-
- Document
#101
- 01/29/69
- SHELL
STRENGTH - THICKNESS
- RUPTURE
- G.
Robertson, Dow Corning, memo to Koning regarding a mammary implant
ruptured 1 ½ years after implantation which was returned by Dr.
Crosby. Robertson states, “(T)he envelope edges adjacent to the
rupture, appeared to be of a very low tear strength. The physical
properties of this envelope may never have been adequate.”
(emphasis added).
- CITE:
KKH 1654. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-------------------
-
- Document
#102
- 03/24/69
- KNOWLEDGE
OF LIQUID SILICONE DANGERS
- KNOWLEDGE
OF SYSTEMIC DISEASE
- Dr.
Franklin Ashley, a clinical investigator for IND 2702, writes to Dr.
Frank McDowell regarding an article by Bishoff and Bryson on the
carcinogenicity of silicone in fluid in rats and mice. Braley, Dow
Corning, has reviewed the article and has stated to Dr. Ashley that:
“According to what he says, and he would not want to say this to
you, he feels that this article is well written and should not be
published. I agree.”
- CITE:
OOM 320814. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
- Document
#103
- 06/10/69
- MISCELLANEOUS
- COMPLICATIONS
- TESTING
- TISSUE
REACTION
- Memo
from Olson to Frisch with copies to Bennett, Hobbs, Hunter and
Radzius regarding “Telephone Communication with Dr. John Wilson of
Johnson & Johnson.” Dr. Wilson, toxicologist at Johnson &
Johnson, was contacted by telephone regarding their subacute dermal
rabbit study on Dow Corning 556 and 360 fluids and Dow Corning
MDDX-4-4122 wash resistant base. Dr. Wilson stated that the
materials had been applied to rabbit skin daily. All animals showed
a trend toward testicular atrophy. “There was a suggestion of
dose-response relationship with Dow Corning materials although the
effects were not statistically significant. A subacute oral rat
study is in progress.” Olson indicated to Wilson that Dow Corning
would be concerned about positive findings with the second study and
would be agreeable to meeting with them to compare their respective
data.
- CITE:
DCC 281041112, Exhibit to McHard Deposition, Exhibit to K. Olson
- Deposition,
and Exhibit to LeVier Deposition. Dow Corning Trial Exhibit List
Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#104
- 07/15/69
-
- KNOWLEDGE
OF LIQUID SILICONE DANGERS
- GEL
MIGRATION
-
- Food
and Drug Research laboratories report on the findings in the chronic
parenteral (intraperitoneal) study initiated by Dr. Ballantyne, Rees
and Hawthorne at the NYU School of Medicine. After silicone fluid in
the peripheral erythrocytes in early hematologic examinations was
observed, Dow Corning transferred the study and its financial
sponsorship from NYU to Food and Drug Research Laboratories. “When
the animals received 51 cc and 62 cc of fluid, inflammatory cells
were observed in the spinal meninges (which was not stated in
earlier reports). Injections of large volumes of silicone produces
wide spread deposition throughout the reticuloendothelial system,
silicone vacuole accumulation in cells and a systemic distribution
of silicone droplets.
-
- CITE:
T 2866 - 2945 (The study is referenced in FDA 26875 - 26889). NOTE:
See 06/30/75 entry.
-
- -------------------
-
-
- Document
#105
- 08/06/69
-
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- KNOWLEDGE
OF SYSTEMIC DISEASE
- TESTING
-
- Isquith,
Dow Corning Biomedical Research Laboratory, memo on the “Current
Status of Microbiological research.” Isquith states that:
“The main purpose of the survey is to help in establishing the
basic relationship between organosilicon structure and biological
activity, the further pursuit of which rests with our own secondary
stage research activity into the physiology (metabolism, mechanism
of action, site of action, etc.) of the compounds and a good
screening procedure for identification of developmental potential. (DCC
16000004)
-
- Another
area for research is the development of a biological assay for
determination of organosilicone interferon induction. (DCC
16000004). Dow Corning has developed sufficient expertise in viral
methodology to conduct the assay, but “there would be considerable
advantage in using such a system (more stable virus, greater
lethality) as is currently being employed in a survey for interferon
inducers at Dow (Chemical) Human Health by Dr. N. Miner....” (DCC
16000005) He recommends using Dr. Miner’s lab for seeking a long
lasting interferon inducer among organosilicone compounds. (DCC
16000006) Finally, another area is the “Investigation of
Physiological Effects of Some Organosilicon Compounds.” (DCC
16000011). Isquith concludes that the area of microbiology in
relation to organosilicon chemistry “is mushrooming at a pace that
even now we are unable to adequately provide this cover. A wise
investment at this time would be the hiring of a virologist (M.S.
preferably) with training in tissue culture, virology, and
immunochemistry. I have not had time to investigate thoroughly, but
feel there is a good chance for development of possible potential in
the areas of hypersensitivity, graft rejection, and autoimmune
disease (arthritis, glomerulonephritis, etc.) which should be within
the scope of a person with the training I suggested.” (DCC
16000014)
-
- CITE:
DCC 16000002 - 160000014, Exhibit 2 to Isquith Deposition, Exhibit 3
to
D.McGhan Deposition, Exhibit to Blocksma Deposition (used by
plaintiffs and Dow
Corning), Exhibit to LeBeau Deposition, Exhibit to Bennett
Deposition, Exhibit
to Boley Deposition, and Exhibit to Julius Johnson Deposition
WITNESS: “Bennett
(Authenticated in Isquith, Vol. I, 119-120). Dow Corning Trial
Exhibit List
Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#106
- 08/14/69
-
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- MISCELLANEOUS
- ORGANIZATIONAL SURVEY
- TESTING
-
- Letter
of agreement between Dow Chemical Company, Dow Corning Corporation
and Lepetit SpA for a joint development program regarding the
biological activity of organosilicon compounds. The agreement
requires the full disclosure of all proprietary and confidential
information of each party to the agreement to each other party.
