Document NeDjKMGqw2JqQZ1QpNoy1rgzR

FILE NAME: Asbestos in Hair Dryers (HD) DATE: 1986 DOC#: HD038 DOCUMENT DESCRIPTION: Copy of the Former Registration Cards of the IHF, well as a Protective Order Entered by the US District Court THOMAS W. HENDERSON THEODORE GOLDBERG JOEL PERSKY ANTONIO D. PYLE ROBERT L. JENNINGS, JR. THOMAS W. WHITE ROBERT ALAN KREBS H E N D E R S O N & G O L D B E R G , 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 m 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, RUJr :kjk Enclosures PYRO METAL FINISHERS, INC. PYRENE MFG. CO. 10 EM PIRE S T .. NEWARK 12, NJ JOINED: 5/16/41 RESIGNED: 12/3/56 RL.AEL.PEHCKBEALTMCHA,NVNP, -PPRYERSE. N E - C-O -TW O DIV. PULLMAN STANDARD P . O. Box 71 B u tle r, P a . 16001 Joined: 1/1940 Resigned: Joined: 7/73 Resigned: 6/79 7/1965 Richard S. Jones, General M gr. PROCTOR & GAMBLE CO. IVORYDALE TECHNICAL CENTER CINCINNATI, OHIO 45217 JOINED: 10/19/37 RESIGNED: 9/7/65 R. J. BEAMAN, INDUSTRIAL HYGIENIST 132 IN THE DISTRICT CC.LRT OF THE FOR THE WESTERN UNITED STATES d i s t r i c t OF PENNSYLVANIA IN RF: ASBESTOS LITIGATION ! Miscellaneous No. 8482 a n d n o w , this / ,, day of March, 1 9 8 $, upon mmoutuioonn ((tthhee . bY INDUSTRIAL " foundation, INC. (th. , HF, and its President, DANIEL C. BRAUN, m .D. ("Dr. Braun") 0 ' u r - Braun ), pursuant to a "d 45 f the F6deral RUl6S v i l Procedure, 28 as U h e 'R U l e S ">' ^ t 0 * * 1 -I. 4 , the IHP having ^ s e r t e d that the Index Cards referred to in Paragraph Two of its of tTe COntain S e n S i t i V e ' Pr0prlet" ^ information and that some 6 1 n f rmat ion c o n t a i n e d t h e rein i = . , h e r e i n is not r e l e v a n t to the asbestos litigation identified at K . ' (the - a k 3 Ve Miscellaneus Number _ Sb6StOS Lit igation"), and the Court subseguently deter_ r : ; at a 1 1 the inf0rmation COntained therein is relevant in e - . . t o . L i t i g a t i o n but that the i h p is e n t i t l e d to an appropriate Protective Order 1-0 fh. . e er t0 Pre',ent ""due dissemination of this information, IT iS HEREBY ORDERED: "" ... P tiffs, as well as to lenal > LU -L e g a l c o u n s e l in P i XT ., , ,, .n Pittsburgh for anv of the defendants (either original or third party) named in the A s b e s ttooss Lr ^4 +.lgation ( h e r e . "PlttSbUr9h Asb t o s hitigation J the -- -- (t h e , ndex c; C011e c t i v e ly referred to ,, ~ > p u . of a,,y or all w thS "<* duplication 8 5 deposition of Dr burdo Braun- der>s, any Pittsbur w EXbib*t TM * E E to In Drd t0 minin>ize --- -- -- -- ate copies T . ^ - g u e s t , in writte/ j - - .** Counsel shall D r - Braun at th ^ n c Unsel's ]eft. , Order Th . * " W t h i " thi" y (3 0 ) days fro " ^ Tb* letter shall indicate rm entry of this " C d s requested or ,,hich i,,d . ' ^ C"Pl of ~ - - party or parties ,, h i c T ^ * * " ^ - - 2retained Sd THAT `he Index Car in .. ln the actual custody Said " - 1 reproduced bv th* of th ' represents, r S h a ^ bd 9ab^ " counsel which requested J " as provided in oopies of the index r a " P a r a p h t h r EE herein dS' ex P t 3tha- , T H A T the Index Ca r d s (o may not be divuiged or J ' any i n f e c t i o n contained 1,111 b9 obtaining the i,,d ex Catd'" " ln#t'd * CU"S61 " hich -- tion with lltigatiQn *' trob the IBF except ^ the U " U a d states of A m e r i ca J " ' " ` th- ~ 1 ~claims are in-- - ln the VariOUS ctrts and/or age ' 109 ^ " Y ba Pendi"9 ^ riba ~ of its stabe Onited states j Production of documents or w r U t e n - q u e s t s for e,UeSt " COUb^ l ' s letterhead i,, a rr9atr i 6 S ' to written as t 0 Proceedings referred to ln t h . f f TM ^ requests, to m this paragraph. 4 ' A c py of t h is P r o t e c t i v e Qrd production or other dissemination of th ' -- Pany any to matters referred to in d 6 ea t 0 ln Paragraph t h r e e . " U h resPact .`-.irjrL- "pu`"""-- The iar shali be reimbursed f r C M i n =>> of the index ca r d s h ^ Sburgh Asbestos c i t a t i o n Counsel ' o r . Braun on m a t t e r s d i r e c t s <S'50) 3 ^ j . Index Cards, or as tn o t+-hk e r i h f m a t t e r s s a iYd relatln9 to the reimburse the I,,F the C Unsel shall c total sum of tu ,S30 - 0^ `or the time spent by D r . Bra " , D11*r* d o c u m e n t s for the d e p o s i t i o n and for t l T ^ r`3V1<!''ln9 i t M l f ' * - U Dr. Braun. as for any desired ^ dePS U i o " depositlO" conference with 7 - t h a t the District.court of the u,, `t d Western District of all matters relatina 9 Pen , Penr>sylvania w i n to tht0 thls Protective / * retain order. ^ States for the . Jurisdiction over United states District Judge