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