-
- CITE:
TDCH 1275 - 1276. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#107
- 11/15/69
-
- KNOWLEDGE
OF SYSTEMIC DISEASE
- MISCELLANEOUS
- COMPLICATIONS
-
- Doremire
memo to Bennett regarding chemical warfare and riot control agents,
XZ8-3063. This is a silicone glycol. It goes through the skin as if
there was no skin there. “Do you have any suggestions for a
chemical that could be added to XZ8-3063 which would cause a variety
of effects? These effects could vary from a drug that would act as a
simple tranquilizer to a drug which would cause a loss of
consciousness.” In the case of riot control, the drug might be
effective for ½ hour whereas a chemical warfare use might need 2-4
hours effectiveness. He plans on checking with the “Analytical
Laboratory on toxicity information.
CITE: DCC 281014081, Exhibit 3 to Harris County LeBeau Deposition,
Exhibit to
Rowe Deposition, Exhibit to Bennett Deposition, Exhibit to McHard
Deposition,
and Exhibit to Ryan Deposition. Dow Corning Trial Exhibit List
Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#108
- 00/00/70
- 00/00/71
- 00/00/72
- FRAUD/MISREPRESENTATION
- Dow
Corning advertisement; “New sterile package provides Silastic
Mammary Prosthesis ready to implant. This convenient, sterile
blister pack assures greater product reliability, eliminates
excessive handling and can be easily opened with scissors.” It
also includes references to sizing rings and that the mammary
implant no longer is fitted with fixation patches.
- CITE:
M 700003; M 700008 - 700009. DUPLICATE; M 370049 - 370052; M370108 -
370109; M 370113 -
370114; KKH 62679 - 62682; M 700019 - 700020. Dow Corning
Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#109
- 09/20/76
-
- Hobbs,
Dow Corning, memo to Hinsch with a copy to Lentz regarding
information concerning migration of silicone gels. Hobbs states that
experimentation had not demonstrated migration of Dow Corning
mammary gel but this factor does not appear to be true for all
silicone gels. Hobbs further states that gels having a low
consistency due to low levels of cross-linker appear to migrate
along tissue planes in much the same manner as large injected doses
of silicone fluid.
-
- CITE:
M 170104, Exhibit 130 to Burda Deposition; Exhibit 91 to Braley
Deposition. DUPLICATE: M 570060. NOTE: The document was listed as
00/00/70 on
Plaintiff’s Trial Exhibit List. Dow Corning Trial Exhibit List
Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#110
- 01/12/70
-
- KNOWLEDGE
OF LIQUID SILICONE DANGERS
- GEL
MIGRATION
-
- Silas
Braley, Dow Corning, memo to various Dow Corning employees
distributing interim research report on the investigation of
Dimethylpolysiloxane Fluid Injections at the Institute of
Reconstructive Plastic Surgery, New York University. The interim
report states that “our most interesting recent findings indicate
that in both mice and rats, injection of large volumes of liquid
silicone, either interperitoneally or subcutaneously, in multiple
injections, apparently produces a wide spread deposition of this
material throughout the reticuloendothelial system. A more recent
finding of some interest is that there is an apparent accumulation
of silicone vacuoles both within the red cells and the leukocytes of
the peripheral blood in mice and rats, which appears about one to
three months after injection and persists for several months.” The
NIH grant will run out in about one year and these studies will have
to be terminated. “It is our feeling that the evidence of systemic
distribution of silicone droplets or vacuoles can not necessarily be
considered an adverse effect, but is more likely related to total
dosage. The dosages employed in animals rarely can be achieved in
man with the possible exception of breast injections....”
-
- CITE:
T 2881 - 2885. NOTE: The report itself was an Exhibit to the K.
Olson
- Deposition
(KKH 9841 - 9845). This document also has the Bates number OOM
321368
- 321672 on it. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#111
- 02/02/70
-
- STERILIZATION/CONTAMINATION
-
- J.H.
Wetters, Dow Corning Medical Products Plant, Report No. 229 to
Burdick with copies to Reilly, Mantle, Piper, Don McGhan, Houle and
Robertson regarding “White Particle Contamination of the Mammary
Gel.” The major contaminant was found to be crystalline by
microscopy and potassium chloride and potassium bicarbonate by
x-ray. Wetters cannot explain the presence of potassium bicarbonate.
The white poly lined can in which it is contained could possibly be
the source of this material. J.P.
Fitzgibbon feels that the crystalline potassium salts are the major
portion of the contamination. “Gordon Robertson and Ken Olson
should be contacted for an opinion as to whether these potassium
salts are harmful.” (MM 234057)
-
- CITE:
KMM 234056 - 234057. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#112
- 02/18/70
-
- KNOWLEDGE
OF LIQUID SILICONE DANGERS
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- TISSUE
REACTION
-
- Report
prepared Food and Drug Research Laboratories for the Dow Corning
Toxicology department. There are relatively little specific
experimental data available on the reactivity of biological systems
to silastics and polymethylsiloxane (PMSs) fluids. Prior studies by
other laboratories showed “significant testicular atrophy
resulted” from topical application of a polymethylsiloxane fluid.
In the present study, 15 applications of PMS fluid was applied
topically on rats, guinea pigs, rabbits and dogs for a 20-day
period, and was administered in the diets of rats and rabbits for
eight months. In the
rabbits that were topically applied with PMS fluid, “the reduction
in the testicular weights of the PMS-treated rabbits is considered
biologically significant.”
- In
the rats that had PMS administered orally for one year, growth was
retarded as early as the first week in feeding. The differences in
weight gain between the test and control groups was “statistically
significant” during the third week, with the weight gain in the
test group lower than the control. In the female rats, there were
“notable endocrine effects,” smaller ovaries, enlarged
pituitary, and increased weight in the adrenals and thyroids.
In the rabbits that had PMS administered orally for eight
months, there was a “trend toward decreased testicular size in the
test group...,” a tendency toward lower hemoglobin and hematocrit
in all rabbits in the test group, “some effect of PMS fluid on
sperm maturation...,” and testicular atrophy in the test rabbits.
-
- CITE:
T 2302 - 2341, Exhibit to K. Olson Deposition, and Exhibit to LeVier
Deposition. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
- -------------------
-
- Document
#113
- 02/19/70
-
- KNOWLEDGE
OF SYSTEMIC DISEASE
- MISCELLANEOUS
- COMPLICATIONS
- SILICA
- Dow
Corning study titled “Acute Inhalation of 14C-Labeled J-DCA”
(silica) by Hobbs and Lacefield finds that the acute inhalation of a
relatively large amount of J-DCA appears to confine its residence
and effect to the lung. The low levels of J-DCA found systemically
is a strong indication that the acute adverse response is confined
to the lung. This would also indicate the lung to be the target
organ from a chronic exposure.
