Document NNvQbYnY3Od2XdyBz0JEOZ1Lb
FILE NAME Industrial Hygiene Foundation IHF
DATE 1986 DOC IHF026
DOCUMENT DESCRIPTION Protective Order with Memo to BC RE IHF Member
Registration Cards
THOMAS W. HENDERSON THEODORE GOLDBERG JOEL PERSKY ANTONIO D. PYLE ROBERT L. JENNINGS JR THOMAS W. WHITE ROBERT ALAN KREBS
HENDERSON & GOLDBERG P.C.
ATTORNEYS AT LAW 1612 FRICK BUILDING
PITTSBURGH PENNSYLVANIA 15219
412 471-3980
July 3 1986
Barry Castleman Ph.D.
1722 Linden Avenue
Baltimore MD 21217
RE Industrial Hygiene Foundation
Dear Dr. Castleman
Please find enclosed a copy of the former membership registration cards of the Industrial Hygiene Foundation as well as a Protective Order entered by the U.S. District Court for the Western District of Pennsylvania which governs the conditions of possible dissemination of these documents As we have discussed in the past it is my opinion that the present Protective Order precludes publishing the list in a book or magazine for public use but nothing prevents dissemination of the list to other attorneys involved in litigation so long as the Protective Order accompanies the documents
These documents are being sent to you at this time for your review and analysis in connection with your work as an expert witness with our office in various asbestos and related product liability lawsuits I believe that the Protective Order is clear that these documents may be used by you or other attorneys in connection with other forms of litigation so long as the protective order accompanies the documents and no use is made of the documents for purposes other than litigation such as competitive efforts by competing industrial hygiene companies to exploit former members of the IHF
It is my understanding that you are willing to abide by the terms of the Protective Order until modified by the court
Very truly yours
RLJJr kjk
Enclosures
Robert L. Jennings Jr.
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