Document wDQvbnn8ByEKV0NjmbrKV18Y6
JAMES M. HUGHES, Ph.D. DIRECT DIAL: 843-216-9133 FAX: 843-216-9440 E-MAIL: jhughes@nmlrp.com
LAW OFFICES
Ness, Motley, Loadholt, Richardson & Poole
PROFESSIONAL ASSOCIATION
28 BRIDGESIDE BOULEVARD POST OFFICE BOX 1792
MT, PLEASANT, SOUTH CAROLINA 29465 843-216-9000 FAX it 843-216*9450 E-MAIL: nmlrp@nmlrp,com
January 22, 2001
OTHER OFFICES: CHARLESTON, SOUTH CAROLINA
BARNWELL, SOUTH CAROLINA PROVIDENCE, RHODE ISLAND NEW ORLEANS, LOUISIANA RALEIGH, NORTH CAROLINA
Bert Cappel, Esquire Billy Baggett, Jr., Esquire Baggett, McCall, Burgess, & Watson 1130 Python Street Lake Charles, LA 70601
Re: Record of McKinley Respirator Protection
Dear Bert and Billy:
Enclosed are some log in sheets I had copied when I was reviewing documents at Jones Day. These are the sign in sheets that I could find from 1975 through 1984 of whether Mr. McKinley worked in a regulated or non-regulated area and whether or not he wore respirator protection. The year 1977 is missing. For the other years, however, out of 18 times he logged in as having worked in a regulated area, 14 of those times he did not wear breathing protection. This goes directly against Harlan Jewett's claim at his 30(B)(5) deposition that Mr. McKinley almost always wore breathing protection. Mr. Jewett also stated that no employee was ever disciplined for not wearing breathing protection.
Also enclosed is a copy of Harlan Jewett's deposition with Exhibits.
Sincerely
JMH/drl Enclosures
JAMES M. HUGHES