Document KzG5jYVebxkp5RY60VXE9qDx0
August 14, 1968
George W. Wright, M. D. Head, Medical Research Department Salat Luke's Hospital 11311 Shaker Boulevard Cleveland, Ohio 44104
Dear George:
I am sending you a copy of a memorandum that ms written for me by Dick Standel of our office. I have gone over this in detail with Clint Burnett and he is very much in favor of this program. He suggested that 1 talk with you about the possibility of your availability in connection with at least this one case. Of course, he was somewhat dubious but thought that it was a matter that should be thought out. We are proceeding to try to organize the Defense Task Force.
If you plan to be in New York in the near future, X should be happy to discuss this with you. If not, would you be good enough to call Dick Standel in my office and discuss this with him. He is very well informed on the subject and is carrying the ball for me in the Task Force planning.
I am
With kind regards to you and Mrs. Wright,
Sincerely,
HMB:LH Fnc.
MT-002759
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(3) A person with extensive knowledge of control efforts of ibis company and o generally with fedpeet to this hazard
At the present time C. L. Sheekler would appear to be our overall asbestosis expert. It is imperative that he be available for educa tional (and possibly testimonial) purposes. If his function in the task force is to be adequately performed his responsibility in that area must be assigned first priority.
(4) A person from our Insulation Division who possesses know
ledge of the asbestos insulation industry and of'our
insulation product lines, including the general chemical
make-up of such product's.
*1
R. A. Stapleton would be the man here. However* it is contemplated that where sufficiently experienced and knowledgeable local people are available (district managers * contract unit managers, salesmen, etc.) we shall utilise them with respect to any litigation pending in the locality of their responsibilities. It would be Mr. Stapleton's function to secure optimum cooperation from these people. Mr. Stapleton would not travel with the task force except where adequate local per sonnel were not available, although his services may be required from time to time as a witness. The Division has indicated its will ingness to make Mr, Stapleton available in such capacity until such time as this work would interfere too greatly with his other duties, at which time it will be necessary to consider some other arrange ment .
(5) A member of the J-M Legal Department to act as liaison and coordinator^
You have indicated that the writer should continue in this responsi bility. In that event, inasmuch as most of these cases will probably be tried in the Federal Courts, I recommend that the writer take a course in Federal Court Trial Procedure. Such a two-semester course is presently available at night at New York University Law School, Graduate Division, at a cost of $150 per semester.
A serious effort should be made to coordinate the efforts of our task force with the corresponding activities of other manufacturers in the industry who also are defendants in these cases. It may be that in time a single overall committee will prove desirable.
I think that the task force (with the exception of the outside lawyer described in (1) above) should be formally instituted immediately. The basic concept is that the task force will be available to meet with local attorneys for the purpose of educating and guiding them in these cases. As experience in the defense of these cases is gained, this cumulative knowledge will be made available to our various trial counsel. The task force will gather information gen erally useful to our defense, including the names of witnesses, expert or otherwise, best suited to testify in our behalf.
MT-002761
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The basic expenses of this program, other than the obvious travel costs, will be the fees of the outside lawyer and medical expert. While such expenses will not be insignificant they would appear hardly substantial in terms of our potential overall exposure.
B. B.
Jr.
MT-002762