Document 919yeozpk9VqEV7QDBRa4BYN6

FILE NAME Corning OC DATE 1981 DOC OC457 DOCUMENT DESCRIPTION Legal - Excerpt of Deposition of Lawrence Kimble with Cover Letter FRANK T ABRAHAM C. W. W. WATKINS P. C. NICK C. NICHOLS P. C ROBERT E. P BALLARD C. DALE FRIEND C ROCKNE W. ONSTAD P. C. JOHN R. LEACH IID GRANT KAISER CRAIG D. BALL REID WILLIAMSON C. JANE FRASER R DAN FONTAINE LAW OFFICES ABRAHAM WATKINS NICHOLS BALLARD ONSTAD & FRIEND A PARTNERSHIP OF PROFESSIONAL CORPORATIONS 800 COMMERCE STREET HOUSTHOONUSTON TEXAS 77002 713 222-720 June 25 1985 BERT H. TUNKS THURMAN M. GUPTON COUNSEL TO THE FIRM W. JAMES KRONZER ASSOCIATED COUNSEL Dr. Barry Castleman 1722 Linden Ave. Baltimore Maryland 21217 N. PLAINTIFF'S EXHIBIT Bayone 3949 Dear Barry I certainly appreciate the hospitality you extended to Larry and myself when we were in Baltimore Your assistance has proven to be and will continue to be very helpful I talked with Bert Danziger from Los Angeles and he indicated you were curious about what happened to the Saranac documents that Illinois had concerning kaylo On February 11 1981 in cause number 80-0180AP in the United States District Court for the District of Maine Lawrence Kimble v Manville Corporation et al the deposition of Willis Hazard was taken On page 49 of his deposition the following question and answer appeared Question And when the kaylo division was sold to OwensCorning what happened to your file Answer The last day that they were part of Illinois we got some corrugated paper cartons unloaded our file cabinet called the janitt he o enr d the afternoon and Corning had them carried over Owens Se ee I am sending you copies of pages 49 and 50 of the deposition Should you require anything else please let me know Very truly yours REB Enlosures cc Mr. Lawrence Madeksho ROBERT For E. BALLARD the Firm w 49 a Now you are familiar with the fact that the Kaylo Division was sold to Corning in May of 1958 A Yes sir a And you knew about that during the time that the sale was being consummated and the transfer occurred occurred A I don't remember when I knew it 1958 stands out when the final thing was accomplished Did you at any time tell anybody from Owens- Corning about the Saranac study dealing with Kaylo A I don't remember t Q Do you remember if there was someone who you ! would consider a counterpart at Corning someone that you may have dealt with or discussed industrial ! hygiene problems at Corning A ! At what period During 1958 A I don't remember that dealing Did you maintain a file _ with the Saranac study the letters from Dr. Vorwald and the reports A. Yes Q And when the Kaylo Division sold to Owens- Corning what happened to your file van LE C) 50 part A The last day that they were of Owens- cartons unloaded Illinois we got some corrugated paper our file cabinet called the janitor at the end of the Corning afternoon and had them carried over to Q Is this as a result of some instruction or memorandum or directive generally to transfer documents i dealing with Kaylo to Corning A I don't remember whether it was or not I know we did that | Q You did . do it A. Yes . Q | also And in addition to your files were other turned over to Corning at that time MR KELLEY Object files A Q . Yes other files were turned over to OwensWhat Corning that you know of A I don't know what they wereI don't know what Q files went over I know ours did And that would include the documents that have been marked today I don't know whether all of those documents A were in that file or not but we sent over material Lod / : ;