Document JroX8O9y59mRLw3MVBoqaEq6Z

RALPH ELLIOTT RAYBUR N M. N A L L RO BERT ESSlN LAW OFFICES ELLIOTT & NALL 213 NORTH TRAVIS STREET Sh e r ma n , T e x a s 7 5 0 9 0 March 8, 1971 TELEPHONE; 093-8177 (AREA CODE 21A) REFER TO OUR FILE: Dr. Robert A. Kehoe Kettering Laboratories College of Medicine Eden Avenue Cincinnati, Ohio Dear Dr. Kehoe: Thank you for your kindness to me on the phone. I enclose herewith a copy of Plaintiffs' Amended Complaint to give you an approach to what plaintiffs' claims are. Also enclosed find a report of the Pollution Research and Control of jgtack emissions. Also find the report of Dr. S. J. Norton of North Texas University who is probably a chemist. Accompanying his report, you will find a plat. I have penciled in the Town of Frisco above the Newman property. From the Gould plant to the Newman home is probably a half mile. The prevailing wind generally has been from the southwest. Our real estate appraisers unanimously refute the report of Mr. Boyd who was employed with Mr. Newman. I enclose Mr. Boyd's report. We indeed have offers made to Mr. Newman for purchase of his property at that which Mr. Boyd appraised it and he has refused it. So you can see that he does not really feel that there has been a depreciation. However, the great impact on the public consciousness of lead and pollution and the en vironment we feel will be bad for us before any jury. We will need someone who is an acknowledged authority in the field who can testify as to the natural lead content of soil and of the human body, its dissemination and discharge. These are matters we would have great difficulty proving locally, although I suppose I could find a doctor somewhere in the Dallas area. We greatly distrust the complaint of Mr. Newman because we are constantly checked by the City of Frisco and its Mayor and Mr. N5335 Dr. Robert A. Kehoe Page Two March 8, 1971 Newman has made complaints of odors and noise at times when our plant was shut down. The roadway you see to the east of Newman's property and the Gould plant is a hard surface country road and the traffic would not be excessive. Frisco railroad runs to the west of Newman's property and a spur comes in between it and the Gould property but I do not believe this ;.is excessively used. If after reviewing this situation you have any suggestions or feel that there are points that could be developed, I would certainly like to call on you as a witness and follow such sugges tions as you have. Everywhere I have checked you have been regarded as preeminent in this field long before lead really became a big problem in the public mind. Very truly yours ELLIOTT & NALL RE :cw Enclosures