Understanding epidemiological evidence; what to ask the expert witness.Epidemiological evidence is more likely now than ever before to be used in toxic tort A toxic tort is a special type of personal injury lawsuit in which the plaintiff claims that exposure to a chemical caused the plaintiff's toxic injury or disease. Different types Toxic torts arise in different contexts. cases. The 1993 Supreme Court ruling in Daubert v. Merrell Dow Pharmaceuticals Daubert v. Merrell Dow Pharmaceuticals, , applied the rules governing expert testimony established by the Federal Rules of Evidence to the admission of scientific evidence at trials conducted in federal courts. , Inc., centered on expert witnesses and raised important questions about epidemiology studies as evidence.(1) The Court ruled that scientific evidence could be admitted without meeting the Frye standard The Frye standard is a legal precedent regarding the admissibility of scientific examinations or experiments in legal precedings. This standard comes from the case Frye vs. United States (293 F. 1013 (DC Cir 1923)) District of Columbia Circuit Court in 1923. of "general acceptance" from the scientific community,(2) and that Federal Rule of Evidence 702, which had superseded the Frye rule, imposed no such requirement. By broadening the range of potentially admissible evidence admissible evidence n. evidence which the trial judge finds is useful in helping the trier of fact (a jury if there is a jury, otherwise the judge), and which cannot be objected to on the basis that it is irrelevant, immaterial, or violates the rules against hearsay , the Supreme Court has made it necessary for trial lawyers to understand epidemiology studies better. This article identifies several decision points in an epidemiology study. Knowing about them can help lawyers make a stronger case. The article is not an exhaustive presentation of all the relevant issues but an introduction on how to ask the right questions of experts when assessing a study, taking a deposition, or examining witnesses during a trial. Most toxic tort litigators are familiar with epidemiology basics, which are crucial to these cases.(3) By now, terms like "relative risk," "attributable risk attributable risk Epidemiology Any factor which ↑ the risk of suffering a particular condition. See Relative risk, Risk factor. Cf Nonattributable risk Statistics The rate of a disorder in exposed subjects that is attributable to the exposure derived from ," and "dose-response relationship The Dose-response relationship describes the change in effect on an organism caused by differing levels of exposure (or doses) to a stressor (usually a chemical). This may apply to individuals (eg: a small amount has no observable effect, a large amount is fatal), or to populations " are familiar.(4) But knowing only how to read off a study's results means treating them as magic numbers Magic numbers The number of neutrons or protons in nuclei which are required to fill major quantum shells. They occur at particle numbers 2, 8, 20, 50, and 82. . Before questioning the epidemiologist, the lawyer should summarize sum·ma·rize intr. & tr.v. sum·ma·rized, sum·ma·riz·ing, sum·ma·riz·es To make a summary or make a summary of. sum the plaintiff's case. The summary should include a complete medical history, exposure information (from company or private records); dates and characteristics of extreme exposures; and life-style factors potentially related to the disease, such as smoking and hobbies. This information can then be compared to data about a typical study subject in the research being examined. Study Design The decision to use one study design rather than another can greatly affect the outcome of the research. Each design has particular strengths and abilities to detect associations between exposure and illness. There are four major study designs--cohort, case-control, clinical trial, and cross-sectional survey. (These are the most popular labels, but there are many synonyms for study design types.) Lawyers can eliminate confusion from the outset by finding out exactly what design was used. * A cohort study A cohort study is a form of longitudinal study used in medicine and social science. It is one type of study design. In medicine, it is usually undertaken to obtain evidence to try to refute the existence of a suspected association between cause and disease; failure to refute compares people who were exposed to a toxic substance with people in a reference group drawn from the general population and then asks whether the groups have different rates of disease. This type of study examines a group of people who all have had or will have a range of similar exposures; for example, gas station workers and exposure to benzene benzene (bĕn`zēn, bĕnzēn`), colorless, flammable, toxic liquid with a pleasant aromatic odor. It boils at 80.1°C; and solidifies at 5.5°C;. Benzene is a hydrocarbon, with formula C6H6. . The study may be historical, identifying people who were exposed in the past and then locating the relevant medical records. For