For Toxic-Tort Counsel

Daubert-ready toxicology, curated by a witness who's been there.

Mold, PCBs, dioxins, glyphosate, PFAS, hexavalent chromium. The science is solid. The sourcing is scattered. Assembling auditable, tier-tagged evidence packets for one case costs forty paralegal hours at $250/hour. Surviving a Daubert challenge with it depends entirely on your expert and the chain of citation backing him up. The TKG puts a working medical toxicologist in the loop on every claim, every source, every tier badge—before it leaves the platform.

Auditable provenance
Court-ready deliverables
The Dahlgren signature
What Plaintiffs' Counsel Walk Into

The science is on your side. The presentation isn't.

Toxicology evidence lives in silos. IARC monographs. ATSDR profiles. EPA IRIS records. Peer-reviewed cohort studies. Thirty years of agency reclassifications. Your paralegal assembles them. Your expert inherits them. Opposing counsel discovers all of it.

Citation Rot

The science you cite this quarter isn't the science the agency posts next quarter. EPA IRIS files revise. ATSDR profiles update. IARC reclassifies. If the version you cited at filing isn't the version on the website at deposition, you're handing opposing counsel an attack vector.

Daubert Exposure

Motion-to-exclude is the new motion practice. FRE 702 and its 2023 amendments put the burden on you to show your expert's methods are reliable. Without a structured chain of citation, every claim is a footnote your opposing counsel will challenge in chambers.

Discovery Surface

Your expert's reliance materials become opposing counsel's playground. Whatever your expert touches, opposing counsel inherits. A scattered reliance list with broken URLs and unversioned PDFs is a deposition where you spend two hours defending bibliographic hygiene instead of mechanism of injury.

What We Do · The Three Pillars

One platform. Three things it has to be.

The TKG isn't a database. It's a deliverable engine. Every claim you'd cite, every source you'd disclose, every figure you'd put in front of a judge—structured, versioned, and signed off by a working medical toxicologist before it ever leaves the platform.

Auditable Provenance

Every claim on the platform traces to a primary source, tier-tagged and timestamped to the exact document version cited. Three-source minimum. The chain holds whether opposing counsel pulls it on filing day or two years into discovery.

T1: Regulatory (IARC, EPA IRIS, ATSDR)T2: Peer-reviewed cohort and mechanismT3: Agency profile and secondary review

Court-Ready Deliverables

Output is structured for FRE 702 from the first byte. Bradford Hill criteria mapped per claim. Exhibit-ready PDFs that fit a senior associate's binder, not a slide deck. Every citation is bates-numberable; every figure has the cite under it.

PDFJSON-LDCSVBates-readyVersioned

The Dahlgren Signature

Every claim, source ranking, and tier badge passes a working toxicologist's deposition lens before it goes live. Not a panel. Not a committee. A name—James G. Dahlgren, M.D.—that opposing counsel has to confront, not the platform.

Forty years of cross-examination. Now in the data layer.
The Toxicologist in the Loop

James G. Dahlgren, M.D. Forty years on the witness stand. Now in the data layer.

James G. Dahlgren, M.D.

Occupational & Environmental Toxicology

Dr. Dahlgren is a board-certified internist and toxicologist with decades of expert-witness experience in chemical-exposure litigation—PCBs, dioxin, asbestos, hexavalent chromium, and the long tail of modern toxic-tort substances. He is the lead toxicology expert in the Sky Valley PCB case (Erickson v. Monsanto), and the curator of every claim, source, and tier ranking in the Toxicology Knowledge Garden.

1980s
Founding

James Dahlgren Medical. Independent occupational and environmental medicine practice in Los Angeles. Clinical care of patients with chemical-exposure injuries, plus expert evaluation for litigation.

1996
Hinkley, California

Served as toxicology expert examining residents of Hinkley for health effects of hexavalent chromium exposure in groundwater. Anderson v. Pacific Gas & Electric. $333 million settlement. The case that became the Erin Brockovich film.

2019
Sky Valley Retained

Lead toxicology expert for the plaintiffs in the Sky Valley Education Center PCB-contamination case. King County, Washington. PCBs and dioxin/furans bioaccumulating in occupants of a school building with PCB-containing caulk.

2025
Appellate Victory

$185 million verdict upheld by the Washington Supreme Court (6–3, October 2025). The jury award stood. The expert testimony stood. The cross-examination didn't crack it.

"Chromium was the poison in the Brockovich case. Chromium is super toxic and super carcinogenic. But chromium is only one molecule. There are thousands of toxic substances out there. The next case you walk into, you do not have to start from zero. The Garden is already there."

What Lawyers Actually Buy

The deliverables menu.

Twelve productized, named SKUs. All are case-specific or substance-specific. All are versioned, citation-grade, and Dahlgren-reviewed. Order one or order the bundle.

DEL-01

Daubert-Ready Exhibit Packet

Per-substance, per-jurisdiction. Strength-of-evidence map, tier-tagged source bibliography, Bradford Hill mapping per causal claim, anticipated cross-examination prep, and expert-credentials block. Ships as a chambers-ready PDF plus the underlying JSON-LD.