CITE: DCCF 5008903 - 5008907, Exhibit to K. Olson Deposition. Dow
Corning Trial
Exhibit List Abstract
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#114
- 03/02/70
-
- KNOWLEDGE
OF LIQUID SILICONE DANGERS
- TESTING
-
- D.
Ballantyne letter to E. Hobbs, Dow Corning, answers questions about
the investigation regarding dimethylpolysiloxane fluid raised by
Hobbs’ letter of 02/19/70. Current findings show an apparent
accumulation of silicone vacuoles that were observed on the
erythrocytes of rats only. He currently has studies underway on mice
and baboons but the results are not substantial at this time. A
research paper should appear in the April issue of the
Reticuloendothelial Society.
-
- CITE:
T 2888 - 2889. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#115
- 04/13/70
-
- KNOWLEDGE
OF GEL BLEED
- KNOWLEDGE
OF SYSTEMIC DISEASE
- MISCELLANEOUS
- COMPLICATIONS
- RUPTURE
- TISSUE
REACTION
-
- Olson
memo to Boone with copies to Hunter, Hobbs, Koning, Radzius and
Stark regarding “Inflatable Mammary Toxicology.” He responds to
Boone’s memo stating, “The stability of dextran solutions in an
implant situation over the long haul, particularly if there is
diffusion of body fluids across the membrane would be difficult to
accurately assess without biological data generated under use
conditions. It is important to know these things prior to marketing.
With my cursory knowledge of the problem I would tend to feel that
such a device might cause some patients and Dow Corning some degree
of grief. I would think that a rather extensive clinical
investigation is indicated in order to assess benefit versus risk
for Dow Corning.”
-
- CITE:
KMM 146382-146384. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#116
- 04/14/70
-
- KNOWLEDGE
OF SYSTEMIC DISEASE
- TESTING
- TISSUE
REACTION
-
- “Two-Year
Implant Studies with Silastic Materials in dogs” by S. Carson and
Food and Drug Research Laboratories for Dow Corning Corporation.
Carson states:
“A
two-year study was undertaken to evaluate the effects associated
with implantation of silastic materials into three sites of beagle
dogs. Its purpose was to determine the tissue reaction and systemic
effects associated with the implantation of silastic materials into
subcutaneous, intramuscular, or intraperitoneal areas in dogs and to
evaluate these responses to the implants with relation to time. No
adverse findings were seen which could be associated with the
implantation of the test materials. Fibrous capsule formation is the
only histomorphologic change found in these animals. Capsule
formation was of a 1 to 2+ thickness during the first six months of
study and ranged from 2+ to 3+ thickness during the final
examination after two years of test. In several cases, inflammatory
cell reactions were also found. These were however anticipated, and
were observed at the six-month and two-year sacrifice periods.
The findings, therefore, are primarily associated with a
minimal degree of foreign body reaction and no adverse systemic
pathological manifestations are associated with the implantation of
the silastic materials.
-
- CITE:
T 1529 - 1572. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#117
- 04/20/70
-
- TESTING
- TISSUE
REACTION
- FRAUD/MISREPRESENTATION
- KNOWLEDGE
OF SYSTEMIC DISEASE
-
- A
study contracted to Food and Drug Research Laboratories by Dow
Corning entitles “Two Year Studies with Miniature Silastic Mammary
Implants TX-202A and TX-202”B in Dogs, Dow Corning Tox. File No.
1306-3” is sent to Dow Corning. In this study, one of the four
dogs died and the three others had a chronic inflammatory response
to the implants. While FDRL reports that the only adverse effects
two years after implantation are fibrous tissue encapsulation and
chronic inflammation, the attached chart (Table 3) shows reactions
at 6 months of “large granulomatous mass adjacent to capsule”
and “liver and kidney-congested.” Dow Corning submitted this
study, with the incorrect chart (Table 3) as part of its PMA Double
Lumen Silastic II and Silastic MSI Gel Saline HP application.
-
- CITE:
F 462 - 483, Exhibit 9 to California Braley Deposition. DUPLICATE: p
A75\460 - 17482; T 2363 - 2383. NOTE: See 00/00/73 - F 12 - 16; P
17491 - 17496; and Depo. of Bobby Purkait, MDL 926, p. 50-51,
Exhibit 22 (07/09/93).
Dow Corning Trial
Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
- -------------------
-
- Document
#118
- 05/06/70
-
- RUPTURE
- SHELL
STRENGTH - THICKNESS
-
- J.K.
Boone, Dow Corning , handwritten note to F. Stark regarding
inflatable mammary development assurance. Boone writes:
“The bags for the inflatable mammary prostheses are taken directly
from the production of the standard seamless mammary. It is expected
that gel filled bags are softened by the gel somewhat, giving an
ultimately softer bag with somewhat higher elongation. Thickness of
the bags varies with the size and width, but it is ordinarily
between 0/010” and 0.020” with the average being about 0/017.
Several individual prostheses were subjected to severe
testing (after filling and tube removal). They were slammed
repeatedly against a smooth wall. Valves functioned well, bags can
be broken under stress without the valves leaking.
To date, 153 of these devices have been submitted to quality
assurance, and 18 of these have been rejected for a variety of
reason. Leakage through the valve has not been a problem.
- It
is very difficult to project the eventual clinical failure rate for
this device at this time. I would estimate failures less than 1% on
devices successfully implanted, another failure rate should be
expected for devices damaged during surgery. These will be
immediately detectable as these devices are filled. This will cause
professional irritation but little liability.
Patients are being cautioned that these devices may break or
leak at some later date.... The device now marketed (gel filled) has
certainly not been complication free but to date it has not caused
us severe liability problems. Over
the long haul, I would guess that we might be sued about as often
for hard, painful breasts as for ‘shrinking’ ones.”
- Dow
Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#119
- 06/01/70
-
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- COHESIVENESS
- LIQUID COMPONENT OF GEL
- KNOWLEDGE
OF GEL BLEED
- MISCELLANEOUS
- COMPLICATIONS
- SILICA
- TISSUE
REACTION
-
- Minutes
of the Inflatable Mammary Meeting sent to Bennett, Boone, Bennett,
Hobbs, McIntyre, Olson, Rathjen and Stark.
