Document Mzg92YeVB0Kw1y0QdEgbGo9V

5immonsCooperLtf Attorneys at Law Front the desk of: TedN. Gianaris . . . FYI December 7, 2005 Camille CribareMello Ryan McQueeney Sanchez Daniels & Hoffman 333 West Wacker Drive, Suite 500 Chicago, Illinois 60606 RE: Ford Motor Company, General Motors Corporation and Detroit Diesel Company Dear Ms. CribareMello and Mr. McQueeney: We look forward to your timely response to our written discovery. Also, we heed to depose all witnesses, fact and/ox expert, which you plain to call at trial next year on behalfof Ford, General Motors and/or Detroit Diesel. It is very important we receivetheir reports and start deposing these witnesses very soon. There is a general tendency in this litigation to put offresponding to discovery and producing experts in anticipation of settlement negotiations. We cannot allow ourselves to get lulled into such apotential trap. We must completeall these depositions soon. Furthermore, Iwould like both Ford and General Motors to each designate awitness or witnesses to be deposed on behalf of the respective corporations on the following topics: (1) tiie health and safety aspects ofyour companies' asbestos-containing products; (2) efforts and attempts your company made to create, or include for sale on your vehicles oras replacementparts, non-asbestos containingfictionmaterials,including . the technical and engineeringfeasibility ofsuch non-asbestos friction products in the 1960s, 1970s, and 1980s. The safety aspects, both pro and con, ofsaid non-asbestos fiction products, and the cost of said non-asbestos fiction products. (3) Warnings or cautions provided to customers, mechanics or users ofyourvehicles or . fiction materials regarding any potentially harmful health effects ofyour asbestoscontaining products. -Why these Warnings or cautions were made when they were made and how the decision was made regarding what language to include in said caution or warning. ei/d - ' .Mom Office iwwamnweawpecCTiii [707 Berkshire BH 8M.47S.9533 . P.0. Ira 52! 418.259.2212 fcictdllnn It ' --------- -- Page 1 of -2 209 Soulh tcSalleSt 312759-7500 Suite 805 317.759 75IA Fn* Tews Office_ _ _ _ _ _ I 103 North Sycarnete f pn Dnwtt/n c4g:eo 90 Of In. Re: All Asb. Camille CribareMello Ryan McQueeney December 1, 2005 Page 2 (4) Membership in, activities in and relationship 'with the National Safety Council, the Friction Material Standards Institute, The Asbestos InfonnartionAssociation, and the Industrial Hygiene Foundation. Please let me know in the next ten (10) days when we can start deposing the corporation on these issues. . Sincerely, Ted N. Gianaris TNG/swc Page 2 of 2 n'd c4g:eo 90 01