Document Ev8bJ1orz184oGZpdBkn2ZRgx

Topic 1 W. R. Grace 1 Depositions 1 Lovick 1 Montana depo 1 follow up with Tom Baiz, other Montana lawyers. 1 Thomas A. Baiz, P.O. Box 1828, Great Falls, MT 59403 (406) 727-7113 2 Thomas A. Kragh, 410 1st St. East, Polson, MT 69860 2 Al Stewart depo of Lovick 1 admits to knowing many people died of mesothelioma and lung cancer and they all worked at Libby mine 2 tries to differentiate between work in dry mill and wet mill 3 dry mill and wet mill operated simultaneously. I.e., the wet mill did not function as a replacement for the dry mill. 4 will not admit that he thinks asbestos is a health hazard. 2 Junker depo 1 Texas depo - can't warn blacks or they won't come to work 2 Weinstein depo - can't warn niggers or they won't come to work. 3 Martin Dyes - video depo of Junker. 3 Murphy the Elder 1 Speights/Miller depo of Murphy 1 refers to 5 or 6 indices 2 8000 boxes of docs,reduced to 2000 now reduced to 500. 2 needs be be redeposed, probably serially. 1 pin down details of documents, numbering system at various times, 2 rules for inclusion and exclusion 1 CPD vs. non-CPD documents. Topic 3 dates various acts and decisions made regarding documents. 4 from what locations were documents gathered 1 Libby? 2 S. Carolina 3 Cambridge? 4 Research Center? 5 Overseas 6 Libraries? 5 "Privilege" issues 6 Empty file folders. 7 Indexes, including computer index 1 who created and when 2 purpose for which indexes used. 8 microfilm story 1 Greitzer and Locks letter and invoice. 2 how many rolls 3 what is on the microfilm 4 who did the transfer 5 index of microfilm documents. 9 Miller found 500 boxes in Cambridge "penthouse." 10 Approx 50 boxes regarding work comp. 4 Rosenberg 1 Alaska depo re: Otto 2 Redepose on Otto? 3 Will he open up on "reforumlation" if shown Ambros dirty story? Topic 5 Arthur D. Little 1 Check firstwithSpeights 1 question is, do we really want this info? 2 Mike Thorton to be approached. 3 produce all studies, reports, correspondence to and from WRGrace, 6 Brown 1 WRGrace research 2 General Discovery/deps/interrogs 1 Insurance Personel 1 internal risk management people re: comp claims 1 Gladys Christ claim from Texas 2 European and Australian subsidiary people 1 need interrogs and doc production to further identify people, places and subjects. 3 Washington Research personnel. 1 Columbia, Maryland 4 National Medical Division 1 Dialysis labs and equipment. 2 asbestos filters 3 Louisianna case - argument re: venue somewhere else because there were so many National Med labs in other places. 5 Davison Chemical Division 1 subpoena duces tecum - docs re: asbe 1 asbestos in plants - pipefitters, insulators, maintenance personel 2 labelling of chemicals 3 MCA labelling knowledge and info. Topic 4 warning employees re: dangerous chemcials. 2 IHF membership and documents 3 Holly Huart 1 local counsel letter says Davison Chem docs destroyed 2 Al Stewart follow up. 6 USG and NG vermiculite use 1 Gypsum board. 2 invoices and sales documents 1 WRG 2 USG and NG 3 Quantities used. 4 Source of vermiculite. 7 Schundler story 1 Schundler bought by Manville in mid 1960s and still owned by Shuller 2 Manville depository docs? 3 WRG invoices re vermiculite sold to Schundler. 8 Removal of attic insulation from market but not MK. 9 Libby Montana 1 discover documents in Libby 2 go thru Montana Dept Health Files 3 Check with Tom Baiz in Helena. 3 Documents 1 W. E. Smith - Rob check NMLRP W. E. Smith boxes. 1 Rob check NMLRP W. E. Smith boxes. 2 all reports etc to and from WRG Topic 2 J. C. McDonald 1 raw data 2 all reports etc to and from WRG 3 Otto Ambros 1 German comp claims 2 Edgewood documents 1 Tom Crumpler. 4 OSHA/EPA 1 submissions re: complaining about change in PEL 2 submissions re: tremolite inclusion in regs. 3 Rob - EPA fined WRG $500,000. for violations in destroying buildings at Libby mine with first doing abatement - WRG employees ignorant about need to perform abatement. 5 Empty tile folders 1 see, Murphy the Elder and the doc depository 6 Privileged docs. 1 see, Murphy the Elder 7 WRG libraries 1 research division 2 National Medical division. 3 Cambridge 4 Libby 5 expanding plants 4 Longo misc 1 Tremolite settles to bottom of bag 2 videos of friability tests Topic 3 "Cementitious"is misleading 1 there is no cement in MK 2 it is like dried mud - is subject to abrasion and becoming airborn by relatively light hand rubbing - petting the dog. 4 MK compared to U.S. Mineral 1 has tested both and can't say one is more friable than the other. 5 Microvac technique 1 now an accepted ASTM standard. 6 R.J. Lee 1 testifies that product is not MK 2a mystery product, with, therefore no UL rating, no code approval somehow specified for a multistory building by an architect/engineer of mysterious stupidity. 7 Longo Adv. 1 defuse on direct. 8 WRG use of Longo 1 called Longo to testify in sol case about how bad product was and therefore plaintiff should have known of problems. 2 Trisek case (sp) California, Ken McClain n counsel. 9 T & N docs re: testing of MK 10 Purpose of asb in MK 1 1958-1960, no asbestos 2 1960 - , asbestos 3 - now, no asbestos. 4 I.e., asbestos not necessary to product, and WRG knew that before they put asbestos in MK. 11 Cement products the same as MK 1 Zonolite Hi temp cement Topic 2 Zonolite Finishing cement 12 Longo has bags and photos of MK 3 from Embarcadero Center, San Fran, 1972-73. 1 no warnings. 13