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. REDACTED 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