Document MMXLKZaxdRpb2yLjrOvRw8v2M

LIBERTY MUTUAL Mosswood Park Office Building, 3505 Broadway, Oakland, California 94611 * Tel. (415) 653-5800 November 18, 1974 Sherwin-Williams Co. P.0. Box 23505 Oakland, Ca. 94623 ATM. : MR. RICHARD GIONOEPI R. A. G. NOV Z l 1974 PERSONNEL i INSURANCE":-/ N.CT7 . j* i, r e: Redacted h e s w in -w il l ia ms b mh t s Redacted Gentlemen: This will refer to our conversation on November 15, 1974, regarding the abovecaptioned matter. At that time, 1 spoke to you regarding an offer made by Mr, Robert Laws, the attorney for Kaiser Hospital. The substance of this conversation was that Mr. Laws would be willing to settle his $6,000 lien for a total of $2,000. This information was relayed to me by Mr. Sam Meredith, our attorney who is handling the workmen's compensation end of this case. He was approadhed by Mr. Laws, and this offer was made to him. Additionally, Mr. Laws stated that he would not inform the applicant's attorney prior to trial that they had settled their lien. . Additionally, we discussed the possibility of the prejudicial aspect, where if we settled the lien for one-third, the applicant's wife might have same grounds whereby she could say, since you settled Kaiser's lien, you should settle my claim for one-third also. I want to enforce that neither Mr. Meredith nor Liberty Mutual is recommend ing this action specifically, but is directing this information to SherwinWilliams for their comment on the matter. This matter is scheduled for hearing before the Workmen' s Compensation Appeals N40609 r ang e: NOV 25 1974 LIBERTY MUTUAL INSURANCE COMPANY LIBERTY MUTUAL FIRE INSURANCE COMPANY LIBERTY LIFE ASSURANCE COMPANY OF BOSTONHOME OFFICES: BOSTON