IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY

                            FIRST JUDICIAL DISTRICT OF PENNSYLVANIA

                                      CIVIL TRIAL DIVISION

                                             - - -

                    ANGELO LAULETTA, ET AL.         : MAY TERM, 1994

                        VS.

                    TURCO PRODUCTS, INC. ET AL.    : NO.  2067


                                             - - -

                                      ROOM 253, CITY HALL
                                   PHILADELPHIA, PENNSYLVANIA

                                             - - -

                                        FEBRUARY 5, 1999

                                             - - -

                          CONTINUING TESTIMONY OF ROBERT CUNITZ, PH.D.

                                             - - -

                             BEFORE:  HONORABLE VICTOR J. DI NUBILE
                                          AND A JURY

                                             - - -




                      GEORGE D'ANGELIS, R.P.R., OFFICIAL COURT REPORTER
                                     LAND TITLE BUILDING
                                100 S. BROAD STREET, 2ND FLOOR
                              PHILADELPHIA, PENNSYLVANIA, 19110
                                        (215) 683-8056

                                             - - -
 








                    APPEARANCES:


                                 DEMARCO AND DEMARCO
                                 BY: JAMES J. DEMARCO, ESQUIRE
                                 COUNSEL FOR THE PLAINTIFFS





                                 BY:  PHILIP VOGLER, ESQUIRE
                                      ROBERT MANNINO, ESQUIRE
                                 COUNSEL FOR TURCO PRODUCTS AND ASHLAND
                                 CHEMICAL






















                        GEORGE D'ANGELIS, R.P.R., OFFICIAL COURT REPORTER
                                     LAND TITLE BUILDING
                                100 S. BROAD STREET, 2ND FLOOR
                              PHILADELPHIA, PENNSYLVANIA, 19110
                                        (215) 683-8056

                                            - - -
 









                                             INDEX
                                             _____











                    WITNESSES:

                                           DIRECT     CROSS    REDIRECT



                      ROBERT CUNITZ, M.D.    6         48         67
 
                                                                             4




         1

         2                            MORNING_SESSION
                                      _______ _______

         3

         4

         5                       (THE FOLLOWING TRANSPIRED IN OPEN

         6                 COURT, IN THE PRESENCE OF THE JURY:)

         7                             THE COURT:  GOOD MORNING.  WE

         8                 WILL PROVIDE YOU WITH THE REVIEW OF THIS

         9                 MATERIAL.  I THINK I CAN HELP YOU.  DR.

        10                 CUNITZ DISCUSSED THE GENERAL CONCEPTS OF

        11                 WARNINGS.  THEN WE PRESENTED THE VARIOUS

        12                 DOCUMENTS, P-3, P-5, P-9 P-20 AND D-11.  D-11

        13                 BEING ACTUALLY MORE THAN A DOCUMENT.  IT'S

        14                 THE DRUMMOND QUESTION WITH THE WARNING.  SO

        15                 ON IT I THINK THAT THE VARIOUS EXHIBITS

        16                 REFLECT THE WARNINGS THAT THE VARIOUS

        17                 PLAINTIFFS CAME IN CONTACT WITH DURING THEIR

        18                 WORK.

        19                             MR. DEMARCO:  I AM NOT SURE

        20                 WHETHER I SHOWED HIM THESE.

        21                             THE COURT:  YOU CAN SHOW IT TO

        22                 THE DOCTOR AGAIN.  I THINK P-3 WAS THE MOCKUP

        23                 OF THE TURCO WARNING LABELS.  IF YOU COULD

        24                 GET P-3.
 
                                                                             5




         1                       THEN ALSO P-5, WHICH IS A BLOWUP OF

         2                 SOLVENTS.  I'M NOT SURE IF THAT'S A TURCO

         3                 SOLVENT.  IT MIGHT BE P-5.  P-5 WAS A BLOWUP

         4                 OF A TURCO DRUM WITH A HANDLE ON IT.

         5                       P-20 WAS A PHOTOCOPY OF A WARNING LABEL

         6                 THAT YOU HAVE, I THINK, IN YOUR POSSESSION,

         7                 MR. DEMARCO, ON THE TABLE.  I THINK YOU WANT

         8                 TO SHOW THAT TO DR. CUNITZ AND THEN D-11 IS A

         9