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PLAINTIFF'S EXHIBIT
0 S : :i SOU HERN
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ATES BANKRUPTCY DISTRICT OF NEW
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YORK
X In Proceedings for a Reorganization Under Chapter 11
;j JOHNS-MANVILLE CORPORATION, et al., !j Debtors.
Case Numbers 82 B 11656 ( Through 82 3 11676 (
i !I 'JOSEPH McLOUGHLIN and HELEN
McLOUGHLIN, et al..
Plaintiffs,
Adversary Proceeding Number 82-6037
V.
`JOHNS-MANVILLE CORPORATION, et al
AFFIDAVIT OF CHARLES H. ________ ROEMER
Defendants. X
STATE OF NEW YORK COUNTY OF NEW YORK
)
) ss . : )
CHARLES H. ROEMER, being duly sworn, deposes anc says:
1. I am an attorney who was admitted to practice in
the State of New Jersey in 1920 and presently maintain an i'
office at 99 Broadway, Elmwood Park, Bergen County, New Jersey,
jj 2. I was born February 5, 1899 and am presently under
; the care of Dr. David Roth. ;1 li 3. Sometime in 1942-43, I was advised by my cousin,
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<`0r. Jacob Roemer, that in the course of reviewing chest x-ravs
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;j or employees at the Union Asbestos and Rubber Company's Paterson
;! plant he had observed a significant number with lung chances ;i
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sugcested that the men be advised of his findings and that \
they secure outdoor employment which cia not involve exposure to asbestos dust- Dr. Roemer said unless this was done im mediately the men would suffer from painful asbestos diseases.
4. Immediately I reported what Dr. Roemer said to Robert Cryor, the Union Asbestos and Rubber Company Plant Manager and Edward Shuman, the Assistant Plant Manager.
5. I was then informed that in accordance with the labor union contract, the 5 or 6 employees in question could not be discharged without the consent of the union. The union refused to consent to their dismissal.
6. I then suggested that since Johns-Manvi1le was the largest asbestos company in the country, we should set up an appointment to see how they were handling the asbestos health problem.
7. Mr.. Cryor and Mr. Shuman set up an appointment with Jchns-Ma.nviile. Shortly thereafter, Mr. Cryor, Mr. Shuman anc I met with Vandiver 3rown, General Attorney for JohnsMa.nville and the President of the Corporation, at JohnsManville corporate headquarters in New York City.
8. We advised the Johns-Manville officials of Dr. Roemer's findings and asked them if Johns-Manville's physical examination program had turned up similar findings and, if so, what Johns-Manville was doing about it.
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p'nys ical ex ami r.a t ion progra... r.ac, indeed, also producer - -; ..cmcs of x-ray evidence of asbestos disease among workers expo S cC tio asbestos and that i t was Johns-Manvi1le's policy not to CO anything nor to tell the employees of the x-ray findings. Vandiver Brown went on to say that it was foolish for us to be
concerned and that if Johns-Manvi1le's workers were told, they
would stop working and file claims against Johns-Manville, and that it was Johns-Manville' s policy to let them work until they
quit work because of asbestosis or died as a result of asbestos-
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related diseases.
10. Thereafter, we contacted Dr. Lanza at Saranac Lake, who was in charge of an asbestos exposure study and we were
unable to cather a.nv further advice or information from him.
Sworn to before me this 29th day of September, 1982
2r, --i C.
Notary Public
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Non.-, ru.:.c.
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\'j. <i : iT'\
QualiTxJ m Q-ji.im Co-ioty
To Expitct Mudi 30,
Charles H. Roofer