many toxic tort questions, this is the only way to conduct a study because the product is no longer used or manufactured. Alternatively, the cohort study may go forward in time. For example, it might enroll all gas station workers who begin their jobs next week, then collect exposure and medical information as time progresses and compare exposure and disease rates. * A case-control study case-control study, n an investigation employing an epidemiologic approach in which previously existing incidents of a medical condition are used in lieu of gathering new information from a randomized population. compares people who have the disease to people who do not and asks if there was a difference in whether or how much they were exposed. This type of study uses subjects whose disease status is known. The cases (those with the disease) are compared to the members of the control group (those without the disease). Generally an industrial hygienist will quantify the exposures, preferably while blind to the disease status of the study subjects. * In a clinical trial, people are exposed or dosed with specific amounts of an agent (for example, a drug or radiation), and the effects it has on them are observed. Obviously, this type of study is not ethical in occupational or environmental research, as the exposure carries no purported benefit to the subject and may actually produce harmful side effects Side effects Effects of a proposed project on other parts of the firm. . * The cross-sectional survey design is familiar to most people. This design is used in taking opinion polls, doing market research, and establishing TV ratings. The cross-sectional survey simply asks subjects, "What is your current exposure and disease status?" There is no time dimension in a cross-sectional survey, and generally the data are self-reported. This type of study is often used to help determine whether more studies are needed. Cross-sectional surveys should not be relied on exclusively, although they can provide a rationale for proceeding with further investigations. Common Designs The cohort and case-control designs are the most common in toxic tort studies. The lawyer should ask the epidemiologist why the particular study design was chosen. Common reasons include time constraints In law, time constraints are placed on certain actions and filings in the interest of speedy justice, and additionally to prevent the evasion of the ends of justice by waiting until a matter is moot. , data availability Refers to the degree to which data can be instantly accessed. The term is mostly associated with service levels that are set up either by the internal IT organization or that may be guaranteed by a third party datacenter or storage provider. , and cost. The reasoning behind this choice may weaken the study's effectiveness as evidence in court. Cross-sectional surveys are much less informative than cohort or case-control studies. However, a cohort study may have been impractical im·prac·ti·cal adj. 1. Unwise to implement or maintain in practice: Refloating the sunken ship proved impractical because of the great expense. 2. because the background rate of disease is too low. Or a case-control study may have been chosen because of exposure prevalence. There is no standard or preferred study design that is best in all cases. However, the reasoning behind the design choice is worth elucidating. Comparing Populations Each study design takes a group of exposed or diseased dis·eased adj. 1. Affected with disease. 2. Unsound or disordered. people and compares it to another population in order to determine if there is a relationship between exposure and disease. Generally, cohort studies compare the rate of disease within the cohort to the rate found in a wider external population--for example, comparing the mortality rate of gas station attendants to that of men in the United States United States, officially United States of America, republic (2005 est. pop. 295,734,000), 3,539,227 sq mi (9,166,598 sq km), North America. The United States is the world's third largest country in population and the fourth largest country in area. . In a cohort study, the lawyer should ask the epidemiology expert to detail the inclusion criteria
Inclusion criteria are a set of conditions that must be met in order to participate in a clinical trial. for cohort membership, such as geography, gender, or race. The boundaries of the cohort help determine the extent to which the findings can be generalized. The comparison population should not be inappropriate. For example, usually a cohort of white women should not be compared to an external population of white men. A case-control study should include a description of the criteria for selecting the controls. Were they chosen randomly? Were they matched on specific characteristics? A cross-sectional survey should include a careful description of the population available for the study (both participants and non-participants). Did the survey include only those who were evacuated e·vac·u·ate v. e·vac·u·at·ed, e·vac·u·at·ing, e·vac·u·ates