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December 6, 1978 Mr. Bill Smith Liberty Mutual Insurance 3000 West Kellogg Drive Wichita, KS 67313 REDACTED vs. The Sherwin-Williams Co. Claim No. C979-30171 NOD Dear Bills As promised, I am enclosing a copy of a letter of November 22, 1978, to Mr. Lively from our Mr. Sarvadi. I had a conversation this morning with Milt Unruh of our Coffeyville plant. He attended the hearing on Friday regarding this claim. As you may be aware, two of our employees were subpoenaed to testify at that plant on behalf of the claimant. In addition there was a demand that we present additional records at that hearing. That prompted my phone call to you last week. I believe we are in agreement that the claimant and her attorney have had substantial opportunity to obtain evidence to support her claim, at the expense of Sherwin-Williams and management at its Coffeyville plant. In addition, they were successful in having Mr. Sarvadi testify at a prior hearing. From our view point, it is difficult to see where all of this "fishing" may be taking us. As I indicated to you before, this appears to be nothing more than the claimant saying that she is ill and, for lack of any obvious reason, her illness must have occurred at work. She has a condition and is seeking a cause, preferably at our expense. According to Mr. Unruh's report to date, Mr. Lively is now preparing our defense in this claim. We are encouraged by this development, and we hope that it leads to a situation where the facts which have been developed may be given an objective hearing by the referee. It seems obvious to us, that and her attorney were on a prolonged fishing expedition in order to buttress her claim. REDACTED (continued) N40384 0007-SWP-005 806218 CONFIDENTIAL Page 2 REDACTED Res vs. The Sherwin--Williams Co. I trust that you will send reports back on future developments in this claim. Please let me know if we can be of any further assis tance to you or Mr. Lively in the defense of this case. Yours very truly, THE SHERWIN-WILLIAMS COMPANY JDK/ew Enc. J. D. KULL, Jr. Corporate Director of Insurance 0007-SWP-005 806219 CONFIDENTIAL