employee which strongly undermine Monsanto's contentions that it is not biologically plausible for the Roundup formulation to be carcinogenic.  It militates against Monsanto's claim that it has carried out sufficient testing to rule out the biological plausibility of Roundup to act as a human carcinogen.

29. Monsanto Internal Email: Employee Expresses ‘Serious Concern' Over Plausibility of Roundup Formulation Carcinogenicity
No: MONGLY00923065
Date: 2/12/2001 — 2/13/2001

Description
This document contains email correspondence between various Monsanto personnel wherein Dr. Mark Martens states: "I don't know for sure how suppliers would react — but if somebody came to me and said they wanted to test Roundup I know how I would react — with serious concern. We have to really think about doing formulations even if they are not on the market . . . glyphosate is still in there and could get caught up in some false positive finding. at *1.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it contains explicit concerns by Monsanto regarding the biological plausibility of the formulated product to cause cancer.

30. Toxicologist Reluctant to Conduct Studies on Glyphosate, Roundup Formulations or Surfactant Ingredients Because Results Could Concern Monsanto
No: MONGLY00877683
Date: 7/29/1999 — 8/3/1999

Description
This document, from 1999, contains email correspondence from between various Monsanto personnel wherein Dr. Donna Farmer writes: "I will not support doing any studies on glyphosate, formulations or other surfactant ingredients at this time with the limited information we have on the situation." at *2.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it demonstrates reluctance by a key Monsanto toxicologist to conduct studies on either glyphosate, Roundup formulations, or surfactant ingredients, suggesting Monsanto was concerned with the results it would find.  This is relevant to the issue of biological plausibility of Roundup and/or glyphosate as a carcinogen.  Indeed, Monsanto maintains that it is not biologically plausible for Roundup or glyphosate to be carcinogenic, a central contention of the general causation litigation, but then expresses fear of conducting studies since it will show a cancer risk.  This is also relevant to Dr. Farmer's credibility, who is one of Monsanto's primary expert witnesses at the company.

31. Monsanto Internal Email: Employee Admits Company Hasn't Tested Roundup for Chronic or Sub-Chronic Toxicity
No: MONGLY01159775
Date: 3/4/2013 — 3/5/2013

Description
This document contains email correspondence between various Monsanto personnel wherein Xavier Belvaux confirms that: "We do not conduct sub-chronic, chronic or terotogenicity studies with our formulations." at *2.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it contains express admissions by Monsanto that it has not tested Roundup for chronic or sub-chronic toxicity. Such lack of thorough toxicological analysis undermines Monsanto's firm denial of the biological plausibility of Roundup's carcinogenicity based on sufficient testing.

32. Monsanto Scientist Admits Potential for Data Coaching in Monsanto Glyphosate Exposure Study
No: MONGLY07080361
Date: 7/5/2000

Description
This document is a study "site visit" from July 7, 2000 of the "Farm Family Exposure" study. Dr. John Acquavella (Monsanto employee at the time) and John Cowell conduct the site visit. The report indicates numerous deficiencies with the study, including: "Protocol amendments had not yet been forwarded to the study team from Exponent; Many of the urines were very spotty and we found one day's urine that was obviously doctored. As at the Minnesota field site, the field team is not reviewing the urines carefully and there is little, if any, coaching of the farm families; There were some obvious errors or missing entries in the questionnaires." at *7-8.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it outlines significant deficiencies—including use of potentially doctored or "coached" data—with a study evaluating glyphosate exposure and the biological plausibility of glyphosate as a carcinogen.  This goes to the credibility and reliability of the study, which is relied upon extensively by Monsanto to mount its general causation defense.

33. Monsanto Consultant: ‘You Can't Say That There is no Evidence' of Roundup Carcinogenicity
No: MONGLY00978170
Date: 9/16/2015 — 11/2/2015

Description:
This document contains email correspondence between Ashley Roberts (Intertek), Dr. Tom Sorahan (Monsanto consultant), and Dr. John Acquavella (former Monsanto employee and consultant).  Dr. Sorahan reckons it is not accurate to claim that there is no evidence for Roundup's carcinogenicity. at *2. Dr. Acquavella concurs: "I agree as well that you can't say that there is no evidence." at *1.

Relevance
This document is relevant and reasonably likely to be used in this litigation because it supports Plaintiffs' claim that there is evidence that Roundup causes cancer.  This document is also relevant to Daubert, since it shows independent Monsanto's consultants and scientists agreeing about the possibility that Roundup causes cancer.

34. Monsanto PowerPoint Presentation Shows Company Awareness of Roundup Cancer Plausibility
No: MONGLY01182770
Date: 7/15/2008

Description
This document is a PowerPoint presentation concerning the "EU Expert Advisory Panel". Page 6 of the presentation is titled: "Monsanto's Roundup ® acts on one of the key stages of cellular division, which can potentially lead to cancer in the long term." at *6. The page references a French in-vitro study which observed adverse effects associated with Roundup.  The final page contains "questions" regarding how to "position" in-vitro hazards using "urine concentrations from applicator exposure into plasma concentrations." at *7.  Monsanto also considers the risks in "running a new study". Id.

Relevance
This document is relevant and reasonably likely to be used in this litigation to demonstrate that Monsanto was aware of the biological plausibility of Roundup as a carcinogen and realized the risks in conducting new studies that would confirm this suspicion already prevalent in the existing scientific literature.

35. Months Before IARC Report, Monsanto Executive Admits Company Faces Issues in Epidemiology, Exposure, Genotoxicity and Mode of Action
No: MONGLY00989918
Date: 10/15/2014

Description:
This document is an email from Dr. William Heydens to Richard Garnett regarding the "IARC evaluation of Glyphosate" wherein Dr. Heydens concedes that "while we have vulnerability in the area of epidemiology, we also have potential vulnerabilities in the other areas that IARC will consider, namely, exposure, genetox, and mode of action…"  at *1.

Relevance
This document is relevant and reasonably likely to be used in this litigation as it contains an admission from 2014 (more than six months before IARC classified glyphosate) by a leading Monsanto toxicologist that glyphosate faces issues in the areas of epidemiology, exposure, genotoxicity, and mode of action in the general causation evaluation by IARC, which indeed found that it is probable for glyphosate to act as a human carcinogen based upon the areas identified by Dr. Heydens.  It suggests reliability of IARC's assessment, which goes to the heart of general causation.  This is also relevant to Dr. Heyden's credibility, who is one of Monsanto's primary expert witnesses at the company.