v.tr. 1. a. To empty or remove the contents of. b. To create a vacuum in. 2. from a toxic chemical Any chemical which, through its chemical action on life processes, can cause death, temporary incapacitation, or permanent harm to humans or animals. This includes all such chemicals, regardless of their origin or of their method of production, and regardless of whether they are produced spill site? Did the survey cover the whole town? The entire county? Confounding confounding when the effects of two, or more, processes on results cannot be separated, the results are said to be confounded, a cause of bias in disease studies. confounding factor Factors In many studies, confounding factors must be examined. These are factors--like race, sex, and smoking habits--that are potentially misleading because they can be associated with exposure and/or disease and must be eliminated from the causal pathway.(5) Potentially confounding factors are identified and collected for use during the analysis of the study. They should be "controlled or adjusted for"--that is, the apparent causal relationship should be taken out of the association. This can be done through the specialized mathematical techniques of stratification stratification (Lat.,=made in layers), layered structure formed by the deposition of sedimentary rocks. Changes between strata are interpreted as the result of fluctuations in the intensity and persistence of the depositional agent, e.g. or regression.(6) The lawyer should question the epidemiologist carefully on these points. The decision to include or exclude potential confounders can introduce biases or mitigate them through the data analysis process. Exposure Assessment Lawyers examining an epidemiology study are most likely to overlook the exposure assessment. Yet this assessment establishes the basis of comparison among exposed groups and is the cornerstone of the study. Ultimately, the numbers generated by the exposure assessment also define the critical dose-response relationship in which an increase in exposure (dose) is expected to result in a higher rate of disease (response). Many people take an uncritical approach to exposure data in epidemiology research. Even epidemiologists often neglect to check whether the exposure assessment method was valid. However, statistics in most cases are only as good as the data that go into them and the method by which the data were obtained. The lawyer should begin by examining the method of exposure assessment and finding out whether it is standard in the field. Was the assessment supervised by a certified See certification. industrial hygienist with relevant experience? New techniques are often used in exposure assessment because epidemiology is a relatively new field and the industrial hygienist may have to work with poor data. The lawyer should ask the epidemiologist if other researchers have validated or replicated the method of assessment, possibly using other agents of exposure or different circumstances. Sometimes continuous data (for example, the percentage of chemicals in the air) are reduced to discrete exposure categories like low, medium, and high. The lawyer should ask the researcher to explain the rationale for the choice of break points between categories. It is possible that if the break points had been set higher or lower, the study would have produced an entirely different statistical result that could lead to a different interpretation. Attributable Risk Rate Much has been written on using the attributable risk rate calculation in toxic tort cases.(7) This calculation describes the amount of disease that the alleged exposure could be responsible for. In legal cases, it is important to be sure that the plaintiff's exposure experience is correctly categorized cat·e·go·rize tr.v. cat·e·go·rized, cat·e·go·riz·ing, cat·e·go·riz·es To put into a category or categories; classify. cat and the relevant attributable risk is calculated. Summaries of the plaintiff's exposure history will be useful here. A comparison of the plaintiff's risk with the risk for a similar category of study participants can be persuasive. Many sophisticated ways to calculate the probability of causation causation Relation that holds between two temporally simultaneous or successive events when the first event (the cause) brings about the other (the effect). According to David Hume, when we say of two types of object or event that “X causes Y” (e.g. have been developed for risk assessments. If these methods are used, the lawyer should examine the assumptions (such as the disease model, the exposure levels, background rate of occurrence, and the age-at-risk calculation) that went into them.