Document v6d2z9M63gwere60vogBJM1M9
A. J. Bronsky Direct: 314-242-5324 Fax: 314-242-5524 aj bronsky@bjpc.com
ROW IV AMES
Law Firm
September 2, 2003
O'Cp-f oJB Ckies
SzSi^J- -to
^ | `A 103 - '-[-33
1010 Market Street, 20th Floor St. Louis, Missouri 63101-2000
Phone 314-421-3400 www.brownjames.com
Mr. Randy Bono THE SIMMONS FIRM, LLC Attorneys at Law 707 Berkshire Blvd. East Alton, Illinois 62024
Re: Madison County Asbestos Litigation
Dear Randy:
I am in receipt of your letter of August 21, 2003. As I have told you previously, and as is apparent from Reichhold's prior responses to your discovery request, Reichhold sold its phenolic molding compound business in the mid 1980's and has very little in the way of records or witnesses with respect to the brief period when Reichhold was in that business.
I am enclosing a complete copy of the deposition of Pat McKelvey taken on March 27, 1996, along with the exhibits to that deposition. I am also enclosing copies of the documents Reichhold referred to in its Answers to Interrogatories. These are bates stamped 000171 through 000938. This production should render the Motion to Compel filed by Rosiland Robertson of your office moot. As you may or may not know, I previously provided Rosiland a copy of the Reichhold Molding Compound Data Book (bates stamped 0000001 through 0000170) when she had requested it. Included within the material is the Records Retention Schedule of Reichhold Chemicals, Inc., effective August 2, 1989, which I think will help you to understand why Reichhold has very few records.
As to the witnesses you have indicated you wish to depose, only Pat McKelvey is presently a Reichhold employee. Once you have reviewed his deposition, please let me know if you still wish to depose him and I will obtain some dates for his deposition. Mr. McKelvey works and resides in North Carolina.
Five of the people you mentioned in your letter were never employees of Reichhold and therefore, Reichhold has absolutely no information on their current whereabouts. Those people are Dr. Steven Sivak, Dr. Richard McBumey, Warren Towns, George Weiss, and Dr. Arthur Rohl.
The remaining ten people are either retired or ex-employees. Reichhold is searching personnel and pension records to determine if any of these persons are deceased, as well as their last known addresses. I will provide you with that information when it becomes available.
St. Louis, Missouri Kansas City, Missouri Belleville, Illinois * Springfield, Missouri
A 7t EXHIBIT \L& Dpnn*nt/lf)0.ctkfi
WWW.DE30BOOK.COM
Mr. Randy Bono Re: Madison County Asbestos Litigation September 2, 2003 Page 2
However, given the length of time since Reichhold was in the molding compound business, it may take some time to locate these witnesses and ascertain their knowledge and willingness to cooperate in the discovery process. I expect to provide you with an update in that regard in the next week or so.
I look forward to hearing from you. Very truly yours,
AJB:ml/7518338 Enclosures cc: Ms. Rosiland Robertson
, " 04.-OS'-01 13:21 FAX 860 547 0447
y
-
THE HaR'ITukD
4)00
i/>
"o
9
a
Hsi
4
APR-05-2003 13:4.:
P4.2 Sd-? 7447
000171
a
I e os
p n:
M *i >
U1 10
r.i.i oovj \j'ki
int nAiuruhi/
t: 3
e
3 bo-
5
X
!I H u. 9O
X
*1
.9
i
2* 3*
w, c c8 ig <0
J O
*S$| sJsaf * \&t b*5 >*; th/i '
88 y> w> UV*U>^
'rtMtT
<>r p>r rorcj**:* SSI;
F 1W', >l:vh.*?
&
:-v.i
>.,, -v I
.fv^| ^=4;,
. . " ` /j ry v <
-.y^i
Hsi ftPR-05-2001 13--43
860 547 3447
000172
UUJ
P.03
OtwnHed on: 04/05/2001
* U4*`U3* U1
x o +. *, r n.v
v#
VI'W
S^C
s
CL
3
O
2
3
S
T3
2
_c
*
-c
2<0 1CL
T>
1VI C j 2a
o
3
Q
9
<
o> Jo
u3 X
Ul
o> E * 2C (9 3o
Xo E IT
o eg
_J U
o
X
uX
s
?I
a c
o
>
c
E
o(S
'c
Q
E *co
<-> I
a
of o
of of
*r'<:
l&
&
I
3. E8
$ 5
$
jr^F
to
o
O0}
I to
i
rtf
o
tv' o?= ?S
tl:
O!.
APR-05-200
8S0 547 3447
000174
1/7
o
V 05
a.
a
o
3
Co
3 e o P.05
04' 05/01 14:^4 1 A A. Bll 34 I 4-14 /
i Mt, HAK1MJKJJ
5
1B
C
HO
ity uuo
15 I
u
O JS
-oJ
X
Xy
o
_5--5 ^^o"
Uj
Sffi H
I
c3
5o1
j 5
HiE
a
c
s g
8PR-05-2B01 13:43
860 S^7 -t.aa'?
000175
c