Document MrpMk0b17Xz3RL4Vn9nNgp4M

NO. 91-6526--X ALVIN STENZEL, JR.? TERRY YEAROUT? JOHN BLANTON; ALBERT GOODNER? ELMER GRAY? and WILLIE VAUGHN, Plaintiffs vs ARMSTRONG WORLD INDUSTRIES, INC., ET AL., Defendants. IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 162ND JUDICIAL DISTRICT PLAINTIFF'S FIRST REQUEST FOR PRODUCTION AND INTERROGATORIES TO DEFENDANT UNITED STATES MINERAL PRODUCTS COMPANY TO: United States Mineral Products Company, Defendant, by and through it attorney of record, David A. Livington, Livingston and Markle, 55 Waugh Drive, Suite 200, Houston, Texas 77007. COMES NOW Plaintiff, ALVIN STENZEL, JR., and files this his Request for Production of Documents and Interrogatories pursuant to Rules 167 and 163 of the Texas Rules of Civil Procedure hereby requesting of Defendant to produce the documents designated and described herein. Production of such documents shall commence no later than thirty (30) days from the date of receipt of this request by Defendant, United States Mineral Products Company above and shall continue thereafter until completed. In the alternative, Defendant may mailcopies of such documents prior to such date. Plaintiff, ALVIN STENZEL, JR., serves these Interrogatories upon you, the answers to which shall be made under oath separately and fully in writing with thirty (30) days after the service of Plaintiff's First Request for Production and Interrogatories to Defendant United States Mineral Products Company Page 1 such Interrogatories and shall be given to the undersigned attorney of record. Respectfully submitted, SILBER, PEARLMAN & WORTHINGTON 1000 Highland Park Place 4514 Cole Avenue, LB 34 Dallas, Texas 75205 (214) 528-2000 (214) 522-7400 FAX Reagan State /Bar DEFINITIONS AND INSTRUCTIONS 1. The words ''writing" and "document" are used herein in their broadest sense, and include any original reproduction or copy of any kind of written or documentary material, including without limitation correspondence, memoranda, inter-off ice communications, notes, diaries, contracts, documents, drawings, plans, specifications, minutes of meetings, invoices, billings, checks, reports, studies, telegrams, notes of telephone conversations, and notes of any and all communications and every other means of recording any tangible thing, any form of communication or representation, including letters, words, pictures, sounds or symbols or combinations thereof. 2. Whenever any writing must be described or identified, all writings in the possession or control of the defendant are included, and all such writings shall be identified by date, Plaintiff'* First Request for Production and Interrogatories to Defendant United States Mineral Products Company Page 2 designation, number and physical description. 3. You are requested to furnish all information in your possession and all information available to you, not merely such information as you know of your own personal knowledge, but also all knowledge that is available to you, your employees, officers and agents, by reasonable inquiry, including inquiry of their representatives. 4. If you are unable to answer the following interrogatories completely, answer to the extent possible, specifically stating whatever information or knowledge you have concerning the unanswered portion. 5.' As used herein, "you" and "your", unless otherwise specified, means the defendant corporation answering these interrogatories, its subsidiaries and predecessors, its present and former officers, executives, directors, agents and employees and all other persons acting or purporting to act on behalf of the defendant corporation or its subsidiaries or predecessors. 6. The term "Defendant" refers to United States Mineral Products Company and includes all of the latter's predecessors in interest, subsidiaries, divisions and any other corporations or entities which Defendant has acquired, purchased, merged with or otherwise assumed the assets and liabilities. 