Dahlgren-signed | PDF, JSON-LD

DEL-02

Compound Dossier

Single-substance deep file: mechanism of toxicity, dose-response curves, latency periods, diagnostic biomarkers, accepted exposure metrics, regulatory thresholds across IARC / EPA / ATSDR / OSHA / WHO.

PDF, JSON-LD

DEL-03

Cohort Library Brief

Curated epidemiological cohort studies for a substance + outcome pair. Yu-Cheng, Faroe Islands, Tar Creek, Anniston AL, NHL/glyphosate, vinyl chloride/angiosarcoma. Effect sizes, population characteristics, exposure assessment methodology.

PDF, CSV

DEL-04

Strength-of-Evidence Memo

Ranks the strongest causal claims for a specific fact pattern. Plaintiffs' brief-shaped: which claims to lead with at trial, which to settle through, which to cite only in expert disclosure.

Dahlgren-signed | PDF

DEL-05

Bradford Hill Mapping

Per-claim mapping to all nine Bradford Hill criteria with source citations. Strength, consistency, specificity, temporality, biological gradient, plausibility, coherence, experiment, analogy—each with the strongest cite in your bibliography.

PDF, JSON-LD

DEL-06

Expert Disclosure (Rule 26)

Pre-formatted FRCP Rule 26(a)(2)(B) disclosure with CV, methods statement, complete reliance list with versioned/timestamped citations, and prior-testimony list for the past four years.

Dahlgren-signed | DOCX, PDF

DEL-07

Cross-Examination Brief

Common defense arguments at deposition with rebuttal authority. Anticipated motions to exclude with reliability and fit responses. Junk-science attacks with the agency citations that defeat them.

PDF

DEL-08

Regulatory Timeline

Agency-knowledge timeline for any substance: IARC reclassifications, EPA IRIS revisions, ATSDR profile updates, OSHA PEL changes. The "what did they know and when" exhibit, prebuilt.

PDF, CSV

DEL-12

Custom Curation (Dahlgren In The Loop)

Direct Dr. Dahlgren engagement on your specific case theory. Curation memo on the strongest evidentiary path, gaps to fill in expert work, and the substance-specific Daubert posture for your jurisdiction.

Dahlgren · 1:1
The Demo · Five Stages, Ninety Seconds

From case file to chambers-ready packet.

This is the actual flow Dr. Dahlgren walks through with plaintiffs' counsel. Live on the platform at toxicology.theknowledgegardens.com. The five stages compress forty paralegal hours into a workflow.

1

Case File

Walk through /case/sky-valley. The case file pre-populates everything: parties, parties' counsel, retained experts, the document corpus, the linked substances, and a 12-event chronology spanning EPA inspection, school closure, filing, expert retention, depositions, and trial. Erickson v. Monsanto. Sky Valley Education Center. King County Superior Court, Washington. PCB and dioxin contamination.

2

Compound & Claims

Click into /compound/pcbs. Eight certified claims, each tier-tagged and source-anchored. IARC Monograph 107. ATSDR toxicological profile. Yu-Cheng cohort (Taiwan, 1979). Faroe Islands cohort (NHANES analog). Anniston, Alabama. The T1 / T2 / T3 source-tier badges are the same strength-of-evidence hierarchy a working toxicologist uses in deposition prep.

3

Expert Profile

Click his name → /expert/dahlgren. His profile is the canonical entry point to his work. Curated bio, specialty, prior-testimony record, the cases he's signed onto in the platform, and the version-pinned substance dossiers behind his sworn opinions. When opposing counsel does discovery on you, this is what they find. Curated. Cited. Versioned.

4

Counsel Flow

Open the Counsel Flow. Walk five stages: Frame the theory of harm. Assemble the source set. Argue the Daubert posture—certified vs. contested claims, both sides of every contested cite. Witness the expert pack with credentials and prior testimony. File. Generate the Case-Prep Exhibit Packet PDF.

5

The Comparison

90 seconds on the TKG. 40 hours at the firm. Same substance. Same case theory. Same Daubert standard. One has a Dahlgren signature. The other doesn't.

One Platform. Every Discipline.

The ecosystem that compounds your advantage.

The Toxicology Garden is one node in a growing ecosystem. Each garden is independent. Each is cross-citable. Together, they create the witness chain judges can't impeach.

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When a TKG claim about glyphosate's neurotoxic mechanism is also tagged and cross-cited in the Health Knowledge Garden (HKG), something shifts. An HKG-affiliated treating clinician pulls up the patient's neurological workup and sees the same glyphosate evidence surface in the HKG context. The toxicology claim has just been strengthened by clinical verification.

Same substance, same endpoint, two independent gardens confirming the thread. That is harder to impeach.

By the time the Builder's Knowledge Garden, NatureMark, and future gardens are live, your subscription pays for access to the combined expertise of toxicologists, construction engineers, environmental scientists, and regulators—all speaking the same citation language, all cross-referencing each other's evidence, all subject to the same verification rigor.

The Closing Argument · Same Prompt, Two Outputs

One chatbot. One curated knowledge garden.

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The chatbot writes about toxicology. The TKG is toxicology. Generic LLMs are excellent prose engines. They are not source-of-truth systems. The TKG is a source-of-truth system with a working medical toxicologist's name on every claim. That's the difference between a draft and a deliverable, and it's the difference between an expert that survives Daubert and one that doesn't.