-
- CITE:
KMM 77733 - 77750, Exhibit to Bennett Deposition and Exhibit to
Isquith Deposition. Dow Corning Trial Exhibit List Abstracts
PENDLETON/PSC Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#120. (ALSO LISTED AS 121.)
- 06/16/70
-
- TESTING
- SHELL
STRENGTH - THICKNESS
-
- Boone,
Dow Corning, memo to Hobbs and others regarding the “Physical
Property Testing on Two Year Implant Specimens.” The study was by
Food and Drug Research Laboratories on silicone elastomers implanted
intraperitoneally, intramuscularly and subcutaneously. Fifteen dogs
were tested with silicone elastomer and seamless mammary
constructions. The results showed “in almost all cases (that there
has been some rise in durometer with attendant loss in elongation
and increase in modulus of the materials.”
-
- CITE:
T 1573 - 1577. (Document # 121 on the Trial Exhibit List states that
this
document does not have a Bates Number). Dow Corning Trial Exhibit
List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
- -------------------
-
- Document
#122
- 07/08/70
-
- COHESIVENESS
- LIQUID COMPONENT OF GEL
- KNOWLEDGE
OF LIQUID SILICONE DANGERS
- KNOWLEDGE
OF SYSTEMIC DISEASE
- MISCELLANEOUS
- COMPLICATIONS
-
- Olson
letter to Michael Robbins, Pharmaceutical Division of The Dow
Chemical Company in Indianapolis, regarding Robbin’s recent
request for information on the toxicity of dimethylpolysiloxane when
injected intravenously into laboratory animals. A search of the
toxicology files at Dow Chemical reveals that preliminary acute and
subacute studies were conducted in 1956 on Dow Corning 200 Fluid,
350cs.” He then summarizes the data where 2 of 4 rabbits died
immediately after being injected with DC 200 fluid at .50 g/kg, 2 of
4 died at 1 g/kg dose and all 4 died at 2 g/kg dose.
-
- CITE:
FDA 27229 - 27230, Exhibit to K. Olson Deposition, and Exhibit to
Hinman
- Deposition.
Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#123
- 09/23/70
-
- MISCELLANEOUS
- SHELL
STRENGTH - THICKNESS
- STERILIZATION/CONTAMINATION
-
- Dow
Corning Corporation Report entitled “Manufacture of Silastic
Mammary Prosthesis.” The purpose of this report is to provide a
detailed description of the manufacturing processes involved in the
production of Silastic Mammary Prostheses. The report gives a
detailed description of the manufacturing facilities, product
composition, processing materials, component specifications,
manufacturing process and quality assurances. This report also
includes product run sheets for the seamless mammary prosthesis and
packaging component information and specifications.
-
- CITE:
KMM 223739 - 223806. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
- -------------------
-
- Document
# 124
- 01/21/71
-
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- KNOWLEDGE
OF SYSTEMIC DISEASE
- MISCELLANEOUS
- COMPLICATIONS
- MISCELLANEOUS
- ORGANIZATIONAL SURVEY
- TESTING
-
- Handwritten
memo to Hunter from Bennett regarding “Trip Report -Europe, Jan.
6-20, 1971.” Section 2, beginning on p.10, discusses a
visit with Lepetit Pharmaceutical co. in Milano on January 14-15,
1971. Present at this meeting were Wm. Caldwell, Zeller - Director
of Central R&D, Carati - Lepetit legal counsel, Levier and
Bennett. Levier and Bennett also met with Lerner.
-
- CITE:
DCC 281011474 - 281011491 (Temporary Dow Corning Bates Numbers 5455
-
5472), Exhibit to Bennett Deposition, Exhibit to Hinman Deposition,
Exhibit to
Isquith Deposition, Exhibit to Julius Johnson Deposition, Exhibit to
LeBeau
Deposition, and Exhibit to LeVier Deposition. Dow Corning Trial
Exhibit List
- Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#125
- 01/26/71
-
- Wayne
Koning, Dow Corning, memo to Forrest Stark regarding a returned
implant by Dr. Bankof. Jan Varner reported that this was an
“old” style implant and that he “was able to break through the
envelope with minimal effort and perhaps there is some degradation
of the envelope over a period of time.” Koning reports to Stark
that “Jan appears to be loosing confidence in the stability of the
envelopes physical properties over an extended period of time
because of frequent comments that are being given recently by large
volumes (sic) users that he calls on.” Koning also states that,
“The terms, friable, disintegration and degradation are being used
frequently in some areas to describe the condition of the envelope
of removed SILASTIC ® mammary prostheses.” (emphasis added).
-
- CITE:
M 570119. DUPLICATE: KMM 335110 Dow Corning Trial Exhibit List
Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
- -------------------
-
- Document
#126
- 03/09/71
-
- COHESIVENESS
- LIQUID COMPONENT OF GEL
- RUPTURE
- TISSUE
REACTION
-
- Morgan,
Dow Corning, memo to Koning, regarding a complaint made by Dr.
Condie concerning the composition of the silicone gel in a ruptured
implant. The patient developed a reoccurring infection and staph
infection four months post-op with fluid “oozing from the
wound.” The memo states “the prosthesis was practically empty of
gel and what gel was there was extremely fluid and oozed out of the
prosthesis and the surrounding tissue.... It appears to me that we
have had a gel breakdown but I did not discuss this in any way with
Dr. Condie.” (emphasis added)
-
- CITE:
KMM 423343 - 423344. DUPLICATE: KKA 152366 - 152367; CO 82 - 83.
NOTE: Dow
Corning was using V. Mueller as its sales agent. Dow Corning Trial
Exhibit List
Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
- -------------------
-
- Document
#127
- 05/11/71
-
- KNOWLEDGE
OF SYSTEMIC DISEASE
- TISSUE
REACTION
-
- Dr.
Glenn Burt, Department of the Army, letter to Silas Braley, Dow
Corning, reporting on an augmentation patient who “encountered a
most traumatic experience. On the second postoperative day the
patient developed a fever which during the next few days spiked
tremendously - as high as 105 degrees - and the patient went
progressively down hill so that we had to remove the prostheses on
the twelfth post-operative day....