7. The term "product" or "asbestos-containing product" refers to finished products, such as plasters, fireproofing, protective coatings, cements, pipecovering, joint compound, Plaintiff's First Request for Production and Interrogatories to Oefendant United States Mineral Products Company - Page 3 millboards, blocks, paper, felts and others, which contain any amount of any type of asbestos material and which are intended for use for any purpose, such as thermal insulation, soundproofing, residential or commercial use, construction, decoration, etc. 8. The terms "test" and "testing" are used in their broadest sense, including but not limited to, studies of atmospheric dust samples, studies of the concentration of silica in such airborne test sample, studies of the lung conditions of workers (by x-ray or other means of medical surveillance), pulmonary function studies of workers, animal studies, pathological studies, industrial hygiene studies, risk assessment studies, cost-benefit analyses and any other studies on'the product concerning health and safety required by any governmental agency. 9. "Health impacts" is intended to refer to any injury, affect, damage, marring, wound, impairment or disability of any part of the human anatomy, including the lungs and lung linings, such as silicosis that is caused by or associated with exposures to silica sand and dust. 10. The term "predecessor-in-interest" when used below is defined for purposes of these interrogatories as any prior existing corporation which Defendant has merged with, consolidated with, purchased assets of, reorganized into or otherwise absorbed to become a single corporation, and any previously existing corporations which merged with, consolidated with, purchased assets of, reorganized into or was otherwise absorbed by a corporation Plaintiff's First Request for Production and Interrogatories to Defendant United States Mineral Products Company Page 4 which was subsequently absorbed by Defendant. DOCUMENT REQUEST NO. 1 Please produce each and every document identified in Exhibit A, attached hereto. INTERROGATORY NO. 1 For each and every document produced in response to Request For Production No. 1 above, is said document a true and correct copy of the original document? ANSWER; INTERROGATORY NO. 2 For each and every document produced in response to Request For Production No. 1 above, please answer the following: (a) Was said document kept, generated or received by Defendant United States Mineral Products Company and\or its predecessor(s)-in-interest in the regular course of business? ANSWER: (b) For each document produced in response to Request For Production No. 1 above, was it the regular course of business of Defendant United States Mineral Products Company and\or its predecessor(s)-in-interest for an employee or representative of Defendant United States Mineral Products Company and\or its predecessor(s)-in-interest, with knowledge of the act, event, Plaintiff's first Request for Production and interrogatories to Defendant United States Mineral Products Cotnoanv Page 5 condition, opinion or diagnosis recorded to make the record or to transmit information thereof to be included in such record? ANSWER: (c) For each said document produced in response to Request For Production No. 1 above, was said document recorded by Defendant United States Mineral Products Company and\or its predecessor(s)-in-interest at or near the time or reasonably soon thereafter? ANSWER: (d) For each* such document produced in response to Request For Production No. 1, is said document a "business record", as that term is used in the Texas Rules of Civil Procedure? ANSWER: INTERROGATORY NO. 3 Please identify the name, address, phone number and job title of the custodian of records concerning asbestos products, asbestosrelated disease and\or asbestos personal injury litigation for Defendant United States Mineral Products Company. ANSWER: Plaintiff's First Request for Production and Interrogatories to Oefendant United States Mineral Products Coneany - Page 6 UEST FOR PRODUCTION NO. 2 Please produce the