Document rM3NozZXJ0w2B7B305LY5Jya
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INTRA-COMPANY CaRBSPONDENCE
Clevelandr e c e iv e r s l o c a t io s TO (INDIVIDUALS NAME? D. Go SaTVSdl
REFER TO LETTER OF
DATE June 14, 1978
Cof.feyvi 11 e
SENDERS LOCATION AND DEPARTMENT
Safety s u bj ec t Deposition of James Douglas
Case, Coffeyville #30 Plant
Dave, this is to confirm telephone conversation with you this morning, June 14, 1978.
Request that arrangements be made to make a deposition on the James Douglas case which has been in the hands of Liberty Mutual for approxi mately a year. Also, another case which is very similar in nature requires a deposition and this person is
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In talking to the lawyer for Liberty Mutual, Mr. Jack Lively, yesterday, he stated that they are really not in a big hurry to do this, but he did state that we should prepare this deposition In order to be ready. Mr. Lively said that late July or early August would be the earliest that he could meet with you; therefore, it may be wise to give him a call before setting up your date to come to Coffeyville.
Contact:
Mr. Jack L. Lively, Attorney 815 Union Street Coffeyville, KS 67337
316 + 251-1300
You asked about records there in Cleveland. Information may be obtained at Mr. Jack Kull's office, and the person to contact would be Mr. Tom Locker.
Please call myself or Bill Howard if you need any other information.
MRU sew
cc; J. R. Aid W. 0. Howard
Safety Director
N40393
0007-SWP-005 806291
r ec eiv ed
jtjw 21 1978
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