Document 5bgenKOeJrN2gLryookL9pyK8

KIRK HANSON WILLIAM A.tJRRAI4 A.LAURISTONARKS DAVID WHiTMAN MICHAEL r.WALLOR ROBERT DPARRILLO OENNISJ MCCARTEN JAMEST.MURPHY HANs0NCuRRAN PARKS CouNsELoRs AT LAW 1210 TURKS HEAD BUILDING PRovIDNcE.RHooE TSLAND 02903 August 21 1979 TELEpHoNE 421-2154 AREA CODE 401 CAM-395 Mr Donald Ferry Metropolitan Talc CompanyInc Box AM 18-22 Bank Street Sunxtit New iJry 07901 RE Westfall et al vs Whittaker Clark John Doe Corporation vs Metropolitan and Pfizer.Inc Our File 79356 Daniels Talc CompanyInc Dear Mr Ferry This will confirm my advice to your secretary that have been engaged by Aetna Casualty and Surety Company to defend the third-party action brought against your company in the above- entitled matter In your letter to the Fowler Agency you referred to documented study done by Professor Rubino If copy of this is available it would be appreciated if you would send copy to me Of course if there is any other materials dealing with the product particularly the component asbestos should have these also might add that have had an asbestosis case in the recent past In the course of that had occasion to read Paul Broduers book dealing with that particular problem FrOm past experience recognize that the most significant investigation will deal with your sources of supply i.e the producersand their respective locale In addition we would also want to know the history of your business relationship with the third-party plaintiff Whittaker Clark Daniels Upon receiving this assignment immediately went to the WtoorMkerrsWCeosmtfpaelnlssatciolnaimComTmheiyssiodon and obtained lhe rports relating encompass medical information pertaining to his ailment Copies have been furnished to Aetna Casualty If you feel you want copies and have not received same CAMC-Abeyta-002749 from the Company please advise furthe1 sOurce of helpful information you may have relates to other cases that may have involved the Company if you are aware of any .1 would like to know where they have been filed and who has protected the interests of Metropolitan Talc CompanyInc If this is an industry problem pre-trial discovery in other cases is often fertile sourceof information for the defense One of the defenses that will be raised is that Metropolitan Talc CompanyInc has no significant contact with the State of Rhode Island Of course do not know this at this stage and have nO familiarity with your business operations If you have salesmen or advertise in local papers or frequently ship goods into the State then.this may be sufficient to confer jurisdiction On the other hand if you have no business contact with the State and make all deliveries to third-parties in New Jersey or other states jurisdiction may pose problem to the plaintiff would like to hear further from you concerning this also Very truly yours William Curran WAC ner CC Aetna Casualty Surety Company CAMC-Abeyta-002750