index, catalogue, table of contents or any her such document which identifies or makes a record of documents :pt by Defendant United States Mineral Products Company regarding ie manufacture, marketing or sale of asbestos products and\or sbestos-related disease. iTSWER: INTERROGATORY MO. 4 For each document(s) identified in Exhibit A which Defendant has not agreed to produce herein, please state whether Defendant has produced said document(s) in response to discovery requests in other asbestos personal injury lawsuits and, if so, please identify \ the name and phone number of the attorneys to whom said documents were produced. ANSWER: INTERROGATORY NO. 5 For each document(s) identified in Exhibit A which Defendant does not believe qualifies as a "business record" under the Texas Rules of Civil Procedure, has said document been deemed a "business record" by any Court in an asbestos personal injury lawsuit in which United States Mineral Products Company was a party? If so, please identify the name and phone number of the Plaintiff's attorney in said lawsuit(s). Plaintiff's first Request for Production and Interrogatories to Defendant United States Mineral Products Company * Page 7 ANSWER: CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Interrogatories was served on counsel of record Plaintiff's first Request for Production and Interrogatories to Defendant United States Mineral Products Company Page 8 Exhibit "A" USM-1 Charts, diagrams, slides, photographs and other demonstration materials used in conjunction with testimony of any expert witness. USM-2 Warning label contained on U.S.M. bags. USM-3 USM-4 Stumpf letter to British Information Services, November 7, 1968. Stumpf Memo to Verhalen, March 13, 1967. USM-5 Stumpf Memo to Neilly, December 24, 1964. USM-6 W.J. Kaag Inter-office Memo, July 12, 1965. USM-7 F.M. Stumpf Inter-office Memo, July 2, 1965. USM-8 Stumpf Memo to Verhalen, September 2, 1966. USM-9 Research Department Memo, September 8, 1964. USM-10 Stumpf Memo to Verhalen, February 20, 1964. USM-11 Polakoski Memo to Stumpf, January 8, 1963. USM-12 Stumpf Memo to Schlemmer, January 9, 1962. USM-13 O'Rourke Memo to Schneider, January 31, 1966. USM-14 Ludlum letter to Acoustical Engineering, November 11, 1959. USM-15 Letter of J.K. Ludlum, Columbia Acoustics to Acousti Engineering of Carolinas, Inc., recommending use of dust masks. February 20, 1953. USM-16 Memo with directions for application CAFCO BlazeShield Type H. December 30, 1965. USM-17 CAFCO Bulletin No. 34 re: Bureau of Mines Approval Respirators & Filters - No. 32 re: Health Hazards to Workmen. USM-18 Memo to Fischer from Schlemmer. February 13, 19 62. USM-19 Memo to Schlemmer from Verhalen. USM-20 Letter of Selikoff to Contracting.Plasterers( and Lathers' International Association. December 10, 1969. USM-21 OSHA Regulations "Standard for Exposure to Asbestos ''Dust", Federal Register, Vol. 37, No. 110 (June 7, 1972). USM-22 Division of Industrial Safety - Los Angeles Memo to Safety Engineers. September 21, 1966. USM-23 Letter from George A. Sherman, Chief, California Department of Industrial Relations, to James P. Verhalen. February 7, 1967. USM-24 Stumpf letter to U.S. Bureau of Mines. 1963. March 23, USM-25 Letter between USM and Wisconsin - Facilities. January 2, 1973. Bureau of USM-26~ Letter between Wisconsin Bureau of Facilities and USM, 4/19/73. USM-27 Letter from Stumpf to health Ed. Portland, Oregon. 3/13/69. Consultant, USM-28 Insulation Hygiene Progress Reports. Spring, 1969. USM-29 Insulation Hygiene Progress Reports. Summer, 1969. USM-30 USM-31 CJSM-3 2 USM-33 USM-34 USM-35 USM-36 USM-37 USM-38 USM-39 USM-40 USM-41 ^^USM"42 USM"43 ^p<2?-^sk-44 ^ ^OSK-43 USM-46 USM-47 ^f^USM"48 Insulation Hygiene Progress Reports. Fall, 1969. Insulation Hygiene Progress Reports. Winter, 1969. Federal Specifications - Sound Absorbing Materials Trowel and Spray Application. 9/3/64 GSA Guide Specifications Protection, May, 1964. for Sprayed-On Fire Memo from O'Rourke to Stumpf. 6/20/61. Memo from O'Rourke to Schlemmer. 