Document ExX90NaDjw7NN0gMmpK4yry1n

FILE NAME: Asbestos in Hair Dryers (HD) DATE: DOC#: HD0 OCUMENT DESCRIPTION: ZZ&ZZZZ/,& WZKh^Z THOMAS W. HENDERSON THEODORE GOLDBERG JOEL PERSKY ANTONIO D. PYLE ROBERT l. JENNINGS, JR. THOMAS W. WHITE ROBERT ALAN KREBS HENDERSON & GOLDBERG, P.C. ATTORNEYS AT LAW 1612 FRICK BUILDING PITISBUROH, PENNSYLVANIA 15219 (412) 471-3980 July 3, 1986 Barry Castleman, Ph.D. 1722 Linden Avenue Baltimore, MD 21217 RE: Industrial Hygie~e Foundation Dear Dr. Castleman: Please find enclosed a copy of the former membership registration cards of the Industrial Hygiene Foundation, as well as a Protective Order entered by the U.S. District Court for the Western District of Pennsylvania which governs the conditions of possible dissemination of these documents. As we have discussed in the past, it is my opinion that the present Protective Order precludes publishing the list in a book or magazine for public use, but nothing prevents dissemination of the list to other attorneys involved in litigation so long as the Protective Order accompanies the documents. These documents are being sent to you at this time for your review and analysis in connection with your work as an expert witness with our office in various asbestos and silica-related product liability lawsuits. I believe that the Protective Order is clear that these documents may be used by you or other attorneys in connection with other forms of litigation so long as the protective order accompanies the documents and no use is made of the documents for purposes other than litigation, such as anti-competitive efforts by competing industrial hygiene companies to exploit former members of the IHF. It is my understanding that you are willing to abide by the terms of the Protective Order until modified by the court. RWJr:kjk Enclosures ; 'I"" I I I I I I I I I I I I I I I I I I PYRO METAL FINISHERS, INC. PYRENE MFG. CO. 10' EMPIRE ST. , NEWARK 12, NJ JOINED: 5/16/41 RESIGNED: 12/3/56 L. E. ECKELMANN, PRES. RALPH BATCH, VP-PYRENE-C-O-TWO DIV. PULLMAN STANDARD P. O. Box 71 Butler, Pa. 16001 Joined: 1/1940 Resigned: Joined: 7/73 Resigned: 6/79 7/1965 Richard S. Jones. General Mgr. PROCTOR & GAMBLE CO. IVORYDALE TECHNICAL CENTER CINCINNATI. OHIO 45217 JOINED: 10/19/37 RESIGNED: 9/7/65 R. J. BEA1'-1AN, IJ\'1)l1STRIAL HYGIENiST i" 132 - INFORTHETHEDISWTERSTICERTN CaDVI.~RTTRIOCFT THOEF PUENNITNESDYLVSTAANTIAES IN RE: ASBESTOS LITIGATION Miscellaneous No. 8482 CONCSEURPNPINLEGMEINNDTAULSTPRRIAOLTEHCETAIVLETHORFODEURNDOAFTIOCONU, RTINC. / ) r?:z. , AND NOW, this . /" day of March, 1986" upon motion (the i' "Motion") by INDUSTRIAL HEALTH FOUNDATION, INC. (the "IHF"), and its President, DANIEL C. BRAUN, M.D. (".Dr. Braun"), pursuant to Rules 26 and 45 of the Federal Rules of Civil Procedure, 28 U.S.C.A. (the "Rules"), and to Local Rule 4, the IHF having asserted that the Index Cards referred to in Paragraph Two of its Motion contain sensitive, proprietary information and that some of the information contained therein is not relevant to the asbestos litigation identified at the above Miscellaneous Number (the "Asbestos Li tigation"), and the Court subsequentl y deter- mining that all the information contained therein is relevant in the Asbestos Litigation but that the IHF is entitled to an appropriate Protective Order to prevent undue dissemination ot this information, IT IS HEREBY ORDERED: 14 THAT the IHF shall make available to counsel for various plaintiffs, as well as to legal counsel i~ Pittsburgh for any of the defendants (either original or third party) named in the ~JCIIlI!",;;.".a_IliJl!IIIZ!!ll!QMJlli!lllJ4iZI!IIIIIIlIW6i"""'."'P""N_,",,-4"",_""- - - - .. Asbestos Litigation (hereinaf Pittsburgh Asbestos Litig ter collectively referred to as the Index Cards (the ation Counsel-) copies of any or the May 17, 198 Index Cards) identified as Exh all of 5 deposition cf Dr. Braun. ibit THREE to In dupl i ca t ion requesting burdens, any Pittsburgh immediate copies of Asbestos order to minimize Li t igat ion Counse 1 direct their request, in w any of the Index Cards shall Dr. Braun at the IHF ritten form on counsel's letterhea within thirty (30) days from d, to . IOnrddeexr. C The letter shall indicate the number entry of this quested ards requested or which and the party or parties individual of complete sets of Index Cards are re- 2. THAT the Index which said counsel represents. retained in the ac Cards reproduced by the IHF s tual custody of the Pittsburgh hall be agsation Counsel which requested copies of Asbestos Liti- provided in paragraph THREE here 3. THAT the Index Card in. the Index Cards, except therein) may not be div s (or any information contain will be obtaining ulged or disseminated by Counse ed 'connection the Index Cards from the l which -- in th with litigation proceedings, suc rHF except in . - :..~~, ~ _~r e United States of America h as to other counsel .. ~.-... litigation lawsuits or claim who are involved in asbestos ' .~"-. in the America various or any courts o s now pendin~ or which may be and/or agencies of the Uni ted pending production f its states, pursuant to of documents or written interro g formal States of requests for request on counsel's letterhead atories, or to written as to proceedings referr~d in lieu of said formal requQst.s( to in this paragraph.  -- 4. A copy of this Protective Order shall accompany production or other dissemination of the Index Cards with any to matters referred to in paragraph THREE. respect S. The IHF shall be reimbursed fifty cents ($0.50) for copying each of the Index Cards, which are a page Pittsburgh Asbestos Litigation Counsel. reqcested by 6. th Should counsel for the plaintiffs or defendant.s notic e deposition of Dr. Braun on matters directly relating e Index Cards, or as reimburse the IHF to other IHF matters, said the total sum of Three to the counsel shall ($300.00) for the time spent by Dr. Hundred Dollars documents for the deposition Braun in revie""ing the itself, as well as for any and for the actual deposition Dr. Braun. 'desired pre-deposition conference with . 7. THAT the District Court of the Uni ted States for Western District of Pennsylvania will retain jurisdictio all matters relating to this Protective Order. n ", / / ~"~P~~,'f the over United States District Judge