(8) Evaluating Associations Epidemiology uses three related concepts--statistical power, statistical significance, and confidence intervals confidence interval, n a statistical device used to determine the range within which an acceptable datum would fall. Confidence intervals are usually expressed in percentages, typically 95% or 99%. . These deal with the likelihood of finding true associations between exposure to the agent and illness and eliminating random or chance associations. One way to think about these concepts is to use the image of a fishing net. The net can be very fine-meshed, and so capture all the fish, or it can be coarse, and so catch only the larger fish. The factors that determine the appropriate mesh size are the size of the fish desired and the relative costs of catching many unwanted undersize fish with a fine net or letting some of the desired fish slip through with a coarser one. * Statistical power refers to the ability of a study to detect a relationship between exposure and disease occurrence of a certain magnitude. The researcher initially calculates this ratio a number of times, using different sets of assumptions about the prevalence of the disease or exposure, the variance (that is, variation of exposure and disease rates in the population), and the number of eligible subjects. The purpose is to determine what level of relative risk might be detected if a true relationship exists. Using the fishing net analogy, the power of the study is like the size of the mesh, which determines how small a fish the net can capture. The estimate of the power of the study may indicate that it could only detect extremely large effects and therefore has very low power. If so, the fact that it did not find an association is not proof that no significant effect exists. (A coarse net may let even big fish slip through.) However, a lowpower study may still be worth doing in order to form a baseline of information or to contribute to a larger grouped analysis later. The lawyer should ask the researcher to provide statistical power calculations and describe what assumptions were used to make them and in what ways that affected the actual study. * Statistical significance levels or probability values refer to the study's ability to eliminate random chance as the reason for the association found in the study. The level of statistical significance set by the researcher generally ranges between 80 percent and 95 percent.(9) The level determines how strong the relationship between two or more variables has to be before it is considered to be due to something other than chance. Again, the fishing net example can be used to compare the statistical significance level to the number of fish to be allowed into the net even though they were not the ones originally fished for. That is, the "net" might be too sensitive, so that false positive associations (comparable to unwanted undersize fish) would be found. A higher figure for statistical significance reduces the number of small fish inadvertently caught in the net. But it also excludes many others that should have been caught. The level set by the researcher is usually 95 percent, which basically means that 1 in 20 of the associations identified by the study might be due to random chance. Other researchers set the statistical significance level at 90 percent. They would rather risk finding false positives (the wrong fish in the net) than let the important ones get away (empty net). The lawyer should ask the epidemiologist to describe why the specific level was chosen and if it was changed for any of the tests. Finding a statistically significant result is important but not essential for building an argument about exposure and disease relationships. In many studies, the result barely excludes or includes the point of statistical significance. The lawyer should ask the epidemiologist whether this study's outcome depends on a small number of cases or a particular exposure classification system. * Confidence intervals are closely related to the statistical significance test, but they give far more information to the interpreter of the data. For the fish net example, the confidence interval tells what size fish the net is designed for and how many fish the net can catch. Confidence intervals denote de·note tr.v. de·not·ed, de·not·ing, de·notes 1. To mark; indicate: a frown that denoted increasing impatience. 2. the degree of uncertainty around a statistical test like the test for relative risk. The confidence interval includes the point estimate (such as the relative risk ratio), based on the data and the upper and lower bounds This article is about order theory and lattice theory. For analysis of algorithms in computational complexity, see Big O notation. In mathematics, especially in order theory, an upper bound of a subset S of some partially ordered set (P of relative certainty of the estimate. These are generally set at 95 percent, and they incorporate the variation of the estimate and the probability of finding random associations. Many people--scientists and others--find that the confidence interval is easier to interpret than probability values because it provides numbers that represent the magnitude of the exposure-disease relationship.