Document 4k4rqGmjxd1q3Xr8R11m8x5G

REDACTED t iP ^ fk VU LIBERTY MUTUAL 2 Executive Campus, P.Oy^ox S}43, Cherry Hill, New Jersey 08002 Tel. (6(l)^63-9i2i February 12, 1980 FEB I i 1330 Sherwin Williams Company 101 Prospect Avenupf, N.W. Cleveland, OH 44] T. M. L, ATTN: THOMAS /OCKER, WC ADMINISl RATOR RE: FILE: HD327-6227(8) D/LOSS: 12/1/75 VS LIBERTY MUTUAL FEBU 1980 awe? Dear Mr. Locker: This letter is a follow up to our telephone conversation of October 30, 1979. At that time, we discussed several items concerning the above captioned matter. Further, you had asked that I submit a list of specific questions for you to answer. Therefore, I would ask that you respond to the following questions: 1. What does John Lucas Company, Incorporated, produce? What are their raw materials? 2. Could you supply us with whatever information you have on plaintiffs concerning their employment. Could you supply us with documentation and verification of John Lucas' corporate history, documents, etc? 3. Could you supply us with material safety data sheets on all materials received at John Lucas? 4. Could we find out how shipments are received: for instance, by rail, truck, ship, etc.? 5. Could you identify the names of the people in charge of John Lucas Company, Incorporated? 6. Specifically, could you identify the Safety Director? 7. What kind of first aid facility was present at John Lucas? 8. If OSHA records were kept at Lucas, could these records be made available to us? 9. Could you supply us with first aid records for John Lucas? REDACTED N40368 LIBERTY MUTUAL INSURANCE COMPANY LIBERTY MUTUAL FIRE INSURANCE COMPANY LIBERTY LIFE ASSURANCE COMPANY OF BOSTON HOME OFFICES: BOSTON EQUAL OPPORTUNITY EMPLOYERS