Document oeMD9q6Vz4xwyEXdwb9zwQdaX

FILE NAME Industrial Hygiene Foundation IHF DATE 1986 DOC IHF026 DOCUMENT DESCRIPTION Protective Order with Memo to BC RE IHF Member Registration Cards . 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 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 in various asbestos and 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 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 Robert L. Jennings Jr. 8 Ceeammcpthien IN THE DISTRICT COURT OP THE FOR THE DISTRICT THE UNITED UNITED STATES STATES IN RE: ASBESTOS ) LITIGATION ) ) Miscellaneous 8482 8482 eT Tm) AND NOW, this 12 AND AND by INDUSTRIAL " Motion DANIEL C. B HEALTH of March FOUNDATION FOUNDATION - Dr. 1986 upon INC the Braun motion the IHF and pursuant to Rules and to asserted that the Index Cards asserted contain sensitive referred Local of Civil Procedure 28 Rule , the IHpF its ' this information information IT HEREBY prevent undue dissemination of ORDERED BA a 3 _ eat cc nf Se siS the Index Cards Cards Index Cards Dr. Braun. May deposition 8. nae We NT ANCAME ae Cards from the TIHp counsel counsel Asbestos Litigation (hereinafter Asbestos Litigation collectively referred to as hereinafter collectively copies any or all of of the Index Cards the Cards Index cf Dr, Braun 1985 deposition Pittsburgh Asbestos Litigation Counsel # Fa = = will be obtaining the Index Cards from the IHP counsel counsel for matters referred The referred IHF to paragraph shall the reimbursed fifty cents Index Cards which requested copying each Index Counsel 0.50 page Page requested by plaintiffs Pittsburgh Asbestos Counsel for the the Should defendants defendants notice counsel Dr. Braun on the deposition Or matters directly relating the the as to other IHF matters said counsel shall Index the IHF the total Sum of Three Hundred Dollars reimburse for the time spent by Dr. Braun in reviewing 300.00 for the the and deposition for the documents as well actual deposition as for any desired deposition conference with 7. Western THAT the District Court District of Pennsylvania of the United States for the will retain jurisdiction over United States District Judge ea amr TUPI