Document 0JDzjabRaRR0qpv0D2nmp82Dx

ludlMj, ATTORNEYS AT LAW NATIONAL CITY BANK BUILDING CLEVELAND, OHIO 44114 TELEPHONE (216) 241-3141 $s IitiflngaiiwtP April 25, 1977 Mr. Jack D. Kull, Jr. Staff Assistant Corporate Insurance Department Sherwin-Williams Company 101 Prospect Avenue, N.W. Cleveland, Ohio 44113 LOUIS S. BELKIN (I9IO-I97S) JOSEPH H. CROWLEY OF COUNSEL WALTER C KELLEY DONALO B. MCCANN FRED J. LIVINGSTONE JEFFREY A. BELKIN ROBERT L. STARKS WALTER J. LASKA STEPHEN M. O'BRYAN THOMAS C. LIBER AUBREY B. WILLACY MICHAEL L. GORDON MARGARET A. FOSTER STEVEN N. BULLOCH JUDITH HARRIS R AW SON Re: First Quarter 1977 Statement Dear Mr. Kull: Enclosed please find our statement of fees and expenses attributable to various active Workers' Compensation matters. By way of a brief status report, I offer the following comments: In the lase, now in the Court of Common Pleas, we are in the process of completing our preliminary discovery. A court order authorizing us to obtain copies of Mj medical records has been obtained. Certified copies thereof have been mailed to claimant's physicians and the hospitals wherein he was treated. Some have responded, others have not. I anticipate that a deposition of the claimant will be necessary. Thus far, it appears that the right side hernia was simply a recurrence of prior hernias in the same area. The left side hernia, however, seems to have been a new one and, therefore, may pose a more serious fact-question for the jury. I doubt whether this case can be disposed of by a motion. Settlement discussions may be in order when our discovery has been completed. TJae__ ..:.imttex,,,yrLLl,,.^ ..the Commission. At present, however, we have established an "iron-clad" jurisdictional defense. I therefore doubt that the Commission will allow this claim upon such appeal. As the file now stands, an allowance would constitute a clear and gross abuse of discretion. REDACTED r ec eiv ed N40120 APR 2 8 ;3?7 CORPORATE INSURANCE