1/17/62. Bureau of Mines - New Approvals re: Respiratory devices, 7/9/62, 10/16/58. Memo to O'Rourke from Stumpf. 7/26/61. Letter of John v. Wiman, Columbia Acoustics to Minnesota Mining and Manufacturing Co. 6/29/61. Letter of Minnesota Mining to Wiman of Columbia Acoustics. 7/28/61. Letter of Stumpf to companies. 4/8/63. Memo of Columbia Acoustics re: Bureau of Mines Approved Respirators and Filters. 5/2/63. Letter of Stumpf to Employers Mutual of Wausau. 9/17/57. Letter of Employers Mutual to Columbia Acoustics. 9/5/57. Letter of Stumpf to Johns-Manville. 9/17/57. Letter of Smith, M.D., Johns-Manville to Stumpf. 9/30/57. Application Manual for CAFCO Blaze-Shield Standard, Heat-Shield, Type H. SMFMA letter to State Health Commissioner. 9/2/70. Letter of Williams Reitze from Mt. Sinai to SMFMA re: draft of Recommended Health Safety Practices. 4/2/70. USM-49 USM-50 USM-51 USM.-5 2 USM-53 USM-54 USM-55 USM-56 USM-57 USM-58 USM-59 USM-60 USM-61 USM-62 USM-63 USM-64 USM-65 Selikoff, Irving J., M.D., Prevention - The Insulation Research Program." April 1970. "Partnership for Industry Hygiene Letter of H. Levine of SMFMA to SMFMA members. 5/27/70. Letter of 0`Rourke, V.P. Sales, USM to American Hygiene Association. 7/28/68. Hygienic Guide Series on "Asbestos." Letter of Cadwalader, Wickersham & Taft to Dr. Smith of Johns-Manville Corp. 7/6/66. Threshold Limit Values for Substance in Workroom Air adopted by ACGIH for 1972. SMFMA- Inspection procedure for Field Applied Sprayed Fire Protection Materials. Letter of J. Balzer of University of California, Berkeley School of Public Health to H. Levine of Asbestospray Corp. 4/8/70. SMFMA Bulletin No. Application Practice. T-l-68, Sprayed Fiber W.R. Bradley letter to H. Levine. 4/28/69. F. Sturopf letter to H.L. levine, L. Jenne, M. Lieff. 11/1/68. SMFMA Recommended Code of Practices for Application of Sprayed Fireproofing Materials. 3/68. PBS Guide Spec Section 092Q, Sprayed Fiber Protection. 5/65 General Services Administration Public Buildings Service Interim Guide Specification, 11/64. GSA Public Buildings Service Interim Guide Spec. 2/7/67. Letter from Levine to Kodaras Labs. 9/72. Amendment 2: Sprayed Fire Protection. USM-66 USM-67 USM-68 USM-69 USM-70 USM-71 USM-72 USM-73 USM-74 USM-75 USM-76 USM-77 USM-73 USM-79 USM-80 USM-81,.. USM-82 USM-83 USM-84 USM-85 3/12/70. Levine letter to Jenne, Toth, Gropp. 3/9/70. Selikoff letter to Levine. 6/15-13/70. Mt. Sinai Medical School Post-Grad School Asbestosis brochure. 1/31/70. Levine letter to Selikoff. 9/11/67. Inter-Office Memo from Verhalen to all CAFCO Sales Personnel. 4/22/63. Letter from Levine to Wittkop (BEH), Toth (S&K), O'Rourke, Binger. 8/11/69. Letter from William Nicholson to Gropp. Undated. - IIHRP - SMFMA Launch NYC Program. Undated. Sprayed Fiber Story, handwriting on top states "Edited Version." 1/6/69. Letter from Levine to Toth (S&K), Gropp, Jenne (Keene). Binger with Letter from Selikoff to Levine dated 12/16/68 attached. 5/19/71. Letter from Selikoff to Levine. 7/17/70. Statement approved by Dr. William J. Nicholson. 9/19/67. Research Department - Open Projects. 10/20/60. Schneider Memo to O'Rourke . Research Bulletin Undated. (on dusting and flaking). Flaking Resistance Tests of CAFCO. 10/16/58. Letter from Wiman to R. Harvey. 2/11/59. International Testing test results. 4/27/62. Research test memo from Stumpf to O'Rourke. 2/17/64. Tests on CAFCO, Blaze-Shield Type D. Circa 1969. 17SM--8 6 USM-87 USM-88 USM-89 USM-90 USM-91 USM-92 USM-93 USM-94 USM-95 USM-96 USM-97 USM-98 USM-99 USM-100 USM-101 USM-102 USM--103v USM-104 USM-105 USM-106 USM-107 USM--108 Research department test results. 9/9/65. International Testing test results. 8/16/66. Article, "Fireproofing Return Air Plenums" by Kodaras from Air Conditionincr. Heatina and Ventilatina. December. 1968. William Bradley test results. 7/2/69. Kodaras tests results. 12/30/69. International Testing test results. 4/27/64. S.D. Sumski Test Results. 7/20/67. U.S. Mineral test results. 7/28/66. Letter from Sumski to Stumpf. 