Document 6woKqQV6X4QQv6QGgL5VRxpB4
RAYMOND W. HACKBARTH ROBERT B. MCCORMICK JAY W. WASON JOHN E- MORRISSEY. JR. CHARLES ANDREWS ROBERT H. WOODFORD JOHN F. LAWTON THOMAS F. QUINLAN CHARLES J. CRONIN JAMES H. O'CONNOR WILLIS S- LEMON CARTER H. STRICKLAND** DENNIS R. BALDWIN CAY M. POMEROY* KEVIN M. REILLY EDWARD J. MOSES GEORGE R- WOLFF CLAYTON H. HALE. JR. ALFRED W. POPKESS KENNETH E. ACKERMAN
Ma c k e n z ie Smit h Le w is Mic h e il & Hu g h es
LAW OFFICES
ARTHUR A. CHALENSKI. JR. CATHERINE A. GALE
ARTHUR W. WENTLA.NDT MICHAEL P. DALY
NANCY L. PONTIUS EDWARD J. SPENCER. Ill CHARLENE E. MC GRAW
* ALSO ADMITTED TO FLORIDA BAR
-A#ALSO A0MITTSD TO D C. BAR
600 ONONDAGA SAVINGS BANK BIXLDING SYRACUSE. NEW YORK 13202-1399 (315) 474-7571 TELECOPIER <3151 474-7571
RECEIVED
0C 2 0 mz
Corp., RisdMgmL
EDMUND H. LEWIS 1604-1972
JOHN H. HUGHES 1904-1972
EDWARD J. SPENCER. JR. 1917-1981
FRANCIS P. MALONEY WILLIAM L. BROAD
CARLETON E. REiFFENSTEIN GEORGE S. SULLIVAN WILLIS A. BROWN T. FRANK DOLAN. JR. ROBERT J. GANG. JR. COUNSEL
December 17, 1982
Mr. Thomas M. Locker Administrator of Workers' Sherwin-Williams Company 101 Prospect Avenue, N.W. Cleveland, Ohio 44115
Compensation
r edac t ed
Re:
v. New Primex Realty
Associates v. The Sherwin-Williams Company
Dear Mr.'Locker:
In response to your November 1, 1982 correspondence and docu mentation, I have a few additional requests.
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First of all, it is of the utmost importance that we locate personnel file, since part of our defense will be
that even if there were cancer-causing materials in the Sherwin-
Williams product as a contaminant or otherwise, nevertheless, her
exposure to the product was of such a passing nature and of such
short duration as to not be causative of her leukemia condition.
Of special interest would be any pre-employment physical, any
history of health problems she may have had during her period of
employment, the number of days per week she worked and the number
of hours per day she worked. If you do not have this at your
national offices, perhaps something could be located in your
Syracuse division.
At your response to my question at number 6, you indicated
that benzene was not present in your paints at the time
REDACTE
worked at your store. However, a testing done at your new location
in May of 1979 indicated that there were traces of benzene present
in the atmosphere. Would you kindly explain this further. For
instance, did Sherwin-Williams use benzene as a thinner or in com
bination with any process it may have had as a preservative, etc.
N40512
00J'-$WP-05501578