Document BREnd0KjLvk0ryNDZj8n94gvw

BENJAMIN B TAYLOR CHARLES VERNON PORTER LAURANCE w . b r o o k s JAMES R. FULLER CHARLES W. PHILLtPS WILLIAM O. RANDOLPH BEN. B. TAYLOR. OR. ADA MOTT FRANK W. MIDDLETON.OR. ROBERT >J- VAN DAWORKER LAW OPriCES TAYIiOH,PORTER,BROOK8 & FULLER May 24, 1949 POST OFFICE BOX 2070 TELEPHONE 3-3AI1 Dr. Robert A. Kehoe, Director Kettering Laboratory of applied Physiology College of Medicine Eden and Bethesda Avenue Cincinnati, Ohio vs. Schuylkill Products Co., Inc. Dear Dr. Kehoe We have your letter of May 3, 19^9, and the letter from your secretary doted April 4, 194-9, and we understand that you expect to be in Baton Rouge shortly, probably during the first week of June. We would like very much to take your testimony in this case at that time in view of the fact that specimens of this man's blood and urine have already been examined by you. We will appreciate it if you will let ue know when you expect to be here so that we may make arrangements with opposing counsel for the taking of your deposition. We shall be glad to discuss with you informally at that time the questions raised in your last letter. Very truly yours. TAYLOR, PORTER, BROOKS & FULLER LW3:mm N9574 May 3, 1949 Mr* L* W. Brooks, Taylor, Porter, Brooks, and Puller, Louisiana National Bank Building, Baton Rouge 2, Louisiana. Bear Mr. Brooks: Reference to your letter of March 24 and my secretary's reply of April 4 will tell you that I had expected to he in Baton Rouge and to be of such assistance as I could in connection with your case of vs Schuylkill Products Company. It now appears most unlikely that I can be in Baton Rouge before the week in which June 1 occurs I am not wholly certain that I can make tills date, but that is my present tentative program. If this is not satisfactory for your purposes. I shall expect to hoar from you. I dare say you are fully aware of the fact that I am not. anxious to appear in connection with the controversies of this company and its employees. I shall lean over backwards, because of the position that I occupy in the courts there, not to show any evidence of the least bias or interest in defending this company, since in my opinion its practices in relation to its employees are utterly barbarian. Because I have not known how to do otherwise-.! have continued to authorise the analysis of an occasional sample sent to us. Frankly, I prefer not to have anything to dowith this situation since I cannot avoid the feeling that I am involved in a bit of medical connivance and sharpshooting in so doing. Very truly yours, RAK ef Robert A. Kehoe," K'" d T KB 0 i) 0 V b 8 3 N9574.01 April 4, 1949 Mr L. . Brooks, Taylor, Porter, Brooks and Puller, Louisiana National Bank Building, Baton Bouge 2, Louisiana. Dear Mr * Brooks t Dr. Kehoe has asked that I reply to your letter of March 24, advising that he will certainly he in Eaton Rouge at some time during the next sixty days and would prefer the examination in person. He will advise you of the date when it has hoen act, and will be available for your purposes. However, if you should need to make the examination prior to Ms anticipated trip, the means suggested in your letter will be quite satisfactory. Very truly yours. it 'H T 'Portlage, Secretary to Dr. Kehoe ef K? 0007364 N9574.02 r BENJAMIN B.TAVLOR CHARLES VERNON PORTER LAURANCE W. BROOKS JAMES R.fULLER CHARLES W. PH I LLI PS WILLIAM G. RANDOLPH SEN. 3. TAYLOR. UR. ADA MOTT PRANK W. MIDDLETON, JR. ROBERT O.VANOAWORKER L AW OFFICES Ta y l o r , Po r t e h , Br o o k s & Fu l i-e h LOUISIANA NATIONAL BANK BUILDING Ba t o n Ro u g e a,LouisiAXA March 2h, 19^9 POST OFFICE BOX 2070 TELEPHONE 3'3-4ll Dr, Robert A. Xehoe, Kettering Laboratory, Eden and Bothasda ."venue, Cincinnati, Ghio. Dear Br. Xehoo: vs, Schuylkill Products We have been ennloyec^fco defend a, workmen's compensation suit filed recently byagainst Schuylkill Products Co,, Inc, The plaintiff alleges that he is suffering from lead poisoning contracted while in the discharge of his duties as an employee of Schuylkill Products Co., Inc. Specifically he alleges the following: "While in the scope and performance of his regular duti-'s as s. cornon laborer, petitioner was 'working the "0" shift, that is, from 11:00 P.M. until 7:00 A.M., and was engaged in his regular work of burning, end was shoveling fuel into a burner when smoke, ashes, load and fumes from said burner were suddenly bloom forceably into his face, eyes, nose and mouth, causing him to inhale said smoke, ashes, fumes end lead and other content of said burner, and to be choked and strangled, and causing him to have to qy/it his work for a time." Dr. C, A. Loric of this City is the attending physician. lie submitted samples of Millie's trine and blood to you on several occasions and you examined and reported thereon. We would, therefore, like to take your deposition at a time convenient to yon. We are wondering whether or not you are planning to be In Baton Rouge any tine within the newt 30 or oO days. If 30, perhaps we can arrange to examine you when you are here. If not, we might have to take your deposition by interrogatories and cross-interrogatories. However, we would prefer to examine you in person 1.-0 ro CO as we believe that such an examination would be much more satisfactory to all concerned. _ LD With kind rorscnal regards, we are CO Q Yours very truly, N9574.03 W TAYLOR, PORTER, BROOKS & FULLER, iC LWB:LW -