5/1/62. Tabershaw Cooper test results. 7/17/70. F. Stumpf memo to N. Buttino. 6/30/69. F. Stumpf letter to International Testing Labs. 2/2/62. D. Oris letter to H. Sommers. 2/10/64. Patent application. 1/24/64. Patent Certificate. 1/21/64. F. Stumpf memo to J. Verhalen. 5/21/63. F. Stumpf letter to H. Sommers. 3/1/62. Associated Testing Labs test results. 1/13/60. Associated Testing Labs test results, 10/29/59. ASTK standard specifications. 9/5/72. SMFMA bulletin "Sprayed Practice'1. Undated. Fiber Application H. Levine letter to J. Ferro. 12/8/70. P. Maresca letter to H, Levine. 8/18/70. USM-109 H. Levine letter to F. Stumpf. 12/3/69. USM-110 Minutes of annual meeting. 1/29/69. USM-111 J.P. Verhalen memo to R.E. Schlemmer. 4/26/63. USM-112 Letter from A. Rohl, 11/3/70. USM-113 Technical Bulletin #C363. 9/28/62. USM-X14 Letter from H. Malarek to R. Colville. 9/10/62. USM-115 Memo from F. Stumpf to J. Verhalen. 3/2/67. USM-116 Memo from J. Verhalen to F. Stumpf. 3/23/67. USM-117 Federal Register Rules. 12/7/71. USM-118 Memo from J. Verhalen to R. Schlemmer. 1/2/62. USM-119 Letter from N.W. Hendry at Johns-Manville. 10/1/68. USM-120 'Memo from F. Stumpf to R. Schlemmer. .10/19/66. USM-121 Massachusetts Dept. of Labor and Industries Recommended Safe Practices, Mineral Data Sheet No. 3 - Mica. 1/69. USM-122 Massachusetts Dept. of Labor and Industries Recommended Safe Practices, Mineral Data Sheet No. 2 - Asbestos. 12/68. USM-123 Massachusetts Dept. of Labor and Industries Recommended Safe Practices. Mineral Data Sheet No. 24 - Dispersoid Respirators Highly Toxic Dusts. 12/68. USM-124 Letter from R. Rickies at NYC Dept, of Air Resources to J. Verhalen. 4/29/70. USM-125 Memo from F. Stumpf to H. Gropp. 6/23/65. USM-126 Letter from E. Sommers of Universal Insulating Machine to F. Stumpf. 4/22/63. USM-127 USM Research Report No. 365. 10/9/69. USM-128 USM Research Report No. 366. 11/12/69. USM-129 USM-130 USM-131 USM-132 USM-133 USM-134 USM-135 USM-136 USM-137 USM-133 USM-139 USM-140 USM-141 USM-142 USM-143 USM-144 USM-14S USM-146 USM-147 The Asbestosis Research Council Recommended Code of Practice. 12/66. Letter from H. Levine to W. Geoghagan of Diesel Construction. 1/12/70. Letter from H. Levine to Jenne of Keene, Lieff of Philip Carey, and Stumpf of USM. 12/29/69. The Asbestosis Research Council Provisional Notes for Guidance for the Application of Sprayed Asbestos Coatings. 6/69. Letter from R. Hackney of Johns-Manville to J. Verhalen. 3/18/66. Letter from W. Nicholson to H. Levine. 5/15/69. Letter from I. Selikoff to H. Levine. 10/9/68. Federal Specification Materials. 9/3/64. for Sound Absorbing Section V of 1956 CAFCO Sales and Application Manual. 10/10/56. NYC Dept, of Air Resources Commissioner's Order. Undated. Tabershaw-Cooper Report to SMFMA. 11/5/70. Tabershaw-Cooper Report to SMFMA. 9/23/70. Research Report re: Vibration Resistance of CAFCO spray. 2/25/57. Letter from Levine to Selikoff. 6/23/66. Letter from Selikoff to Toth. 2/9/70. Letter from Levine to Toth and Lieff. 5/6/68. Letter from Selikoff to Empire Pyro-Spray. 2/3/70. Letter from Selikoff to Contractors Association of New York. 2/2/70. Research Bulletin re: Sound-Shield. 4/10/59. { USM-14 8 USM-149 Sales Bulletin re: Blaze-Shield. 3/31/60. 1969. Article "A Dust Survey Carried Out In Buildings Incorporating Asbestos-Based Materials In Their Construction*1, Byrom, et al. USM-150 Letter from Francis Joyce to Bechtel Corporation with 9/1/70 Report of Tabershaw-Cooper attached. 9/3/70. USM-151 USM-152 USM-153 Factory Mutual Report on Blaze-Shield. 3/26/59. SMFMA Technical Committee Report. 5/22/68. Letter from Levine to William J. 10/26/70. Stanley. USK-154 "Asbestos in the Air and the General Public". Undated. USM-155 Letter from Selikoff to Goldberg. 9/8/70. USM-156 Letter from Verhalen to EPA. 7/3/70. * USM-157 Letters to Editor, Chemical Week. 10/8/66. USM-158 Reprint of Chapter 2, "Asbestosis" by Kenneth Smith. M.D. from The Pneumoconioses. Undated. USM-159 `t1 USM^lfiO ^AA^^sM-iei Letter from O'Rourke to Levine. 