During this time she developed an erythematous rash, joint
swellings, considerable weakness, and an enlarged liver, all of
which made us feel this was a rejection type phenomenon.”
(emphasis added).
-
- CITE:
M 240089, Exhibit 46 to Hinsch Deposition (used by Dow Corning),
Exhibit
to D. McGhan Deposition, Exhibit 21 to California Braley Deposition,
and Exhibit
5 to Harris County Burchiel Deposition. Dow Corning Trial Exhibit
List Exhibit
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#128
- 06/14/71
-
- COHESIVENESS
- LIQUID COMPONENT OF GEL
- KNOWLEDGE
OF SYSTEMIC DISEASE
- TISSUE
REACTION
-
- Dr.
Condie writes to Wayne Koning, Dow Corning, regarding a patient with
breast implants who developed and “allergic reaction in the skin
over the right breast, or an infection in the skin of the right
breast. There was slight itching associated with the condition. This
was also associated with some swelling of the upper lip and it was
felt that she might have angioneurotic edema, however, with
antibiotic therapy the cellulitis cleared up. This was approximately
16 days after she was first seen for the condition.” Six months
later, the right breast again became red and swollen. Upon
aspiration, silicone escaped from the needle’s puncture wound,
resulting in wide spread necrosis. The implant was removed and Dr.
Condie noted that “it was extremely difficult to remove all of the
silicone which was flowing and not gel like in consistency.” Dr.
Condie also states that the silicone in this case was “extremely
watery and flowed very easily. I cannot help but feel in my own mind
that there was something which caused chemical change in the
silicone, making it liquid instead of a gel. The culture which was
taken showed staph coagulasa positive.” (emphasis added).
-
- CITE:
M 570103 - 570104. DUPLICATE: KMM 98372 - 98373; M 240090 -240091.
Dow
Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#129
- 07/07/71
-
- SHELL
STRENGTH - THICKNESS
-
- Manikian,
Dow Corning, memo to Boone stating that he has accumulated data on
the “long term” stability of the envelope. He refers to three
lost of mammaries - 1 from June 1966, 1 from August 1967, and 1 from
April 1971. “There are changes in the physical properties of the
bag after filling. Contact with the gel seems to soften the bag and
lessen its tensile strength.... (W)e neither have data on the
properties of a bag immediately after filling nor have in storage a
large enough number of units to perform a controlled study.”
- CITE:
KMM 220303. DUPLICATE: KMM 223111 - 223114. Dow Corning Trial
Exhibit List
Abstract
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#130
- 12/13/71
-
- STERILIZATION/CONTAMINATION
-
- W.
Koning memo to Bill Mantle, Dow Corning, which states “Bill, here
is another hairy implant from Jan! Please comment. Too bad they
didn’t reject before unsealing the package.”
-
- CITE:
KMM 423367. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#131
- 12/00/71
-
- EMBOLISM
- GEL
MIGRATION
- KNOWLEDGE
OF LIQUID SILICONE DANGERS
- MISCELLANEOUS
- COMPLICATIONS
-
- Publication
by Blocksma entitled “Experience With Demethylpolysiloxane Fluid
In Soft Tissue Augmentation.” Plastic & Reconstructive
Surgery, Vol. 48, No. 6, 564-567. The release of silicone fluid for
general distribution could make every general surgeon think he has
become a plastic surgeon overnight. Used improperly, silicone fluid
has a serious potential for harm. Therefore the author is opposed to
the release of this material to any but bona-fide plastic surgeons
at this time.
-
- CITE:
DCC 204005370 - 204005374; Exhibit 71 to Braley Deposition, Exhibit
to D.
McGhan Deposition, Exhibit 45 to Hinsch Deposition (used by Dow
Corning), and
Exhibit 99 to Harris County Rathjen Deposition. Dow Corning Trial
Exhibit List
Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#132
- 00/00/72
-
- MISCELLANEOUS
- COMPLICATIONS
- TESTING
- TISSUE
REACTION
-
- Article
by Bennett, Gorzinski and LeBeau entitled “Structure-Activity
Relationships of Oral Organosiloxanes on the Male Reproductive
System,” Toxicology And Applied Pharmacology, Vol. 21, 55-67
(1972). The abstract at the beginning of the article states that:
“A series of low molecular weight organosiloxanes depressed male
reproductive function in the mouse, rat, and rabbit. The rabbit was
the most sensitive, and the mouse was the least. Active compounds
were found among phenylmethyl-substituted silanes, linear
disiloxanes, and trisiloxanes; cyclic trisiloxanes and
tetrasiloxanes. Cyclic siloxanes were the most active cyclic.
Monophenylheptamethylcyclotetrasiloxane was quite active;
however, the presence of an additional phenyl group enhanced
activity providing the 2 phenyl groups had the correct sterile
configuration, i.e.,
2,6-cis-diphenylhexamethylcyclotetrasiloxane....
A spectrum of activity was noted in the male animal when active
compounds were administered po for 3-21 days. Small doses
sequentially decreased seminal fluid, seminal vesicle, prostate and
testes weight, associated with decreased blood levels of
testosterone. Large doses caused adrenal hyperplasia, hepatomegaly,
decreased body weight, and decreased serum levels of cholesterol,
phospholipids, and alkaline phosphatase.”
-
- CITE:
DCC 281000743 - 281000755. WITNESS: Bennett (Authenticated in
Bennett, Vol. II, p. 547-548). DISPOSITION: Admitted in Toole (II)
v. Baxter Healthcare.
Dow Corning Trial
Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
- -------------------
-
- Document
#133
- 04/00/72
-
- FRAUD/MISREPRESENTATION
-
- Dow
Corning advertisement: “The Silastic Mammary Prosthesis makes a
world of difference.” Over the past ten years “we have initiated
207 rigid quality control tests to assure the reliability of every
prosthesis manufactured. We have continued to make significant
design improvements. It is simply the most reliable answer to breast
augmentation and restoration following subcutaneous mastectomy.”
