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6. Monsanto Consultant Protests Ghostwriting — I Can't be a Part of Deceptive Authorship…'
No: MONGLY01030787
Date: 11/3/2015 — 11/6/2015
Description
This document contains email correspondence between various Monsanto personnel
and consultants wherein Dr. John Acquavella protests Monsanto's ghost-writing activities: "I can't be
a part of deceptive authorship on a presentation or publication… We call that ghost writing and
it is unethical." at *2, 3.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it confirms Monsanto's ghostwriting of scientific studies used by Monsanto to deny the biological
plausibility of Roundup and/or glyphosate acting as a carcinogen. Regulators and scientists, relying
up ghostwritten studies, cannot weigh conflicts of interest when using the data to determine causation
between glyphosate and carcinogenicity. The reliability and consensus of scientific literature
is directly relevant to general causation. This document also goes to witness credibility.
7. Monsanto Email Chain: Personnel Discusses Plan Seeking Retraction of Seralini Glyphosate Study
No: MONGLY02063095
Date: 9/26/2012
Description
This document contains a series of email exchanges between various Monsanto
personnel regarding letters to the editor of Food and Chemical Toxicology seeking retraction of a study
by Professor G.E. Seralini. Mr. Eric Sachs writes about his efforts to galvanize scientists in a letter-writing
campaign in order to retract the article: "I talked to Bruce Chassy and he will send his letter to Wally
Hayes directly and notify other scientists that have sent letters to do the same. He understands the
urgency…I remain adamant that Monsanto must: not be put: in the position of providing the critical
analysis that leads the editors to retract the paper." at *3, 2; see also MONGLY01045298 (below).
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it demonstrates the significant role played by Monsanto in achieving the successful retraction of
a scientific study without appearing to be directly involved in such efforts. Monsanto's influence on
the quality and quantity of scientific data on glyphosate is related to the conclusions that regulators
and researchers are able to reach with respect to whether carcinogenicity is a biologically plausible
feature of glyphosate. The reliability and consensus of scientific literature is directly relevant to
general causation. This document also goes to witness credibility.
8. Monsanto Scientist David Saltmiras Admits to Leveraging Relationship with Editor of Food and Chemical Toxicology Journal in Effort to Retract Seralini Study
No: MONGLY01045298
Date: 8/20/2013
Description
This document identifies the "Business Goals" of Monsanto employee David
Saltmiras for the fiscal year 2013. Dr. Saltmiras explicitly states under the "Employee Comments" section:
"Throughout the late 2012 Seralini rat cancer publication and media campaign, I leveraged my relationship
the Editor of Chief of the publishing journal, Food and Chemical Toxicology and was the single point
of contact between Monsanto and the Journal." at 6. Moreover, Dr. Saltmiras acknowledges that he "[s]uccessfully
facilitated numerous third party expert letters to the editor which were subsequently published, reflecting
the numerous significant deficiencies, poor study design, biased reporting and selective statistics employed
by Seralini." at 3.
Relevance
This document is relevant and reasonably likely to be used in this litigation
for similar reasons as the previous (MONGLY02063095) document. Dr. Saltmiras acknowledges Monsanto's
intimate contact with the editor of FCT which, per document MONGLY02063095, led to the retraction of
professor Seralini's study from Food and Chemical Toxicology. The reliability and consensus of scientific
literature is directly relevant to general causation. This document also goes to witness credibility.
9. Email from Monsanto Collaborator Bruce Chassy to Editor of Food and Chemical Toxicology Journal Urging Seralini Study Retraction
No: MONGLY00900629
Date: 9/26/2012
Description
This document contains email correspondence between Bruce Chassy and the
Editor of Food and Chemical Toxicology, Wallace Hayes, wherein Dr. Chassy urges Mr. Hayes to retract
the Seralini paper at Monsanto's request (discussed above): "My intent was to urge you to roll back the
clock, retract the paper, and restart the review process." at *2.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it confirms Monsanto's campaign to eliminate a study which observed the adverse effects of glyphosate.
It is relevant for the same reasons as documents MONGLY02063095 and MONGLY01045298. The reliability and
consensus of scientific literature is directly relevant to general causation. This document also goes
to witness credibility.
10. Monsanto Consulting Agreement with Food and Chemical Toxicology Editor Preceding Journal's Retraction of Seralini Study
No: MONGLY02185742
Date: 8/21/2012
Description
This document is a 2012 consulting agreement between Monsanto and editor
of Food and Chemical Toxicology, Wallace Hayes for the period immediately preceding Mr. Hayes's involvement
in the retraction of the Seralini paper from Food and Chemical Toxicology.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it demonstrates the conflict of interest between Mr. Hayes' role as a consultant for Monsanto and
his vocation as editor for a research journal which retracted a study determining that glyphosate is
capable of being a carcinogen. The document is further indication of Monsanto's pervasive influence within
the scientific community which is related to the availability and quality of data on glyphosate used
by researchers and regulators to assess the scientific literature in determining the potential carcinogenicity
of glyphosate. The reliability and consensus of scientific literature is directly relevant to general
causation. This document also goes to witness credibility.
