Document ExwKr5VYJE142Zvo9YZw1EMqb

October IS, l?b9 Hr* Edison. A* Picklesimer Claims Manager Liberty Mutual Insurance Cospaay Liberty ffutual Building 21*0 South Harrison Street East Orange, Jersy U70W REDACT ED 184 C32WA7277 Bear Picklasimer: Recently Mr, Michael Hosier of your staff forwarded to Hr, DeOastro, Personnel Manager of our Hewark Plant, a set of Interrogatories issued in connection with the above captioned claim. It will be a function of this Department to ooijplete and return to yon, the Interrogatories, We are endeavoring at the present time to complete each of the questions to the best of our knowledge. One of the questions recited requests the name and address of each co-worker and immediate supervisor with respect to the departments in which the claimant worked. Since the claimant was a "long-service" employee and normal turnover in some of the departments in which be worked were quite substantial, the task involved represents virtually weeks of going through files, nevertheless, we are making an attempt to go through our current records and obtain as much of a list m m can beginning with the most recent dates and working Of sure concern to us are the questions relating to the materials handled br the claimant and the chemical composition of This is probably an impossible burden, We've talked to our lab people and they have simply thrown their hands up in frustration. The claimant worked in the Receiving and Stores Department for the greatest period of his employment and there fore handled everything that has gone into the manufacturing of paint from X9k9 to 196? To ask us to list all of the materials and their chemical composition would require a man working full time on this particular question for the nest 8 or 9 years. We*re not even sure we can resurrect records dating back that far. lour guidance on this point would N40488 therefore he appreciated,