-
- CITE:
M 700010. DUPLICATE3: KKH 62691; KKH 62692; M 370064; M 370065;
M370106; M
- 370123:
M 700011. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#134
- 04/07/72
-
- GEL
MIGRATION
-
- “Dimethylpolysiloxane
Fluid 14C (Dow Corning 260 Medical Fluid 14C) Distribution and
Disposition In Rats Following Subcutaneous Injection,” by LeBeau
and Gorzinski of the Research Department of DC. A copy was sent to
Ryan, Bennett, Braley, Hunter, Isquith, Frye, LeVier, Speier, Stark,
Boley and others. DC 360 fluid was administered subcutaneously to
rats to measure the distribution of the fluid in expired air, urine
and feces at 8, 30, 60 and 90 days. The highest percentage (.94%)
was detected at the original injection site <10% was detected in
urine and feces. “There was a ubiquitous distribution of low
concentrations of radioactivity in the tissues and organs
(<.02%). However, lymphatic tissue near the injection site had a
higher (ten-fold) concentration of radioactivity of all tissues and
organs examined suggesting migration via lymphatic routes.”
Rodents receiving massive subcutaneous doses of silicone fluid were
examined histopathologically. Droplets of vacuoles were found
throughout the reticuloendothelia systems including the regional
lymph nodes and extending to the liver, spleen, kidneys and
adrenals. Definitive proof of silicone fluid in the droplets was not
demonstrated but the authors assumed it was silicone fluid.
-
- CITE:
KMM 260056 and KMM 270609 - 270623, Exhibit to Bennett Deposition
(used by
plaintiffs and Dow Corning), Exhibit to Isquith Deposition, Exhibit
to K. Olson
Deposition, and Exhibit 3 to Harris County Rathjen Deposition. NOTE:
The exhibit
list also lists Bates Numbers T 2765 -2780 but there are no
documents in the
binder with these numbers. DUPLICATE: DCC 205001829 - 205001841; KMM
173800 -
- 173816;
DCC 204004553 - 204004580; Dow Corning Trial Exhibit List Abstract
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#135
- 04/24/-26/72
-
- TESTING
- FRAUD/MISREPRESENTATION
-
- Article
entitled, “Toxicological Studies, quality control, and efficacy of
the Silastic mammary prosthesis” is published in the journal
Medical Instrumentation. Authors are Gordon Robertson and Silas
Braley of Dow Corning. The
article cites and discusses the FDRL Report on “Two-Year Studies
With Miniature Silastic Mammary Implants” (P 017460 - 017496).
Robertson and Braley reprint the 6 month test results in Medical
Instrumentation and claim that these are the results after 2 years
of implantation.
-
- CITE:
F 12 - 26, Exhibit to Palensky Deposition, Exhibit 19 and 20 to
California
Braley Deposition, and Exhibit to LeVier Deposition. DUPLICATE: KMM
249816 -
249822, J 5223 - 5226. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#136
- 05/04/72
-
- TISSUE
REACTION
- SHELL
STRENGTH - THICKNESS
- KNOWLEDGE
OF GEL BLEED
- GEL
MIGRATION
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- KNOWLEDGE
OF LIQUID SILICONE DANGERS
-
- Silas
Braley, Dow Corning, letter to Dr. Douglas Lake expressing his
reservations about the use of silicone to fill inflatable implants.
He states:
There is a very good reasons for this: the silicone fluid being of
the same basic nature as the silicone polymer used to make the
rubber will dissolve into the rubber and very seriously weaken and
soften it... Another factor which must be taken into consideration
if a silicone fluid is used to fill a silicone rubber bag, is that
the outer surface of such a bag will become oily with the silicone
fluid. This means that the fluid is now capable of being absorbed by
the body and very extensive toxicological work would have to be done
to prove that this is not deleterious to the tissues.... We rejected
the silicone fluids for the above reasons and went immediately to
silicone gel. (emphasis added).
-
- CITE:
KMM 141906 - 141907, Exhibit 32 to California Braley Deposition.
-
- -------------------
-
-
- Document
#137
- 07/14/72
-
- KNOWLEDGE
OF SYSTEMIC DISEASE
- MISCELLANEOUS
- COMPLICATIONS
- TESTING
- TISSUE
REACTION
-
- Dow
Corning Research Report No. 4006 (formerly classified) entitled “A
Toxicological Evaluation Of Trimethylsilanol (Me3Si(OH2) In The
Rat.” The authors postulated that two potential end products of
the biological degradation of trimethyl en-blocked linear
dimethylpolysiloxane polymers or cyclic dimethylpolysiloxane
polymers might to Me3SiOH and Me2Si(OH)2. Other studies are
currently underway at Dow Corning’s Biomedical Research Department
to determine the potential for degradation of dimethylpolysiloxan
polymeric species. (p. 4) The authors conclude that there were no
significantly different dose-related values for body weight, food
consumption, hematology or organ weight ratios for liver, kidneys,
adrenals, heart or gonads. There did appear to be a modest
dose-related significant elevation of blood glucose in the
Me2Si(OH)2 treated rats. There may also be a slight depression of
the triglyceride blood level at the low dose of Me3SiOH and total
lipid is at the low level of normality for this group as well. (p.
13)
-
- CITE:
DCC 281001689 - 281001726 (Temporary Dow Corning Bates Number 3424 -
3461), Exhibit 49 to Bennett Deposition (used by Dow Corning),
Exhibit to Frye
Deposition, and Exhibit to Isquith Deposition. Dow Corning Trial
Exhibit List
Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#138
- 08/18/72
-
- MISCELLANEOUS
- COMPLICATIONS
- SILICA
- TESTING
- TISSUE
REACTION
-
- Robert
LeVier and Michael Jankowiak, Dow Corning, report on “The Effects
of 20 CS DC-360 Fluid And Related Linear/Cyclic
Dimethylpolysiloxanes Administered Orally And Dermally For Four
Weeks To Male And Female Rats On Whole Body Oxygen Consumption,
Serum Total Cholesterol, Organ Weights, And Silicon Distribution.”
There was increase in tissue thyroid weight; potential of
accumulation increasing cholesterol; and slight increases in
silicone levels for heart, serum, urine, liver and thyroid. In
addition, the female rat appeared to accumulate more silicone than
did the male rat.
-
- CITE:
DCD 154000169 - 154000188, Exhibit to Bennett Deposition. NOTE: The
exhibit list identified this document as T20844 - 20863. Dow Corning
Trial
Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#139
- 10/17/72
-
- COHESIVENESS
- LIQUID COMPONENT OF GEL
- RUPTURE
- SHELL
STRENGTH - THICKNESS
-
- Dr.
