Document 93Ze9ZQO2EaoKaaGMpKpK8JwD

A be L.Eobeets . A r r o E d E T a .t L a w C O M M E R C E TITUE B UIUDING / PHONES 0 -0 5 5 7 -0 -0 5 5 . Me m p h i s , Te n n . . August 12, 1937 V"' Dr Hob ft'-'A'A Keho e College of Medicine, Cincinnati, Ohio. Dear Doctor We have been referred to you by the American ` Public Health Association, Reginald LI. Atwater, M. D. , Executive Secretary, relative ,to getting some information ..... as 'to working conditions creating -lead poisoning, in . ,,/. plants for the manufacture or mixing of paint wherein ' ; insufficient ventilation -and insufficient safety standards would be present, and assist in creating said conditions. .As you perhapps may be aware, Tennessee does not have any specific law protecting employees on Occupational . Diseases, neither does it have.any particular Statute pro- , tecting employees relative to plant or industrial oonditions. connected with lead or paint industries. '~ . .We have a particular case here which we represent ' a plaintiff, wherein it is nedessary to have a series of . depositions'-answered by''an exper.t', such as yourself, to know. . the usual and necessary precautions in plants which manufac ture paint or use products of lead, so as to show the required safety.standard which would have to be had in the ordinary uses of'operation of said .business, to protect the n lives and the health; of employees. . -' 'As such experts are not present in this part .of the country, or khown in or about Memphis, and as we have been referred to; you .by/the American Public. :Health Association relative:to such standards, we would highly appreciate if it is possible t h a t 'you could arrange, to answer a series of such depositions in the presence p'f a Notary Public, and we assure you that this would take.-a relatively short space of time in said matter. .-h.Hf/A/ g--:' - I"C 0002257 ,; ;. OOr2?58