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. ts 31 Fncniteien IN THE DISTRICT FOR THE COURT OF T HE DISTRICT THE UNITED UNITED STATES STATES IN RE: ) ASBESTOS LITIGATION ) ) Miscellaneous 8482 8482 wh SUPPLEMENTAL SUPPLEMENTAL AND Now, this day AND AND by INDUSTRIAL HEALTH " Motion DANIEL c, of FOUNDATION March , Dr. 1986 upon INC the Braun motion the IHF and pursuant to Rules and to asserted that the Index Cards asserted contain sensitive referred Local of Civil Procedure 28 Rule , the IHF its a e nguetemy aya pris aan enwen Arie ROR(tet et:i t. NE: she Pittsburgh Pittsburgh Asbestos Asbestos Litigation the Index Cards Cards Index May deposition Counsel Cards Dr, identified Braun direct direct their request request written r to Dr. thirty 30 days entry Braun the within of this this indicate the Order The number complete complete letter or which individual oe kame OO came Aigyee a ANE=) a a Cards from the InP counsel counsel en lieu formal in liey paragraph paragraph . this. paragraph, formal requests requests, Asbestos Litigation (hereinafter Asbestos Litigation collectively referred to as hereinafter collectively copies any or all of of the Index Cards the Cards Index cf Dr, Braun order to minimize 1985 deposition minimize Pittsburgh Asbestos Litigation Counsel direct direct their request rHp within thirty 30 days from entry this this will be obtaining the Index Cards from the IHF counsel counsel for matters referred The referred IHF to paragraph shall the reimbursed fifty cents Index Cards which requested copying each Index Counsel 0.50 page Page requested by plaintiffs Pittsburgh Asbestos counsel for the the Should of Dr. Braun defendants defendants notice on matters the directly relating the the deposition or as to other IHF matters said shall Index the IHF the total counsel sum of Three Hundred Dollars reimburse for the time spent by Dr. Braun in reviewing 300.00 documents as for well the deposition and as for any desired for the actual the deposition deposition itself Braun, conference with 7. THAT the District Court of the United States for the ee Ae ue ny tae Wt ye AEM (VANES Baa Ho