Gregory letter to Rathjen regarding an implant he ruptured
unknowingly during surgery. Three months after implantation, the
patient experienced redness on her breast and perforation of the
skin with the implant protruding outside and “Gel dripping out of
the hole.” He says that this “may be a blessing in disguise,
because perhaps we have all been trying to make too soft and too
fragile an envelope. I do not believe that the old envelope would
have perforated as easily as this one did with the mosquito
hemostat. Perhaps the viscosity of the Gel may have to be
reconsidered in view of this particular type complication.”
-
- CITE:
KMM 54876 - 54877, Exhibit 9 to Harris County Rathjen Deposition,
and
Exhibit to MDL Rathjen Deposition. DUPLICATE: B 949 - 950. Dow
Corning Trial
Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#140
- 11/16/72
-
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- MISCELLANEOUS
- COMPLICATIONS
- TESTING
- TISSUE
REACTION
-
- Dr.
Bennett, Dow Corning, “Bioscience 1972 Status Repost.” Bennett
states that “The interaction of the Chemicals in the biological
organism can be detrimental to the consumer. A chemical which has no
overt direct action in its own right but potentiates the action of a
second chemical taken into the organism simultaneously, forces us to
consider each produce in its use situation to make sure that this
phenomenon is not a hazardous one if it exists.” (p., 1) Also,
biological research in all areas is being constrained because of
economic considerations. “There is considerable interest in
chemicals which affect viruses, cancer, population control, immuno-therapy,
animal and plant hormones, aging, and genetic engineering.” (p.2)
- Bennett
recounts the major projects of each of the segments of the
Bioscience Research Department: Animal Sciences - there is a
continuing Evaluation of 2,6-cis, working with KABI and others;
Microbiology - a program has been developed based on the creation of
antimicrobial activity on surfaces of many diverse types; Plant
Sciences - they are exploring antitranspirant activity of
polydimethylsiloxane fluid; and Metabolism of Organosilicon
Compounds - Bennett believes this unit is the “keystone in the
development of silicon chemicals in profitable biological
applications as well as continuing to assure the Corporation of the
safety of present products.” (p. 4)
-
- CITE:
DCC 16001173 - 16001178, Exhibit to Bennett Deposition. WITNESS:
Bennett
(Authenticated in Bennett, Vol. III, p. 630-631). DISPOSITION;
Admitted in Toole
(II) v. Baxter Healthcare. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
141
- 00/00/73
-
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- KNOWLEDGE
OF SYSTEMIC DISEASE
- TISSUE
REACTION
-
- Dow
Corning Bioscience Research Laboratory “Research Project
Description” entitled “Antimicrobial Research” prepared by Dr.
Isquith. The objective is to “investigate the effect of
‘substrate-bonding’ of organosilicon antimicrobial agents on
their potency; spectrum of activity; reaction to their agents (i.e.,
protein, lipids, detergents; mode of action; biodegradability; and
toxicity in comparison to similar non-silicon containing agents.”
(DCC 16001104) Isquith notes that Weetall and co-workers published a
series of articles on the use of alkoxysilanes to immobilize enzymes
on inert surfaces, and that this technology is currently being
developed as a processing aid in various industries. He states,
“The bonded biologically active agent concept is further expected
to greatly alter the immunological field....” (DCC 16001105) He
notes a potential business opportunity for Dow Corning.
-
- CITE:
DCC 16001104 - 16001109. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#142
- 00/00/73
-
- ACKNOWLEDGEMENT
OF NEED FOR TESTING KNOWLEDGE OF SYSTEMIC DISEASE SILICA Dow Corning
Bioscience Research Laboratory “Research Project Description”
entitled “Exploratory Virus and “Cell Biology” Prepared by Dr.
Robert Lake. The objective is to “Examine the role of enjogenous
Si, organosilicon modified viral antigens, and endogenously applied
organosilicon compounds in modifying humoral and cellular-mediated
immune response to animal viruses.” (LAK 50) There are three
approaches to viral diseases - immunological, host-resistance, and
chemotherapy. Defining a role for silicon containing chemicals in
the immunological or host-resistance approaches will require
examination of the basic interaction of these chemicals with the
lymphoid elements of the cellular immune system, i.e., lymphocytes,
monocytes, and granulocytes. When
organopolysiloxanes are installed in the blood, lungs, peritoneum or
GI tract of the body, they illicit a selective interactive with
macrophages. Macrophages
are the first to encounter and process viral antigens in the immune
response and “virtually control the outcome of and recovery from
virus infection.” (LAK 50) The material is phagocytized by
neutrophils and macrophages, redistributed to lymphoid tissue and a
fibrous wall builds around the material. It is this interaction of
macrophages that Dr. Lake would like to study because “the
potential for organosilicones as modifiers of immunological
phenomena has not been exploited.” (LAD 52) He states, “Critical
variables such as polymer type, size, and organofunctional groups on
the time course of these cellular responses have never been
reported.” (LAK 50) CITE: LAK 50 - 52, Exhibit to Bennett
Deposition, Exhibit to Isquith Deposition, Exhibit 1 to Randonovich
Deposition, Exhibit to Boley Deposition, Exhibit 4 to Lake
Deposition, and Exhibit to LeVier Deposition, DUPLICATE: LAK 47 -49.
WITNESS: Bennett (Authenticated in Isquith, Vol. II p. 423:15
-424:11).
-
- DEPOSITION;
admitted in Toole (II) v. Baxter Healthcare. Dow Corning Trial
Exhibit
List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#143
- 00/00/73
-
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- KNOWLEDGE
OF SYSTEMIC DESEASE
-
- Dow
Corning Bioscience Research Laboratory “Research Project
Description” entitled “Organosilicone Polymer Particle
Technology.” The objective is to “Synthesize uniform particles
of a number of organosilicon resin polymers” to create reactive
drug sites on these particles. The particles could be given locally
or systemically as direct drug deliver systems, i.e., the
instillation of a local anesthetic bonded to an organosilicon resin
in joint spaces, GI tract, etc. to relieve pain. They could also be
diagnostic or therapeutic uses such as binding antigen and/or
antibody or used in diagnostic immunological tests. (DCC 16001050)
-
- CITE:
DCC 16001050 - 16001055. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#144
- 00/00/73
-
- TESTING
- FRAUD,MISREPRESENTATION
-
- Robertson
and Braley, Dow Corning, author “Toxicological Studies, Quality
Control, And Efficacy Of The Silastic Mammary Prosthesis,” relying
on the 1970 dog study. They use a chart to illustrate complications
and claim that the findings are the results at the end of the
two-year study, when the chart is actually the findings at six
months.