(10) At a minimum, the lawyer should ask the epidemiologist to describe the components of the confidence interval being discussed and to provide an interpretation of the upper and lower boundaries of relative certainty. Quality Control and Assurance A program of quality control for each step of the study, established before any data collection, will improve the accuracy of the study. The Environmental Protection Agency Environmental Protection Agency (EPA), independent agency of the U.S. government, with headquarters in Washington, D.C. It was established in 1970 to reduce and control air and water pollution, noise pollution, and radiation and to ensure the safe handling and now requires epidemiology studies to be conducted using "good laboratory practices."(11) The intent and method of quality control should be clearly documented in the study notes. Generally, quality control is done by the individual data collectors and programming staff, with some review by the supervisor. The quality assurance effort involves an overview of the entire study to ensure that there are no systematic errors. Quality assurance should be done by someone not involved in the day-to-day running of the study--perhaps a colleague, review panel, or outside auditor. When reviewing the quality control and quality assurance programs, the lawyer should note the qualifications of the data collectors and supervisors. Data collection provides the basis of the final study results, and since it is usually done by students or research assistants, it ought to be supervised to ensure that rules are followed, variations documented, and errors corrected. The documentation of the quality program should also describe how any substantial problems were resolved. For example, it should identify a data collector who is consistently inaccurate or programming errors that may have been discovered late in the analysis and describe what measures were taken to remedy the situation. Causation The scientific criteria for causation in epidemiology are different from the legal criteria for causation. This distinction must be made clear to all participants in the trial. It is important that everyone keep in mind that mere statistical association between an exposure and an illness, however strong, does not guarantee that the first caused the second. An example often cited in epidemiological circles is the relationship between using nitrate nitrate, chemical compound containing the nitrate (NO3) radical. Nitrates are salts or esters of nitric acid, HNO3, formed by replacing the hydrogen with a metal (e.g., sodium or potassium) or a radical (e.g., ammonium or ethyl). inhalants inhalants, n.pl 1. chemical vapors that are inhaled for their mind-altering effects. 2. in herbology, volatile herbal compounds that are delivered by holding a soaked pad to the nose and mouth, by placing the herbs in steaming water, or and developing AIDS.(12) A very strong association between the two was observed originally, leading some to believe that inhalants caused the disease. However, a little later HIV HIV (Human Immunodeficiency Virus), either of two closely related retroviruses that invade T-helper lymphocytes and are responsible for AIDS. There are two types of HIV: HIV-1 and HIV-2. HIV-1 is responsible for the vast majority of AIDS in the United States. was isolated, making it clear that the association between inhalant inhalant /in·hal·ant/ (in-hal´ant) 1. something meant to be inhaled; see inhalation (def. 3). 2. a class of psychoactive substances whose volatile vapors are subject to abuse. use and AIDS was the result of confounding factors in the study subjects' life-style. In epidemiology, guidelines guidelines, n.pl a set of standards, criteria, or specifications to be used or followed in the performance of certain tasks. for attributing causation are used, rather than strict criteria.(13) These guidelines normally include finding a statistical association showing * a relationship exists beyond random effects Random effects can refer to:
* the exposure precedes the disease, * a biologically plausible mechanism exists, and * a dose-response effect is seen. In addition, the findings should be consistent with other studies. Ultimately, these guidelines are used by scientists researching the study's subject to determine causation. Usually, no single study will be considered strong enough to prove causation in exposure and disease relationships. Conversely con·verse 1 intr.v. con·versed, con·vers·ing, con·vers·es 1. To engage in a spoken exchange of thoughts, ideas, or feelings; talk. See Synonyms at speak. 2. , several studies that fail to show an association do not disprove disprove, v to refute or to prove false by affirmative evidence to the contrary. a causative caus·a·tive adj. 1. Functioning as an agent or cause. 2. Expressing causation. Used of a verb or verbal affix. caus role for the exposure. Many authors have discussed the confusion between the legal and epidemiological criteria of causation.