Document LMevpmzjknw43J7Z55QV4grz
RAYMOND W. HACKBARTH ROBERT B. MC CORMICK JAY W. WASON JOHN E. MORRISSEY. JR. CHARLES ANDREWS ROBERT H. WOODFORD THOMAS F. QUINLAN CHARLES J. CRONIN JAMES H. O'CONNOR WILLIS 8. LEMON CARTER H. STRICKLAND** DENNIS R. BALDWIN GAY M. POMEROY* KEVIN M. REILLY EDWARD J. MOSES GEORGE R. WOLFF CLAYTON H. HALE. JR. ALFRED W. POPKESS KENNETH E. ACKERMAN
Ma c k e n z ie Smit h Le w is Mic h e l l & Hu g h e s
LAW OFFICES
ARTHUR A. CHALENSKi. JR. CATHERINE A. GALE
ARTHUR W. WENTLANDT MICHAEL P. DALY
NANCY C. PONTIUS EDWARD J. SPENCER. Ill CHARLENE C. MC GRAW
OENNIS P. HENNIGAN
ALSO ADMITTED TO FLORIDA BAR
600 ONONDAGA SAVINGS BANK BUILDING SYRACUSE. NEW YORK 13202*1399 015) 474*7571 TELECOPIER (3151 474*7571
RECEIVED
JAH 24 1933
Corp.,RiskMgmt.
ALSO ADMITTED
TOOCB*B
January 19, 1983
EDMUND H. LEWIS IS84*t72
JOHN H. HUGHES 1904*1972
EDWARO J. SPENCER. JR. 1917*1901
WILLIS A. GROWN 1910*1062
FRANCIS P. MALONEY WILLIAM L. BROAD
CARLETON E. REIFPSMSTEIN GEORGE S. SULLIVAN T. FRANK DOLAN. JR. ROBERT J. GANG. JR. COUNSEL
Mr. Thomas M. Locker Administrator o f Workers' Sherwin Williams Company 101 Project Avenue, N.W. Cleveland, Ohio 44115
Compensation
r edac t ed
Re:
v. New Primex
Realty Associates v. The
Sherwin-Williams Company
Dear Mr. Locker:
I would appreciate receiving a response to the information requested in my December 17, 1982, correspondence.
In addition and in response to my August 26, 1982, corres pondence you indicated in response to my question number 9 regarding a list of the suppliers of the components of paint coatings and the components of solvents used at the involved location from July 1, 1977 through December 31, 1978, that you would not release this information. Subsequently I believe that John White of the Aetna spoke to you, emphasizing the importance of us having this information since it is your allegation that benzene was not present in any Sherwin Williams product.
I would appreciate this information immediately as we are now entering an essential pre-trial stage and trial is expected within the next two months.
If this information is not supplied, it will put us in a very difficult situation in defending Sherwin Williams and making allegations that in fact benzene was not present in its products.
Would you kindly advise of the name of the Sherwin Williams
employee who will testify as to the chemicals or other components
of its products and who will be our witness for the proposition that
there was no benzene in any products manufactured, or sold by Sherwin
Williams at the involved outlet store.
.
N40511