DEFENDANT’S EXPERT OPINION: DR. SURESH H MOOLGAVKAR

Movants also furnish an affidavit by Suresh H. Moolgavkar, a physician with a Ph.D. in mathematics and postdoctoral training in epidemiology and biostatistics. He is currently a member of the Fred Hutchinson Cancer Research Center in Seattle and a professor of epidemiology, adjunct professor of biostatistics, and adjunct professor of applied mathematics at the University of Washington at Seattle.

Dr. Moolgavkar opines that the molecular steps in the pathogenesis of mesothelioma are unknown, and which of these steps may be influenced by the presence of asbestos mineral fibers is unclear. The diversity of chemical and physical properties of the mineral fibers means that certain types of asbestos fibers, those in molded brakes or friction products, differ from chrysotile fibers found in other sources.> He invokes experimental research and studies performed by others including R. Valentine et al. demonstrating that heating chrysotile at a range of 300 to 400 degrees centigrade substantially reduced cytotoxicity to human fibroblast cells. He asserts that it is well known that the braking process involves temperatures that eventually transform a majority of chrysotile fibers into forsterite, an inert mixture of silica and magnesia.

According to research by Arthur M. Langer et al. published in 2002, that transformation occurs at temperatures around 650 degrees centigrade. Langer's research suggests that forsterite does not have the same biological activity (disease causing capability) as other fibers.

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