(14) A simplified version of the legal criterion is that there is a greater than 50 percent likelihood--that is, it is more probable than not--that the exposure caused the disease. When questioning the epidemiologist, the lawyer should be specific about the criterion. Both epidemiological and legal criteria of causality causality, in philosophy, the relationship between cause and effect. A distinction is often made between a cause that produces something new (e.g., a moth from a caterpillar) and one that produces a change in an existing substance (e.g. are important in the toxic tort trial. The epidemiology discussion should take place before the final legal assessment of causality. Most scientists are reluctant to assign causality in the epidemiologic sense but may be willing to consider the components under the legal definition.(15) Courtroom Use To date, there are no absolute rules or criteria for court acceptance of epidemiologic evidence in litigation An action brought in court to enforce a particular right. The act or process of bringing a lawsuit in and of itself; a judicial contest; any dispute. When a person begins a civil lawsuit, the person enters into a process called litigation. . This evidence is being used more and more frequently. It was first used successfully in Borel v. Fibreboard fibreboard Noun a building material made of compressed wood Noun 1. fibreboard - wallboard composed of wood chips or shavings bonded together with resin and compressed into rigid sheets fiberboard, particle board Paper Products Corp.(16) It was deemed necessary evidence in the Agent Orange decision.(17) It was also considered "the most useful and most conclusive type of evidence" found in toxic tort cases in Brock brock n. Chiefly British A badger. [Middle English brok, from Old English broc, of Celtic origin.] v. Merrell Dow Pharmaceuticals, Inc.,(18) and it was featured in the benzene exposure assessment reviewed in Mason v. Gerin Corp.(19) Most courts in the country seem to be admitting epidemiological evidence. However, some courts have barred or ignored it, which is what happened in Wells v. Ortho Pharmaceutical In 1941 Ortho Pharmaceutical was founded in Montreal, Canada. The company started with one product and three employees and it was one of the first companies in Canada to make oral contraceptives. Corp.(20) and Reyes v. Wyeth Laboratories.(21) Lawyers seeking guidelines for the appropriateness of epidemiological evidence should consider (1) the strength of the study and (2) the comparability of the plaintiff's situation to that of the study subjects. Finding many studies that support the plaintiff's case will strengthen it. For example, a plaintiff who has a clear history of exposure and has documented levels of exposure that can be related to the history of the subjects in the other studies will have an excellent opportunity to use epidemiological evidence in court. However, most plaintiffs do not have access to detailed personal exposure information. Therefore, the lawyer should ask the epidemiologist to focus on arriving at a well-justified approximate exposure assessment that can be compared to the studies available. Medical Opinion Finally, if an expert witness is providing a medical opinion, it is useful to determine the degree to which that opinion is based on epidemiology studies.(22) The lawyer should ask the expert detailed questions about his or her knowledge and understanding of the relevant studies. Ideally, the lawyer should then have an epidemiologist or other medical professional compare the expert's explanation to the actual text of the epidemiology study. This should help to determine whether the expert's interpretation of the study is indeed consistent with its results. It has been established that courts can look beyond the expert witness's opinion to the factors that support that opinion. The trial attorney can focus on decision points and research choices in epidemiology studies to attain a clearer understanding of the study result or the expert's opinion. No single study will ever be perfect. Studies use human subjects and historical occurrences, and therefore they can never be as completely controlled or exactly replicated as laboratory experiments can be. Questioning medical experts during depositions and in trial on the subjects suggested in this article will help the trial attorney create a convincing case by highlighting the scientific process and its strengths and weaknesses. The Supreme Court's decision in Daubert has opened the courtroom to a wider range of admissible evidence. This decision will make careful questioning of the underlying methods used in an epidemiology study essential. Notes (1)Daubert v. Merrell Dow Pharmaceuticals, Inc., 113 S. Ct. 2786 (1993). (2)Frye v. United States, 293 F. 1013 (D.C. Cir. 1923). (3)See, e.g., Bert Black & David E. Lilienfeld, Epidemiologic Proof in Toxic Tort Litigation, 52 FORDHAM L. REV. 732 (1984); Gerald W. Boston, A Mass-Exposure Model of Toxic Causation: The Content of Scientific Proof and the Regulatory Experience, 18 COLUM. J. ENVTL. L. 181 (1993); Thomas W. Henderson, Toxic Tort Litigation: Medical and Scientific Principles in Causation, 132 AM. J. EPIDEMIOLOGY 69 (Supp. 1990). (4)See, e.g., ABRAHAM M. LILIENFELD & DAVID LILIENFELD, FOUNDATIONS OF EPIDEMIOLOGY (1980). (5)See