Document ByNrVwYn3grGddzjwwJDaLynk
MTC 011589
COVER SHEET FOR B-LEVEL DOCUMENTS REMOVED IN PRIVILEGE REVIEW ORIGINAL B-LEVEL BOX NO.___________ PRODUCTION BOX NO._ F1X.E NC._ 3___________________________
FILE NAME ${\A4-pl ^_____________ _
MTC 011590
2/24/82
SHERMAN ASBESTOSIS MARIAN DOWNS AND DOROTHY
Review of Plaintiffs' Discovery Requests and Interrogatories
Downs only 6/20/79 7/18/79
Plaintiffs' Interrogatories to J-M International J-M's answers
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Downs and Gage 3/28/80
6/23/80 7/1/80
8/4/80
Plaintiffs' Request to Produce to J-M Corporation, Sales, Products, International, and Canadian J-M entities' answer (.objecting to each request) Plaintiffs' Motion to Compel Dis covery and for Sanctions (we do not have a copy! J-M's response to Plaintiffs' Motion
7/1/80 2/10/81
10/7/80 2/10/81
Plaintiffs' Request to Produce,0
J-M Affiliated Comparfpfes^: f * 'jj | Defendants' production/* v .;. i ;i y
2 v s'k *%J `w*
Plaintiffs' Request to Pr J-M Affiliated Companies Defendants' production
7/7/8Q
2/10/81 7/31/81
Plaintiffs' second set of Interro
gatories and Request for Production to all J-M Affiliated Companies Defendants' Answers (with 1,500
pages of documents) Defendants' Supplemental Answers
MTC 011591
MARIAN DOWNS AND DOROTHY GAGE
Review of Plaintiffs' Discovery Requests and Interrogatories
2/24/82
3/4/81 2/24/82
Defendant J-M Sales Interrogatories to Plaintiffs As of this date, neither Gage or Downs have answered J-M's Interro gatories
-2- MTC 011592
Re: Donald M. Russell
M-81-96-CA }
MH7 ll>
SUMMARY OF PERSONAL AND MEDICAL RECORDS FROM JOHNS-MANVILLE DENISON PLANT
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PERSONNEL
J-M Employment - October 26, 1970, to May 2, 1980; reason - another job. He was earning $5.62 per hour at separation. His evaluation at that time - quality was good; quantity was good; attitude was good; attendance was very good.
Previous Employments
August 1957 to June 1962 - Manager of H. L. Green Building, Dallas, Texas, for the McCrory Corporation, earning $400.00 per month plds bonus.
November 1962 to September 1967 - Personnel work for Johnson & Johnson, Sherman, Texas, earning $114.00 per week.
October 1967 to November 1968 - Long distance truck driver for Frozen Food Express, Dallas, Texas, earning $132.50 per week.
November 1968 to November 1969 - High-temp furnace operator for Texas Instruments, earning $2.25 per hour.
November 1969 to May 1970 - Drill, press and auto coning machine oper ator for Falls Machine Co., Akron, Ohio, earning $2.10 per hour.
May 1970 to September 1970 - Shipping department and electric plating Machine operator for Johnson Steel & Wire, Akron, Ohio, earning $2.79 per hour.
MEDICAL
Health Progress Notes
3/8/74 - surgery on left wrist for cyst removal by family doctor, Dr. Baur; missed 2-1/2 weeks from work.
7/28/75 - surgical repair of left inguinal hernia by family doctor. Dr. 0. T. Baur. Missed 2 weeks from work.
ANNUAL PHYSICAL EXAMINATIONS
|T|IT)8|1I| I"/f& JT"
November 1979 - FYC 88Z; FEVi Jkz
xrCayr within 'normal limits;
sputum cytology negative; BP 114/709 ltmgSj normals, has sool$ed5^ pack of
cigarettes per day for the last 20 yearsg walgjtt 127. . On, the questionnaire he stated that he had a sore throat, heagt igi^ir, nujyjb&j^, and sleeping
difficulties; he has worn a respirator a
He worked In
the plastic Industry for 1 year.
MTC 011593
EMPLOYER'S REPORT OF INJURY December 1970 for a crush injury and laceration to the right 4th and
5th fingers.
MTC 011594
o /3-IHM7
CASE STATUS REPORT
Donald M. Russell M-81-96-CA J-M NO. 13-11147
Plaintiff was employed at the Johns-Manvilie Denison plant from October 26, 1970, to May 2, 1980, which is when he is claiming asbestos exposure. We have not received Plaintiff's answers to interrogatories. His deposition was scheduled for May 1982, but was cancelled. It will be rescheduled for sometime during September through November 1982* A copy of the summary of Plain tiff's personnel and medical plant records is attached. An attorney record service is in the process of sub poenaing medical records.
(7/1/82)
J-M 83
MTC 011595