11. Email Confirming Monsanto's Intention to Pay Wallace Hayes (Editor of Food and Chemical Toxicology) as Consultant
No: MONGLY00971543
Date: 8/12/2012 — 8/13/2012
Description
This document is an email from Dr. David Saltmiras to Dr. Heydens wherein
Dr. Saltmiras "Contact Wallace Hayes to determine his availability and fees for attending the meeting."
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
for the same reasons as the above (MONGLY02185742) document. Mr. Hayes' paid consultancy for Monsanto
constitutes a conflict of interest with his role as editor of a journal publishing research on glyphosate-
especially given his involvement in retracting a study pertaining to the biological plausibility of glyphosate
as a human carcinogen. The reliability and consensus of scientific literature is directly relevant
to general causation. This document also goes to witness credibility.
12. Monsanto Email Confirming Company's Intimate Relationship with Wallace Hayes, Editor of Food and Chemical Toxicology Journal
No: MONGLY01096619
Date: 9/19/2012 — 9/20/2012
Description
This document contains an email correspondence between various Monsanto
personnel wherein Dr. Saltmiras expresses the following with respect to the recently published study
in Food and Chemical Toxicology by Seralini: "Wally Hayes, now FCT Editor in Chief for Vision and Strategy,
sent me a courtesy email early this morning. Hopefully the two of us will have a follow up discussion
soon to touch on whether I C'I' Vision and Strategy were front and center for this one passing through
the peer review process…. and what is that, Vision and Strategy? I also suspect this paper may
be in our own best interests — the last rites for Seralini's few remaining shreds of scientific
credibility." at *2.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it confirms Monsanto's intimate relationship with Wallace Hayes who was subsequently involved in retracting
professor Seralini's study pertaining to the biological plausibility of glyphosate as a human carcinogen,
a conclusion that was adverse to Monsanto's commercial agenda. The reliability and consensus of scientific
literature is directly relevant to general causation. This document also goes to witness credibility.
13. Monsanto Email Confirming Attempt to Seek Retraction of Seralini Study
No: MONGLY00978886
Date: 10/9/2012 — 10/10/2012
Description
This document contains email correspondence between various Monsanto personnel
wherein Daniel Goldstein writes the following with respect to professor Seralini's study: "Retraction-
Both Dan Jenkins (US Government affairs) and Harvey Glick made a strong case for withdrawal of the paper
if at all possible, both on the same basis- that publication will elevate the status of the paper, bring
other papers in the journal into question, and allow Seralini much more freedom to operate. All of us
are aware that the ultimate decision is up to the editor and the journal management, and that we may
not have an opportunity for withdrawal in any event, but I felt it was worth reinforcing this request."
at *3.
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 confirms Monsanto's attempt to
seek retraction of a study pertaining to the biological plausibility of glyphosate as a human carcinogen;
a conclusion adverse to Monsanto's commercial agenda. Mr. Goldstein makes it clear that a retraction
would curtail professor Seralini's "freedom to operate." Id. The reliability and consensus of scientific
literature is directly relevant to general causation. This document also goes to witness credibility.
14. Monsanto Email Chain Confirming Undisclosed Involvement in Successful Retraction of Seralini Study
No: MONGLY00936725
Date: 9/28/2012
Description
This document contains email correspondence between Dr. Goldstein and Eric
Sachs regarding the Monsanto campaign to retract professor Seralini's paper. Dr. Goldstein states: "I
was uncomfortable even letting shareholders know we are aware of this LTE…. It implies we had
something to do with it- otherwise how do we have knowledge of it? I could add ‘Aware of multiple letters
to editor including one signed by 25 scientists from 14 countries' if you both think this is OK." at
*1. Mr. Sachs responds: "We are ‘connected' but did not write the letter or encourage anyone to sign
it." Id.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as confirms Monsanto's undisclosed involvement in the successful retraction of a paper pertaining to
the biological plausibility of glyphosate as a human carcinogen; a conclusion adverse to Monsanto's commercial
agenda. Moreover, the document demonstrates that Monsanto personnel were aware of the imperative need
to covertly instigate the retraction campaign and the inappropriateness of such action. The reliability
and consensus of scientific literature is directly relevant to general causation. This document
also goes to witness credibility.
15. Peer Review by Monsanto Scientist Charles Healy Recommending Rejection of Study That Found Glyphosate and Roundup Adverse Effects
No: MONGLY01238768
Date: 9/12/2008
Description
This document is a peer review by Monsanto employee Dr. Charles Healy of
a study titled "Cytotoxicity of herbicide Roundup and its active ingredient, glyphosate in rats". The
document contains recommendations for rejecting the study which found substantial adverse cytotoxic effects
associated with Roundup and glyphosate.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it demonstrates Monsanto's covert manipulation of the science on glyphosate cytotoxicity given Dr.
Healy's vested interests in Monsanto which conflict with the impartiality of the peer review process.
Access to comprehensive, impartial peer-reviewed data on glyphosate, which is relied upon by both regulators
and scientists to determine the associations between glyphosate and cancer, is thus limited given that
Monsanto is able to circumvent the impartiality of the peer-review process. The reliability and consensus
of scientific literature is directly relevant to general causation. This document also goes to witness
credibility.
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