HARVEY CHECKOWAY ET AL., RESEARCH METHODS IN OCCUPATIONAL EPIDEMIOLOGY 84-85 (1989). (6)Id. at 95-96. (7)See, e.g., Black & Lilienfeld, supra A relational DBMS from Cincom Systems, Inc., Cincinnati, OH (www.cincom.com) that runs on IBM mainframes and VAXs. It includes a query language and a program that automates the database design process. note 3, at 760-61; Boston, supra note 3, at 236; Comment, Melissa M. Thompson, Causal Inference in Epidemiology: Implications for Toxic Tort Litigation, 71 N.C. L. REV. 247, 252-54 (1992). (8)See CHECKOWAY ET AL., supra note 5, at 325-27. (9)A few have called for 99 percent studies. See, e.g., Michael Dore, A Proposed Standard for Evaluating the Use of Epidemiological Evidence in Toxic Tort and Other Personal Injury Cases, 28 HOW. L.J. 677, 692-95 (1985). (10)KENNETH J. ROTHMAN, MODERN EPIDEMIOLOGY 119-25 (1986). (11)See, e.g., Judith K. Baldwin & Kristin Hoover, Quality Assurance and Quality Control in Toxicology toxicology, study of poisons, or toxins, from the standpoint of detection, isolation, identification, and determination of their effects on the human body. Toxicology may be considered the branch of pharmacology devoted to the study of the poisonous effects of drugs. : How Might These Concepts Apply to Epidemiology? 33 J. OCCUPATIONAL MED. 1247, 1248 (1991); Chemical Mfrs. Ass'n Epidemiology Task Group, Guidelines for Good Epidemiology Practices for Occupational and Environmental Epidemiologic Research, 33 J. OCCUPATIONAL MED. 1221, 1222 (1991). (12)Bert Black, Matching Evidence About Clustered Health Events with Tort Law A body of rights, obligations, and remedies that is applied by courts in civil proceedings to provide relief for persons who have suffered harm from the wrongful acts of others. Requirements, 132 AM. J. EPIDEMIOLOGY 79, 82 (1990). See also Thompson, supra note 7, at 263-64. (13)See, e.g., Alfred Evans Alfred Evans or Alf Evans may refer to:
BIOL Biological . MED. 175 (1976); A.B. Hill, Environment and Disease: Association or Causation? 58 PROC (language) PROC - The job control language used in the Pick operating system. ["Exploring the Pick Operating System", J.E. Sisk et al, Hayden 1986]. . ROYAL SOC. MED. 295 (1965); Mervyn Susser, What Is a Cause and How Do We Know One? A Grammar for Pragmatic Epidemiology, 133 AM. J. EPIDEMIOLOGY 635 (1991). (14)See, e.g., Harold H. Ginzburg, Use and Misuse of Epidemiologic Data in the Courtroom: Defining the Limits of Inferential in·fer·en·tial adj. 1. Of, relating to, or involving inference. 2. Derived or capable of being derived by inference. in and Particularistic par·tic·u·lar·ism n. 1. Exclusive adherence to, dedication to, or interest in one's own group, party, sect, or nation. 2. Evidence in Mass Tort Litigation mass tort litigation Mass injury claim Civil litigation A class of civil actions in which multiple plaintiffs are injured in a similar fashion by a defective product, hazardous substance, or disaster. See Asbestos, Breast implant, Class-action, Dalkon shield. , 12 AM. J.L. & MED. 423, 433-34 (1986); Steve Gold, Causation in Toxic Torts: Burden of Proof, Standards of Persuasion, and Statistical Evidence, 96 YALE L.J. 376 (1986); Barry Nace, Epidemiologic Evidence: Its Uses and Misuses in Toxic Tort Cases, TRIAL, Oct. 1988, at 62; and see Thompson, supra note 7, at 263-66. (15)See, e.g., Joshua E. Muscat Muscat, Maskat, or Masqat (all: mŭs`kăt, mŭs`kət), city (1993 pop. 533,774), capital of Oman, SE Arabia, on the Gulf of Oman. It is flanked by rugged mountains. & Michael S. Huncharek, Causation and Disease: Biomedical Science Noun 1. biomedical science - the application of the principles of the natural sciences to medicine bioscience, life science - any of the branches of natural science dealing with the structure and behavior of living organisms in Toxic Tort Litigation, 31 J. OCCUPATIONAL MED. 997, 998 (1989). (16)493 F.2d 1076 (5th Cir. 1973), cert (Computer Emergency Response Team) A group of people in an organization who coordinate their response to breaches of security or other computer emergencies such as breakdowns and disasters. . denied, 419 U.S. 869 (1974). (17)597 F. Supp. 740, 746 (E.D.N.Y. 1984). (18)874 F.2d 307, 311 (5th Cir.), modified, 884 F.2d 166 (5th Cir. 1989), cert. denied, 494 U.S. 1046 (1990); in Boston, supra note 3, at 284. (19)No. 78-1337 (D. Kan. 1983), in Troyen A. Brennan, Helping Courts with Toxic Torts, 51 U. PITT. L. REV. 1, 34, 37 (1990). (20)615 F. Supp. 262 (N.D. Ga. 1985), cert. denied, 479 U.S. 950 (1986). (21)498 F.2d 1264 (5th Cir.), cert. denied, 419 U.S. 1096 (1974). (22)Bert Black, Evolving Legal Standards for the Admissibility ad·mis·si·ble adj. 1. That can be accepted; allowable: admissible evidence. 2. Worthy of admission. ad·mis of Scientific Evidence, 239 SCI (Scalable Coherent Interface) An IEEE standard for a high-speed bus that uses wire or fiber-optic cable. It can transfer data up to 1GBytes/sec. (hardware) SCI - 1. Scalable Coherent Interface. 2. UART. . 1508, 1510-11 (1988). |
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