Document DG3gLgeOrOnQmwY9G7YZLrOyd

SurtKN R. SHOWN Gary B. Chviwau LaWHEVCY r. 0A1T E. CRA10 OAUl Canbact C. Fterxsi* Lvcy T. Franc* OmuO' COOMUCW Gary L. Ckabam Maureen L. HaUGregory L. Haa*on William Evan Jonw Sherman v Loun Bkaslet J Luck Rowt C. Luxv Terry J. MacDonald Garlington, Lohn & Robinson, pllp -.1- Attorneys at Law 199 West Pine PO. Box 7909 Missoula, Montana 59807-7909 406-523-2500 TelETAX 406-523-2595 October 29, 1997 ^ jLlS&McNm. JOHN O. MUOD Antta Hamel Foe Shane N. Kuly Laoot E. Riley Susan p. Roy Robut E. Sheridan W. Dehnu Stamm. Puter J. Stowtap WUIAM T. Wacnek Kelly M Vou R.H. "TV* RowrooN orcouNMt, J.C Gamimcton 190S-ms Jon L- Heberling, Esq. McGARVEY, HEBERLING, SULLIVAN & McGARVEY 74S South Main KalispeU, MT 59901 RE: Libby Asbestos Cases Dear Jon: We have talked to Grace about your request to have Dr. Egilman review documents at the repository in Boston. That can be arranged, however, there are two fundamental points that need to be discussed. If Dr. Egilman is to review documents at Winthrop Square, he has to do so in some recognized capacity The usual and accepted capacity for someone who is neither a lawyer nor a paralegal is as an expert. As you know, Dr. Egilman has not been designated as an expert witness in any Libby case. We would appreciate receiving your designation of Dr. Egilman as an expert if you want him to review Grace's documents. Second, a review of documents is conducted pursuant to a document request, with rare exception. Please submit such a request. If die anticipated review is to be conducted pursuant to one or more existing requests, please identify them. We believe this is absolutely necessary to avoid, or at least to minimize, the possibility of future disagreements. This is particularly appropriate in this situation, where Dr. Egilman and his associates have spent many days at Grace's repository reviewing and copying thousands of documents. What documents can there be at Winthrop Square that he has not reviewed? If there are specific categories of documents that you want Dr. Egilman to review, please let me know. We will not get into a discussion with Dr. Egilman about this. We are more than willing to discuss it with you or Roger. /on KebeilVng, Esq. Rc: Libby Asbestos Cases October 29, 1997 Page 2 Once we get you request and your designation of Dr. Egilman as your expert, we will able to respond with particularity. Very truly yours, GARLINGTOK >HN & ROBINSON, PLLP GLG/ld Direct Linc/(406) 523-2543