Document zQvYxoeDjaV7J9mXxVK96w4Qm

LAWRENCE MADEKSHO ATTORNEY A COUNSELLOR AT LAW GULFWAY PLAZA BLDG. 8320 GULF FREEWAY SUITE 218 HOUSTON. TEXAS 77087 f December 8, 1987 641-0291 Mr. Danny Van Winkle Vinson & Elkins Attorneys at Law 3300 First City Tower 1001 Fannin Houston, Texas 77002-6760 Re: William R. Chattman vs. Owens-Coming Fiberglas et al Civil Action File No. H-37-1007 - In the U. S. District ? Court for the Southern District of Texas - Houston Division Dear Mr. Van Winkle: Enclosed herewith please find Plaintiff*s Request for Production directed to the Bendix Corporation. By copy hereof, a copy of same is being forwarded to all interested counsel of record. I remain, Very truly yours, Lawrenci LM: em Enclosure: RFP CERTIFIED MAIL - R.R.R. #252420 cc: Mr. Robert E. Ballard All interested counsel of record .deksho N- 252420 RECEIPT FOR CERTIFIED MAIL NO INSURANCE COVERAGE PROVIDED-- ' NOT FOR INTERNATIONAL MAIL (See Reverse) 9i6I Jdv 'OOSG UUOJ Sd PLAINTIFF'S ___ EXHIBIT v P S founttll.Jutyim SBtBSk Complete Runs 1.2,3. and 4. Add your address In the "RETURN TO" space on reverse. (CONSULT POSTMASTER FOR FEES) 1. TI* fo&wtog srvfc* Is requested (efteck ons). S^^wfwmaMdatiOeflywed............... -t showlajWwn.daN.indaddress otdoBvtry.. 2. O RESTwcraoaivffly.......................... :(ntt mma* mmn*a aargrt & mw t>/Mv*nct0JW./ ______ t ............ t TOTAL TF . registered insured BCEflTmai . Ocoo 0 ARTICLE NUMBER EXPRESS MAE (Ahnys ettrie ilyMtere sf addressee or ipM) Uom (eeahee tne artde oneriM dOovt. SI6NATURE Mdr*ts OAtttortM agM fgjg^g^EKITIS- uite 3300 First C*X 1001 Fannin_______ fidm 6l a ^UAftETOOBJVSftEMBE:] a 7n. amsrtwt mus ------- RETURN RECEIPT c IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION WILLIAM R. CHATTMAN VS. OWENS-CORNING FIBERGLAS CORPORATION ET AL CIVIL ACTION FILE NO. H-87-1007 REQUEST FOR PRODUCTION TO: BENDIX CORPORATION and its attorney of record# Mr. Danny Van Winkle, Vinson & Elkins, 3300 First City Tower, 1001 Fannin, Houston, Texas 77002-6760. Pursuant to Rule 34 of the Federal Rules of Civil Procedure, the Plaintiff requests this Defendant, Bendix Corpora tion, to produce for inspection and/or copying by the Plaintiff's attorney during regular business hours, Monday through Friday, in Houston, Texas, all documentation in possession of this Defendant, or subject to its control, concerning its items listed below. Notice is given that the original of this Request is not being filed with the District Clerk pursuant to the Local Rules of Civil Procedure. The subjects, items, and categories covered by this Request are as follows: 1. The Canadian Health Department report of May 30, 1949, wherein asbestos or asbestos-related diseases was discussed in whole or in part. f 2. Copies of all correspondence from Mr. E. A. Martin, director of purchases, to Canadian Johns Manville Company, Ltd., Johns Manville and other suppliers of asbestos to this Defendant wherein asbestos, asbestos products, asbestos diseases, or the consequences of asbestos exposure are discussed in whole or in part. 3. Copies of all corporate memos prepared by Mr. E. A. Martin, director of purchases, wherein asbestos-related diseases are discussed in whole or in part. 4. Copies of all memos, correspondence, and reports of this Defendant's safety directors wherein asbestos-related dis eases or the health effects of asbestos exposure are discussed in whole or in part. 5. Copies of this Defendant's annual reports for the years 1950 to 1975. 6. Copies of all of this Defendant's record retention polocies. 7. A list of the names and addresses of any and all custodians of this Defendant's corporate records regarding asbestos or asbestos litigation. 8. A complete listing of all names of individuals who participated in responding to this Request for Production, their address, title and employer. 9. Copies of all reports to or prepared for this Defendant by its own medical doctors or consultants, or outside medical -2- ( consultants, wherein asbestos diseases, or the diagnosing of asbestos diseases is discussed in whole or in part. This Re quest is for reports prepared specifically for Bendix Corporation and does not relate to the individual medical reports prepared on specific claimants who have filed suit against this Defendant. This Request is for the period of time from 1970 to the present time. 10. The complete files of this Defendant's own employees who have filed claims or lawsuits against this Defendant for asbestos-related diseases between the years 1955 and 1975. This Request is for this Defendant's own employees working in the manu facturing facilities of this Defendant. 11. Complete copies of all documents furnished to ICF, Incorporated since 1985 regarding the survey of asbestos process ors. 12. A complete copy of this Defendant's products catalogued for the year 1950, 1955, 1960, 1965, 1970, 1975, 1980, and 1985. 13. A complete list of names, addresses, and employer of all persons who, between the years 1966 to the present time, have parcipated or have knowledge of, the shredding of documents that were in the custody or control of this Defendant. This Request is addressed to documents which relate in whole or in part to asbestos or asbestos-related diseases. 14. A complete listing of all trade associations to which this Defendant was a member between the years 1940 and 1975. -3- ( Respectfully submitted. LAW OFFICES OF LAWRENCE MADEKSHO 8320 Gulf Freeway, Suite 218 Houston, Texas 77017 (713) 641-0251 TBC #12797500 Admissions ID No. 4949 AND ROBERT E. BALLARD ABRAHAM, WATKINS, NICHOLS, BALLARD, ONSTAD & FRIEND 800 Commerce Street Houston, Texas 77002 (713) 222-7211 TBC- #01651000 Admissions ID No. 4946 CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the foregoing Request for Production has been forwarded to Mr. Danny Van Winkle, Vinson & Elkins, Attorneys at Law, 3300 First City Tower, 1001 Fannin, Houston, Texas 77002-6760, on this 8th day of December, 1987, by certified mail, return receipt requested. _______ /V LAWRENCE MADEKSHO -4-