Document XOOYZ3DRYL4z1xkRj3LX3rJo4

FILE NAME: WR Grace (WRG) DATE: June 30, 1977 DOC#: WRG 175 DOCUMENT DESCRIPTION: 1977 Memo to HC Duecker from RH Locke regarding California Laboratories 02/12/1996 15:02 6173564837 SSHC PAGE 06 GRACE TO^ H. C. Duecker F3CM: R. H. Locks CZ ; 0. M. Favoflrn / S , 5, Wood W. F. McCord R. M- Vining 3. R- Williams x'1 ' \ .V C d n irp u c fio n d e d u c t * Divi*i<art C61C:C-3 DATS: SUBJECT: June 30, 1977 Caliromi:t Laboratories RE: RHL t o HCIJ 20 J u n e 77 Same S u b j e c t 1. Concerning the submittal of MK Samples to one or more California labs for outside analysis, I understand we are confident that the results will be such ve can use then la confidence with the Cali fornia Department of Health- However, the possibility exists the results might also prove unusable, for reasons of procedural, saag>llag ,or other errors. I believe we can think of some past outside laboratory resules which wera either erroneous at the time or misleading later- This is not a big risk; it Is a little risk. Rut, its there. The results of these laboratory analyses ve will obtain - erroneous or accurate - will be subject to discovery in any subsequent relevant litigation, and we are talking about ME in California. 4 I believe, however, that If a client were to ask an attorney to under take such an investigation of the eubjeet area, he on his own judgement might aak laboratories to make such analyses. Ths resulting data would probably' be held to within the attorney: client relationship, and would not be discoverable unless the client agreed to waive the relationship. .. While the above dlaowssleo concerns the quantitative oalysia ample we've talked shout It should be noted that the California Department of^Health made Chair d a d a i o n basad on-airborne eoneenrr*- t, not quantitative la the Instance of the California 02/12/96 15:03 TX/RX NO.4725 P.006