Document peLd3mG4myeERR2zNzVmmxb0D

FILE NAME Manville JMA DATE 1982 Apr 2 DOC JMA076 DOCUMENT DESCRIPTION Letter between Lawfirms RE Deposition of B.J. Biggs & Location of AIA Minutes with BC Notes Policy Asbestos , The is our rep AIA ance ance Feb 1980 There people are no J presently serving En AIA formale formale committees her a committees complete complete officeJem WALL STREET NEW YORK N. Y. 10006 212 785-1000 CABLE LABELLUM TELEX 1286/876 128166/687665 5 128166/687665 Cadwalader Wickersham Taft & A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 1333 New HampshirAvee.N.W Washington DC 20036 Telephone 202 293-6300 PALM BEACH FLA33460 306 855-9800 TWX 510-962-7628 TWX 710-822-1034 RAPIFAX 202 293-62390 XEROX 202 387-1417 April 2 1982 RECEIVED RECEIVED RECEIVED RECEIVED RECIVED RECEIVED RECEIVED RECEIVED APR 5 1982 SEAWELL DALTON LUCHES & TIMMIS ATTORNEYS Robert R. Hatten Esquire 14749 Warwick Boulevard Newport News Virginia 23602 Dear Mr. Hatten Re Asbestos Cases 77-1 Deposition of B.J. Pigg At the deposition of B. J. Pigg Executive Director Asbestos Information Association America AIA you requested copies of the minutes of all AIA Annual Meetings Board of Directors Meetings Executive Committee Meetings and Technical Committee Meetings The deposition transcript will record my objection to the timing of your request I explained that counsel would have to go through hundreds of papes of minutes representing over a year period to identify and redact any Attorney and Work Product privileged material I also informed you that AIA budgetary material was irrelevant to any issue in your cases nor was it likely to lead to the discovery of relevant or admissible evidence The long process of reviewing the minutes is now complete Attached at tab 1 is a copy of all AIA Annual Meeting Minutes Attached at tabs 2 through 4 respectively are the minutes of the Board Executive Committee and Technical Committee The appropriate redactions have been made and are clear from the copies provided - Robert R. Hatten April 2 1982 Page Two Esquire I have been informed by the Asbestos International Association that they do not object to the release of their Recommended Code of Prictice entitled Repair and Removal of Asbestos Insulation I am forwarding a copy of that document to the Court Reporter and to you under separate cover A bill for duplication expenses will be included with that document Attachments JAA mw Sincerely yours Atabana Joseph Joseph A. Artabane Counsel for Deponent B. J. Pigg and AIA