7/17/68. Letter from Lange to Stumpf. 9/23/57. Letter from Stumpf to Lange. 10/3/57. USM-162 Minutes of Meeting, Board of Examiners with 7/15/70 Tabershaw-Cooper Report Attached. 7/21/70. 0SM-ltf3r. Letter from Cooper to Levine. USM--164** Letter from Levine to Cooper. 11/5/70. 6/10/70. \/ USM-165 Letter from Levine to Fowler. 10/27/70. USM-166 Letter from Levine to SMFMA members. 10/8/70. USM-167 Kodaras Report on Sprayed Mineral Fiber Dusting Tests. 7/10/67. USM-163 Kodaras Report for SMFMA. 12/26/67. USM-169 Article "Application of Sprayed Inorganic Fiber Containing Asbestos: Occupational Health Hazards", by Reitze, Nicholson, Holaday and SeliJcoff. 8/3/71. USM-170 Letter from B. Walls of Cadwalader, Wickerman & Taft to J. Verhalen. 11/27/61. USM-171 Letter from R. Porter of Keasbey & Mattison to J. Verhalen. 11/10/61. USM-172 Letter from J. Verhalen to G. Reycraft of Cadwalader, Wickersham $ Taft. 10/20/65. USM-173 Certificate of Incorporation of Sprayed Mineral Fiber Manufacturers Association, Inc. 12/1/65. USM-174 Constitution and By-Laws of Sprayed Mineral Fiber Manufacturers Association, Inc. Undated. USM-17 5 -v Memorandum from J. Verhalen to Members of SMFMA re: Meeting on 12/7/65. 12/4/65. USM-176 Letter from J. O'Rourke to J. Edmonds of American Institute of Steel Construction. 1/26/66. USM-I77 Letter from J. Verhalen as SMFMA Member to H. Levine. 12/8/76. USM-17S Letter from H. Levine as SMFMA Member to Mr. Weatherby of Keene, Mr. Toth of Philip Carey, and Mr. Gropp of USM. 9/29/69. USM-179 Letter from H. Levine as SMFMA Member to Mr. Jenne of Keene Corp., Mr. Toth and Mr. Lieff of Philip Carey, and Mr. Gropp & Mr. Stumpf of USM. 4/8/70. USM-130 Letter from W. Reitze of Mt. Sinai to H. Levine as President of SMFMA. 4/1/70. USM-181 Letter from H. Levine as SMFMA Member to USM, Philip Carey, Keene Corp., and Asbestospray Corp. 6/24/69. USM-1S2 Letter from H. Levine as SMFMA Member to USM, Philip Carey,- Keene Corp., and Asbestospray. 6/24/69. USM-182 Letter from Levine to Verhalen. 3/10/66. Letter from SeljJcoff to Binger of SMFMA. 2/9/70. Letter from Levine to Stumpf (USM), Jenne (Keene), and Lieff (S&K). 2/5/69. 5>USM-18 6 Letter from Levine to Stumpf (USM), Lieff (S&K), and Jenne (Baldwin). 10/22/88. Letter from Levine to (S&K), Stumpf (USM), (Cadwalader). 3/4/66. Wilson (Baldwin), Verhalen (USM), Lieff Boyer USM-187 USM-188 Letter from Selikoff to Levine. 5/12/69. Letter from Levine to Jenne (Keene), Toth (Philip Carey), and Gropp (USM). 5/19/69. USM-189 Letter from Levine to Wilson (Baldwin), Lieff ' (S&K), USM (Stumpf). 4/12/66. USM-190 USM-191 Letter from Levine to Verhalen (USM), Wittkop (Baldwin), Binger (S&K), Boyer (Cadwalader). 5/10/66. Letter from Levine to Jenne (Keene), Toth & Lieff (Philip Carey), and Gropp & Stumpf (USM). 2/26/70. USM-192 Letter from Levine to Verhalen. 11/11/66. USM-193 Letter from Verhalen to Lieff, 3/6/66. USM-194 Letter from Levine to Wilson (S&K), Stumpf (USM), Verhalen (Cadwalader). 3/4/66. (Baldwin), (USM), and Lieff Boyer USM--lBSt Letter from Levine to Verhalen. 3/7/66. USM-1S6- Letter from Levine to Wilson (Baldwin), Lieff (S&k), and Stumpf (USM) with attached article "Asbestos Exposure and Neoplasia11. 4/11/66. USM-197 Letter from Levine to Insulation Industry Health Research Fund c/o Selikoff. 9/11/68. USM-19 8 Letter from Levine to SMFMA Board of Directors. 1/4/71. USM-199 USM-200 USM-201 USM-202 USM-203 USM-204 Letter from Selikoff as President-Elect of New York Academy of Sciences to Levine. 4/10/68. Letter from Levine to Jenne (Keene), Toth (Philip Carey), and Gropp (USM). 12/13/69. Letter from Selikoff to Carroll of Contracting Plasterers' and Lathers' International Association. 12/10/69. Sampling Report of Reitze and Rohl re: sampling at 127 John Street in NYC on 9/3/70. Undated. Sampling Report of Reitze & Rohl re: sampling at 1 State Street in NYC on 9/16/70. Undated. Letter from R. Hebblethwaite of Florida State Board of Health to L. Benavides of Dade County Health Department. 1/24/67.