Document OQy9rkRR1wQB8barX56ZRgOj

FILE NAME: National Safety Council (NSC) DATE: 1984 Apr 3 DOC#: NSC177 DOCUMENT DESCRIPTION: Legal - Notice to Take Deposition of Phillip Schmidt I UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY AT LOUISVILLE J A M E S C. B A G G E R L Y ) ) Plaintiff ) ) V. ) ) S E A B O A R D S Y S T E M S R A I L R O A D I N C ., ) et al. ) ) Defendant ) 5 ?; it- K. ,-r .at * NOTICE OF DEPOSITION CIVIL ACTION NO. C-83-1190 L-B .. . NOTICE TO TAKE DEPOSITION You are hereby notified that, pursuant to the terms and provisions of Rule 30 of the Federal Rules of Civil Procedure, on April 17, 1984, beginning at 10:00 a.m. at the Hotel Continental, 505 North Michigan Avenue, Chicago, Illinois, the plaintiff will take the deposition of Phillip Schmidt, Chief Librarian, National Safety Council, 444 N. Michigan Avenue, Chicago, Illinois. This deposition is being taken in a number of jurisdictions as shown on the attached sheet. It is being taken pursuant to the Federal Rules of Civil Procedure for all purposes allowed by those rules, including -# - T use at trial. In cases which this deposition is noticed that' are pending ^ in State Courts or a Federal Court with special rules, this deposition will be conducted pursuant to those rules if not inconsistent with the Federal rules. If, for any reason, the deposition cannot be taken in compliance with all rules, a second deposition will be taken specifically for that Court at the same time and place listed above. The purpose of this deposition is to have Mr. Schmidt produce annals of the National Safety Council and other publications present in the National Safety Council library and to authenticate the same materials. The Plaintiff further intends to inquire of the witness any knowledge he has concerning the membership of the National Safety Council. To the knowledge of the undersigned, Mr. Schmidt has never been deposed in asbestos litigation. This deposition is expected to last only four hours but will continue from day to day until completed. You are invited to attend and participate. I I Respectfully submitted, BLATT & FALES P. 0. Box 365 JONES & GRANGER P. 0. Box'' 4340 HoustQiw yTexaA/ 7/ ^J. Weldon Granger NOTICE OF DEPOSITION OF PHILLIP SCHMIDT SERVED IN THE FOLLOWING JURISDICTIONS In Re: Asbestos Cases (USDC - South Carolina) (Insulator, Shipworker, Plantworker) USDC, District of Pennsylvania Lechner v. Conrail, et al C/A No. 82-2301, et al USDC, District of South Dakota, Southern Division Burger v. Chicago Northwestern Transportation Co. C/A No. 83-4118 USDC, Western District of Kentucky, Louisville Division Greenwell v. Seaboard Systems Railroad, Inc. C/A No. 83-0541-L-A USDC, Eastern District of Tennessee Brown v. Southern Railway Company C/A No. 1-83-280 USDC, District of Utah, Central Division Tea v.. Dhvf &;-Rio Grande Westeri Railroad Co. . ..* C/A No. C82.-1174(C)-- USDC, District of Nebraska Carroll v. Union Pacific Railroad Co. C/A No. 83-0-615 USDC, Southern District of West Virginia at Huntington Judd v. The Chesapeake & Ohio Railway Co. C/A No. 83-3035 USDC, Eastern District of Pennsylvania Scholl v. Conrail and The Reading Co. C/A No. 82-1685 \ Circuit Court, Twentieth Judicial Circuit, St. Clair County, Pease v. Illinois Central Gulf Railroad Co. C/A No. 82-L-1012 Illinois USDC, Western District of Virginia, Roanoke Division Palmer v. Norfolk & Western Railway Co. C/A No. 83-0282-R USDC, District of Maryland Davis v. Western Maryland Railway Co., et al. C/A No. N-83-4 USDC, District of Maryland Yergan v. The Baltimore & Ohio Railroad Co. C/A No. H-83-1231 USDC, Middle District of Florida, Jacksonville Division Grimsley v. Seaboard System Railroad, Inc. C/A No. 83-880-Civ-J-l2 USDC, Central District of California at Los Angeles W a l s h v. S o u t h e r n P a c i f i c Trans. Co. C/A No. CV-83-0751 (WMB) I CERTIFICATE OF MAILING This will certify that the undersigned today placed in the United States Mail, Postage Prepaid, copies of the within NOTICE TO TAKE DEPOSITION to the below listed counsel: Kenneth J. Tuggle BROWN, TODD & HEYBURN 16th Floor, Citizens Plaza Louisville, KY. 40202 Attorneys for Raymark Steven F. Schuster OGDEN, ROBERTSON & MARSHALL 1200 One Riverfront Plaza Louisville, KY. 40270 Attorneys for Seaboard Robert C . Ewald WYATT, TYRANT & C & B S . ? Citizens Plaza Louisville, KY. 40202 s - ' Attorneys 'for Owens-Corning Stuart E. Alexander TILFORD, DOBBINS, ALEXANDER & BUCKAWAY 600 West Main Street Lousiville, KY. 40202 Attorneys for Nicolet Edward H. Stopher BOEHL, STOPHER, GRAVES & DEINDOERFER Suite 2300 One Riverfront Plaza Louisville, KY. 40202 Attorneys for Celotex John David Cole COLE, HARNES & BRODERICK P. 0. Box 1869 Bowling Greene, KY. 42101 Attorneys for Keene Randall A. Jordan NIGHTINGALE, LILES, DENNARD, P. 0. Box 1496 Brunswick, GA. 31521 CALDWELL & JORDAN Attorneys for Seaboard F. Saunders Aldridge Savannah Bank Building Savannah, GA. 31412 Attorney for Seaboard i