Document 3JqN7Z25neakXVDZZamjNnO7J

Castleman File: American Petroleum Institute w/c = with cover letter or memo If DATE = 0, undated CD-ROM Document #:API DATE ^ V"7> published article from medical journal published article from trade journal published advertisements newspaper article published government report government inspection results unpublished or internal report unpublished presentation from conference letter memorandum industry warning labels industry sales literature industry recommended practices meeting minutes (with attachments) membership list L. BC notes WILLIAM E!. BAGGETT ROBERT CT McCALL ROGER G . BURGESS LAW OFFICES BAGGETT, McCALL & BURGESS A PROFESSIONAL LAW CORPORATION 3006 COUNTRY CLUB ROAD 70605 P.O. DRAWER 7820 LAKE CHARLES, LOUISIANA 70606-7820 (318) 478-8888 FAX (318) 478-8946 July 30, 1991 WILLIAM BAGGETT, JR. REBECCA S. YOUNG ROBERT C. ARLEDGE Dr. Barry Castleman 1722 Linden Avenue Baltimore, Maryland 21217 RE: Shell Documents/ Bonsib Report Dear Dr. Castleman: Paul Henderson introduced us about a month ago while you were Beaumont testifying in one of his asbestos cases. You expressed an interest in some documents I told you about that Hershel Hobson recently obtained from Shell m some of our benzene cases. I believe we also talked about the 1948 API Toxicological review on Benzene. I have enclosed copies of these as well as a few similar documents you may be interested in seeing. I have also enclosed a copy of "Dust Producing Operations in the Production of Petroleum Products and Associated Activities." We have argued that what Standard Oil did to protect its employees is relevant to show what our clients' employers could reasonably have learned and done about asbestos as early as 1937. Of course, since employers are usually immune from tort liability, this document may not be helpful to plaintiffs in states other than Louisiana. In fact, evidence of employer knowledge could potentially be damaging to a plaintiff's product liability claim. Once you have a chance to review these materials, I'd really appreciate hearing wha4^you think about them. \ Yours truly, WBBjr/ct Ends. \ willj^m\. BA JR.