Document rxGgXk1q6LQb0Y1Jo7XMKg840

LAW O F F I C E S ALBERT HOUCK 5 W. MARKET ST. LEW ISTOW N , PENNA. TELEPHONE 7SI July 22, 1964 Dr. Robert A. Kehoe University of Cincinnati Department of Preventive Medicine and Industrial Health Cincinnati 19, Ohio In re: James F. Noerr and wife Dear Dr. Kehoe: The Sitkin's Smelting Company and the insurer have failed to make any amicable move so we have instituted a suit in equity looking toward an injunction and damages. I propose to institute discovery proceedings against the Smelting Company and have prepared a draft of questions to elicit from them information that might help our case. I am enclosing a copy of the proposed questions which are to be answered in writing, and then if necessary to be followed by an oral examination. It would be appreciated if you would read these ques tions and give me your suggestions of any changes or addition al matter which you would like to know to help you in support ing your opinion. Please feel free to make suggestions. AH:bc Enc. N5332