Document ppRdJOO5z3mbQ5nRKDR5vmJbX

AL-1167 -&<> A TIA FEDERAL EXPRESS October 12, 1990 Mr. Robert M. James Aluminum Company of America 1501 Alcoa Building Pittsburgh, Pennsylvania 15219 Re: Asbestos Litigation Dear Mr. James: Certain of Eastman Kodak Company1s former employees have commenced lawsuits httre in RGcKester against OwensCorning FiberglasT and other asbestos manufacturer! claiming that they sustained asbestosis, mesothelioma and other injuries after coming into contact with asbestos while on the job at Kodak. Owens-Corning Fiberglas and certain other asbestos manufacturers are taking the position that any injuries sustained by these plaintiffs was the fault of Kodak in allegedly not providing the employees with a safe place to work. Owens-Coming Fiberglas has actually brought Kodak into one such lawsuit as a third-party defendant .aria in other lawsuits is seeking to identify documents and witnesses to support this claim. Of course, Kodak, vigorously disputes these allegations by the manufacturers and believes that it was the manufacturers' failure to warn adequately of the hazards of~ asbestos which contributed to the workers' injuries. I am writing now to alert you that your names have surface4 during the course of discovery 'l'n this litigation and to advise~~you that you may be contacted by a representative of Owens-Corning Fiberglas, another asbestos manufacturer or an attorney or investigator acting on their behalf. You should know that if someone does contact you, you have no obligation to speak with them. What you do say can be recorded or noted and later used in the course of an action against Kodak. It is also possible that statements can be taken out of context and used to contradict you if you should play a role in the litigation at a later date. While it is your decision whether to talk with these representatives, you should be aware of the implications connected with doing so. EASTMAN KODAK COMPANY LEGAL DEPARTMENT 343 STATE STREET ROCHESTER, NEW YORK 146500207 370086 0001 AL-1167 October 12, 1990--2 Kodak's outside counsel, Brian flora-, or I will be in touch with you in the near future to arrange a conference call or a meeting to discuss your recollections in detail. In the meantime, if you are approached, please contact Brian (716-546-8000) or myself (716-724-2479). I am looking forward to speaking with you at that time. JMQ:rv (716) 724-2479 James M. Quinn cc: Brian M. Zorn, Esq. 370086 0002