Document BRmN787bMwgQbGXE5Rv8DyyKm

MEMO TO: File DATE: March 22, 1982 FROM: James L. Brooks SUBJECT: Sherwin-Williams A-0422 D/t: 01-30-81 82 OD 0034 REDACTED On March 11, 1982, Rick Baum called indicating he was to appear at the Industrial Commission on March 12, 1982, for discovery purposes and wanted someone from our office available if need be. We were not needed. In our discussion, Rick and I did not feel optimistic about our chances of prevailing in this case. This was further confirmed through conversations with Lita on March 12, 1982, who indicated the new building had been sprayed with fireproofing containing fibers. Lita called later and related that the pipes were insulated with asbestos. On March 15, 1982, Dr. Van Orstrand called me on this case. The gist of our conversation is included in the attached letter of March 17, 1982. He in essence felt we had a difficult case to defend. On March 16, 1982, I called Rick, Lita, and Tom and gave them some preliminary figures on the possible costs of the case (see attached). In the interim, I had called Wausau Insurance Co's for the cost of an annuity and they will call me back March 22, 1982. My thinking on the annuity is to have an alternative to a large outlay of cash should we attempt settlement of the case. Rick is attempting to set up a meeting with petitioner's attorney the week of March 22, 1982, to determine which direction petitioner's attorney is going with the case. I asked Tom Locker to obtain a price on an annuity if he could. On March 19, 1982, Tom called stating we should have a price on an annuity either March 22, 1982 or March 23, 1982. All of the above has been relayed to all parties. cdr cc: L. Scharnhorst T. Locker ^ R. Baum *MRS4,S8i? 0007-SWP-005802505