Document Ne6MRz01xrJ75kwyLddk2K06w

FILE NAME: Sperry Rand (SR) DATE: 1986 DOC#: SR001 DOCUMENT DESCRIPTION: Sperry Rand Member of IHF 1956-1959 with Cover Letter 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 Pi t t s b u r g h ,Pe n n s y l v a n i a 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 enclpsed 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 silica-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 anti-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 IN THE DISTRICT COURT OF THE UNITED STATES FOR THE WESTERN DISTRICT OF PENNSYLVANIA IN RE: ASBESTOS LITIGATION Miscellaneous No. 8482 SUPPLEMENTAL PROTECTIVE ORDER OF COURT C O N C E R N I N G I N D U S T R I A L HEALTH FOUNDATION, INC. AND NOW, this day of March, 1 9 8 6 , upon motion (the "Motion") b y I N D U S T R I A L HE A L T H FOUNDATION, INC. (the " I H F " ), and its President, DANIEL C. BRAUN, M.D. ("Dr. Braun"), pursuant to Rules 26 and 45 of the Federal Rules of Civil Procedure, 28 U . S . C . A . (the " R u l e s " ) , and t o Local R u l e 4, the I HF h a v i n g asserted that the Index Cards referred to in Paragraph Two of its Motion contain sensitive, proprietary information and that some of the information contained therein is not r elevant to the asbestos litigation identified at the above Miscellaneous Number (the "Asbestos Litigation"), and the Court subsequently deter mining that all the information contained therein is relevant in the Asbestos Litigation but that the IHF is entitled to an appropriate Protective Order to prevent undue dissemination of this information, IT IS HEREBY ORDERED: !- THAT the IHF shall make available to counsel for various plaintiffs, as well as to legal counsel in Pittsburgh for any of :he d e f e n d a n t s ( e i t h e r o r i g i n a l o r t h i r d p a r t y ) n a m e d in t h e Asbestos Litigation (hereinafter collectively referred to as "Pittsburgh Asbestos Litigation Counsel") copies of any or all of the Index Cards (the "Index Cards")identified as Exhibit THREE to the May 17, 1985 deposition cf Dr. Braun. In order to minimize duplication burdens, any Pittsburgh Asbestos Litigation Counsel requesting immediate copies of any of the Index Cards shall \ direct their request, in written form on counsel's l e t t e r h e a d , to Dr. Braun at the IHF within thirty (30) days from entry of this Order. The letter shall indicate the number of complete sets of Index Cards requested or which individual Index Cards are re quested and the party or parties which said counsel represents. 2. T H A T the I n d e x C a r d s r e p r o d u c e d by the I H F s h a l l be retained in the actual custody of the Pittsburgh Asbestos Liti gation Counsel which requested copies of the Index Cards, except as provided in paragraph THREE herein. 3. T H A T th e I n d e x C a r d s (or a n y i n f o r m a t i o n c o n t a i n e d therein) may not be divulged or disseminated by Counsel which fill be o b t a i n i n g the Index Cards from the IHF except in :onnection with litigation proceedings, such as to other counsel n the United States of A m erica who are involved in asbestos itigation lawsuits or claims now pending or which may be pending i the various courts and/or agencies of the United States of lerica or any of its states, pursuant to formal requests for oduction of documents or written interrogatories, or to written quest on counsel's letterhead in lieu of said formal requests, to proceedings referred to in this paragraph. 4. A c o p y of t h i s P r o t e c t i v e O r d e r s h a l l a c c o m p a n y an y production or other dissemination of the Index Cards with respect to matters referred to in paragraph THREE. 5 . - The IHF shall be reimbursed fifty cents ($0.50) a page for copying each of the Index Cards, which are requested by P i t t s b u r g h Asbestos Litigation Counsel. 6. S h o u l d counsel for the p l a i n t i f f s or d e f e n d a n t s notice the deposition of Dr. Braun on matters directly relating to the Index Cards, or as to other IHF matters, said counsel shall reimburse the IHF the total sum of Three Hundred Dollars ($300.00) for the time spent by Dr. Braun in reviewing the documents for the deposition and for the actual deposition itself, as well as for any desired pre-deposition conference with Dr. Braun. 7. T H A T the District Court of the United States for the Western District of Pennsylvania will retain jurisdiction over all matters relating to this Protective Order. United States District Judge SP E R R Y GYROSCOPE CO. DIV. O F SPERRY -RA N D CORP. G R EA T NECK, NY JO IN ED : 3/5/56 RESIGNED: 4/1/59 DR. R. J . MURRAY, MED. DIR. SPRAY CRAFT CORP. 2508 CONEY ISLAND AVE. BRO O KLYN , NY 11223 JO IN ED : 11/20/70 RESIGN ED: 12/31/73 H ER BER T L. LEVINE, PRES. THE SOLVAY PROCESS CO. 61 BROADW AY, NEW YO RK, NY JO IN ED : 5/21/35 RESIGNED: 4/6/44 R. H. PERK IN S, DIR. OF OPERATIONS