Document o9ZDr4E5Joj2mr210QxxZpvnD
Privileged & Confidential To: Joseph Huber From: Bill McLellan
PLAINTIFF'S EXHIBIT CIIR-201
May 15, 1999
Asbestos Litigation
The Company has over 1,200 lawsuits pending relating to claims brought on behalf of former auto mechanics who claim exposure to asbestos in connection with performing vehicle repairs on brakes and clutches that contained asbestos.
Lawyers representing the plaintiffs have served discovery requests to the Company that seek information concerning:
Brake specifications and performance standards. Bf?PP M<s;/*/e/2.>^ (Co^P.)
History of brake lining usage and development.
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The identity of products that contained asbestos. /-/yeey/e- c7-
The brand or trade name of the product. Po gecoo
The date the products were placed on the market, a/p BscePO
A description of the physical or chemical composition of the products. See MS
The dates the products were removed from the market and the reasons for their
removal. coPfi-
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A description of the appearance of the products.
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A detailed description of the intended use of the products!) %erAu
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The last year that the Company sold asbestos-containing products,
Documents generated relating to the design, preparation, or introduction into
the market of products that contained asbestos. CoPP.
Testing conducted to determine potential health hazards. d/P-
Design changes or modifications as a result of testing.
Materials generated containing warnings about possible injury resulting from
asbestos. --
Books, pamphlets, etc. indicating that asbestos fibers may be hazardous to
human health. ---
Membership in trade organizations that published documents relating to
asbestos hazards. --
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Present use of asbestos in products. a6 BPjBz/c'TJ cpa/tP/M /)S&ST0S (fir yp
Whether asbestos-containing products can be used without liberating asbestos fibers into the air. -- Dust count testing or studies.
Research into products that did not contain asbestos to replace asbestoscontaining products. --
The manufacture or sale of products which could substitute for asbestoscontaining products.-----
While information concerning many of the items identified above may not be available from Detroit Axle, we have a duty to inquire as to all of these items. Your assistance in determining whether any such documents exist would be much appreciated. I recommend that you forward this message to individuals that potentially could have responsive documents and ask them to provide the documents to you in a folder. Those who do not have documents should respond with an E-mail message which reflects that, after reviewing their files, no duch documents could be found. Thanks for your help.
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