-
- CITE:
T 3003 - 3001 Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#145
- 00/00/73
-
- KNOWLEDGE
OF LIQUID SILICONE DANGERS
- GEL
MIGRATION
-
- A
Dow Corning study examines the suitability of injectable silicone
fluid for soft tissue augmentation. Four observed positive
tumorigenic findings of fibroadenoma and fibrosarcoma are dismissed
as tumore characteristically and typically seen spontaneously in
rodents and not related to treatment with silicone fluid. Data
reveals phagocytosis evidenced by the presence of macrophage
histiocytes and basal giant cells, with absorption of silicone and
deposition throughout the reticuloendothelial system.
-
- CITE:
KMM 48449 - 48498. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#146
- 03/12/73
-
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- GEL
MIGRATION
- SHELL
DEGRADATION
-
- Dow
Corning Bioscience Research Laboratory “Research Project
Description” entitled “Biodegradation” prepared by Dr. Isquith
of Dow Corning. The objective is “To determine the ability of
microorganisms to biodegrade a polydimethylsiloxane (PDMS) structure
and the subsequent microbial fate of its degradation products.”
-
- CITE:
DCC 16000273 - 16000279. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#147
- 03/19/73
-
- KNOWLEDGE
OF SYSTEMIC DISEASE
- MISCELLANEOUS
- COMPLICATIONS
- TESTING
- TISSUE
REACTION
-
- Study
from Bennett, Statt, LeBeau, Golzinski, E. Wiessbruger, J.
Weissburger and Ulland regarding item 17, “Primate Absorption and
Elimination Balance Studies Including Pulmonary, Urinary, Biliary
and Fecal Excretion of T-butanol, Trimethylsilanol,
Dimethylilanediol and Hexamethyldisiloxane,” item 18, “Primate
Absorption and Elimination Balance Studies Including Pulmonary,
Urinary, Biliary and Fecal Excretion of
Octamethyl-cyclotetrasiloxane and
2,6-cis-Diphenylhexamethylcyclotetrasiloxane,” item 19 “Chronic
Toxicity and Carcinogenicty of Industrial Chemicals and
Pesticides.” CITE: DCC 281061215 - 281061216, Exhibit 56 to
Bennett Deposition (used by Dow Corning).
-
- -------------------
-
-
- Document
#148
- 04/05/73
-
- EMBOLISM
- KNOWLEDGE
OF LIQUID SILICONE DANGERS
- STERILIZATION/CONTAMINATION
-
- Report
by S. Braley, Dow Corning, of telephone conversation with Mrs.
Herman D. Jones of the
Georgia Crime Lab regarding a death caused by a breast injection of
silicones. Pathologist reports large amounts of silicone emboli in
the brain and lungs. In the case of the breast tissue, the silicone
was dripping out. Current testing equipment and procedures will
accurately test for the carbon silicon bond but will not detect
where the silicone came from, whether there were additives in the
silicone or whether it was pure silicone. They will detect whether
they were phenyl methyl silicones or all methyl.
-
- CITE:
KMM 305064 - 305065. Dow Corning Trial Exhibit List Abstracts
- PENDLETON/PSC
Attorney Work Product/Privileged & Confidential
-
- -------------------
-
-
- Document
#149
- 05/02/73
-
- SHELL
STRENGTH - THICKNESS
- RUPTURE
-
- Gary
Corbeill, Reliability Engineer for Dow Corning, analyzes a Silastic
Round implant returned by Drs. Terino and Sengleman to Bill Mantle,
who in turn sent them to Art Rathjen. Corbeill states that, “Due
to their thin ‘skin’ these mammaries are delicate and will
rupture when subjected to undue pressure.” (emphasis added).
CITE:
CR 160 - 161. NOTE: Bill Mantle is the sales representative for the
Los
Angeles area. Dow Corning Trial Exhibit List Abstracts
PENDLETON/PSC Attorney Work
Product/Privileged & Confidential
- -------------------
-
-
- Document
#150
- 05/22/73
-
- ACKNOWLEDGEMENT
OF NEED FOR TESTING
- KNOWLEDGE
OF SYSTEMIC DISEASE
-
- Dow
Corning Bioscience Research Laboratory “Research Project
Description” entitled “Exploratory Antigen Modification,”
prepared by Dr. Isquith of Dow Corning. It was later re-titled
“Silicon-containing Antigens.” The objective is “To determine
the capability of organosiclicon-midified antigens to stimulate or
reduce immunogenic response.” Isquith suggests a direct
modification of antigens by chemical attachment of low molecular
weight organosilicon moieties” as an alternative to other antigens
(such as peanut oil) which cause adverse health effects. (KMM
546449) He states that, “This project is aimed at examining the
effect, if any, of silicon-modification on known antigens. The value
will be in the immuno-therapeutic valve of the modified effects. An
increase or decrease in antibody synthesis, caused by antigen
modification, may be desirable.” (KKM 546453)
-
-
- CITE:
KMM 546448 - 546453, Exhibit to Bennett Deposition, Exhibit to
Blocksma Deposition (used by Dow Corning), Exhibit to Radonovich
Deposition, Exhibit to Isquith Deposition, Exhibit to Tyler
Deposition, Exhibit to Boley Deposition, Exhibit to LeVier
Deposition, and Exhibit to Lake Deposition. This document also has
the Bates Number KMM 491075A - 491080A on it. WITNESS: Bennett
(Authenticated in Isquith, Vol. II, p. 355: 1-6 and 357: 13- 16).
DEPOSITION:
Not introduced in Toole (II) v Baxter Healthcare. Dow Corning Trial
Exhibit List
Abstracts
- PENDLETON/PSC
Attorney Work Product Privileged & Confidential
TO
DOCUMENTS: 151 - 200
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