60.
Email from Monsanto Toxicologist Michael Koch Discussing Tier 2 Studies
No: MONGLY02111857
Date: 9/10/2014
Documents Released: 3/15/2017
Description
This document contains an email from Michael Koch (Monsanto Toxicologist)
discussing multiple Tier 2 studies and a 1-year Dog Waiver Draft for Canada.
The study and the draft are redacted but Koch’s comments that precede
both can be viewed. His comments reference “Kimberly” –
Kimberly Hodge-Bell is a known participant and orchestrator in drafting
waiver requests to regulatory agencies.
61.
Monsanto Executive Expresses Long-Held Concerns Over IARC Testing Glyphosate
No: MONGLY01208470
Date: 9/18/2014
Documents Released: 8/1/2017
Description
This document contains an email from Dr. Donna Farmer to Dr. John Acquavella.
Dr. Farmer notes: “Just wanted to let you that what we have long
been concerned about has happened. Glyphosate is on for an IARC review
in March of 2015.” at *1.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as it demonstrates Monsanto’s long-term concerns about glyphosate
being tested by an independent research agency which rendered a general
causation conclusion regarding the potential for glyphosate to cause cancer.
That Monsanto knew IARC could come to its scientific conclusion, lends
support to the appropriateness of that opinion. It also suggests reliability,
an element under Daubert. This is also relevant to Dr. Farmer’s
credibility, who is one of Monsanto’s primary expert witnesses at
the company.
62.
Months Before IARC Report, Monsanto Executive Admits Company Faces Issues
in Epidemiology, Exposure, Genotoxicity and Mode of Action
No: MONGLY00989918
Date: 10/15/2014
Documents Released: 8/1/2017
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.
63.
Monsanto Consultant Acknowledges Relevance of Other Roundup Ingredients
in Judging Plausibility of Glyphosate Carcinogenicity
No: ACQUAVELLAPROD00008909
Date: 1/23/2015
Documents Released: 8/1/2017
Description
This document contains email correspondence between Drs. Donna Farmer and
John Acquavella, wherein Dr. Acquavella discusses the response from DeRoos,
who carried out an epidemiological study on glyphosate, to Monsanto’s
comments regarding the dose thresholds cited by Monsanto as relevant for
carcinogenicity. Dr. Acquavella reflects with respect to DeRoos’
comments: “the issue of the human findings representing relevant
routes of exposure (whatever that means) and being interpretable in and
of themselves. Perhaps Tom should be prepared regarding the other ingredients
in Roundup formulations being relevant for judging glyphosate.” at *1.
Relevance
This document is relevant and reasonably likely to be used in this litigation
as Monsanto’s former employee and consultant recognizes the potential
relevance of other ingredients in Roundup formulations in assessing the
biological plausibility of glyphosate as a carcinogen. It also lends support
to the DeRoos study, which is relied upon by experts on both sides. The
document is also relevant to credibility of Monsanto’s primary witness,
Acquavella.
64.
Monsanto Internal Email: Company Executive Admits to Low Level of Formaldehyde
in Roundup
No: MONGLY00990361
Date: 3/13/2015 – 3/17/2015
Documents Released: 8/1/2017
Description
This document contains an email from Dr. William Heydens to Mr. Josh Monken
(Monsanto) wherein Dr. Heydens admits to the “Low level presence
of formaldehyde” (carcinogen by inhalation) in Roundup; and “Low
level presence of NNG (N-nitroso-glyphosate) in Roundup – many N-Nitroso
compounds are carcinogenic.”
Relevance
This document is relevant and reasonably likely to be used in this litigation
as a Monsanto toxicologist contradicts Monsanto’s claim that it
is not biologically plausible for glyphosate nor the Roundup formulation
to be carcinogenic. This document suggests the opposite. It is also relevant
to credibility of Dr. Heydens.
65.
Internal Email from Donna Farmer: Monsanto Would Rather Keep Roundup NNG
Levels Below 1ppm Rather Than Engage in Scientific Debate Around Biological Activity
No: MONGLY01185582
Date: 7/31/2015
Documents Released: 3/15/2017
Description
This document contains email correspondence between John Acquavella and
Donna Farmer. Donna Farmer concedes that NNG is “an impurity that
arises via reaction of glyphosate with nitrosating agents during or after
manufacture.” Farmer adds that Monsanto’s stance on NNG: “…as
a general policy standard, regulators globally have accepted that nitrosamine
impurities are unavoidable in some amine- based pesticides, and that they
do not require special testing or risk assessment if the levels are at
1ppm or lower. Monsanto therefore prefers to carefully control against
NNG formation rather than to engage in scientific debate around its biological
activity.”
66.
Email Detailing Monsanto Suspicions That Formulated Roundup Can Lead to
Tumor Production
No: MONGLY01183933
Date: 8/6/2015 – 8/7/2015
Documents Released: 8/1/2017
Description
This document contains email correspondence between various Monsanto personnel
regarding the Roundup formulation and the respective effects of glyphosate
and surfactants, wherein Dr. William Heydens states that “surfactant
in the formulation will come up in the tumor promotion skin study because
we think it played a role there.” At *3.
Relevance
The document is relevant and reasonably likely to be used in this litigation
as it once again demonstrates suspicions by Monsanto that it is biologically
plausible for the formulated product to promote tumors. This is also relevant
to Dr. Heyden’s credibility, who is one of Monsanto’s primary
expert witnesses at the company.
67.
Monsanto Consultant: ‘You Can’t Say That There is no Evidence’
of Roundup Carcinogenicity
No: MONGLY00978170
Date: 9/16/2015 – 11/2/2015
Documents Released: 8/1/2017
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.
68.
Monsanto Internal Email on NNG and Formaldehyde Testing Before and After Aging
No: MONGLY06758730
Date: 2/13/2016
Documents Released: 3/15/2017
Description
In this email correspondence, Richard Garnett (Monsanto EU), Lisa Flagg
(Monsanto Global Product Quality Lead, Crop Protection) and others discuss
storage testing of glyphosate. Specifically, the email comments on how
long-term storage of glyphosate increases NNG levels.
Bart Roose (Monsanto EU): “I would suggest we agree in writing that `bad results’ of NNG due to accelerated ageing can be caused by the heat level and is therefore not representative for “normal ageing’.”