1
              1  MELVIN J NOVAK, JR,    *  IN THE
                 et ux,
              2                           *  CIRCUIT COURT FOR
                           Plaintiffs,
              3                           *  FOR
                 v
              4                           *  BALTIMORE CITY
                 BAYER CORPORATION,
              5  et al,                  *  Case No 24C02001729

              6            Defendants    *

              7  *    *    *    *    *    *    *    *    *    *

              8

              9       DEPOSITION OF J PAUL WAYMACK, MD, ScD

             10

             11            The Deposition of J Paul Waymack, MD,

             12  ScD, was taken in the above-Captioned case on

             13  Tuesday, November 11, 2003, commencing at 10:00

             14  am at the Offices of One South Street,

             15  Baltimore, Maryland, and was reported by Cari M

             16  Inkenbrandt, RPR, Notary Public

             17

             18

             19                 EVANS REPORTING SERVICE
                                2 North Charles Street
             20               Baltimore, Maryland  21201
                                     (410)727-7100
             21
 

                                                                2
              1  APPEARANCES:

              2  NANCY G RHOADS, ESQUIRE
                      Sheller, Ludwig & Badey, PC
              3       3rd Floor
                      1528 Walnut Street
              4       Philadelphia, Pennsylvania  19102
                      (215)790-7300
              5            On Behalf of Plaintiff

              6  MICHAEL L LISAK, ESQUIRE
                      Goodell, DeVries, Leech & Dann, LLP
              7       One South Street, 20th Floor
                      Baltimore, Maryland  21202
              8       (410)783-4000
                           On Behalf of Defendant
              9            The Bayer Corporation

             10  DENA M TERRA, ESQUIRE
                      Whiteford, Taylor & Preston, LLP
             11       210 West Pennsylvania Avenue
                      Towson, Maryland  21204
             12       (410)832-2013
                           On Behalf of Defendant
             13            Geoffrey N Sklar, MD

             14

             15

             16

             17

             18

             19

             20

             21
 

                                                                3
              1                  P R O C E E D I N G S

              2              J PAUL WAYMACK, MD, ScD

              3  a witness herein, called for oral examination in

              4  the matter pending, being first duly sworn to tell

              5  the truth, the whole truth and nothing but the

              6  truth testified as follows:

              7                       EXAMINATION

              8  BY MS RHOADS:

              9       Q    Dr Waymack, let me start with just a

             10  few instructions  If you do not hear a question,

             11  just say so, and I'll repeat it  Do you

             12  understand that?

             13       A    I understand

             14       Q    If you do not understand a question, say

             15  so, and I will rephrase it  Do you understand

             16  that?

             17       A    I understand

             18       Q    And if you do not know the information

             19  necessary to answer questions or if you don't

             20  remember, just indicate that  Do you understand

             21  that?
 

                                                                4
              1       A    I understand that

              2       Q    Doctor, did you receive this notice of

              3  deposition?

              4            MR LISAK:  If this is the one that was

              5  faxed in last night, I provided a copy to Dr

              6  Waymack this morning

              7            THE WITNESS:  I received that this

              8  morning about an hour ago

              9            MR LISAK:  We'll mark that as Waymack

             10  1

             11       (Waymack Deposition Exhibit No 1 marked for

             12  identification)

             13  BY MS RHOADS:

             14       Q    Did you bring materials listed on that

             15  notice?

             16       A    I have brought materials that are on

             17  that notice, the exceptions being I have not -- I

             18  did not bring my invoices, because again, I only

             19  received that when I arrived her