Mr.

PLAINTIFF'S EXHIBIT IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY CIVIL SECTION: TRIAL DIVISION RICHARD SANDS and PATRICIA SANDS, h/w VS.

m S-51 INTER-ORGANIZATION MEMORANDUM 4o ?.

Ms.

Westinghouse Electric Corporation Industry Products Company To All Westinghouse Large Motor Division Suppliers large Motor Division Box 225 Buffalo NewVbrk 14240 (7161631 1000 December 1, 1980 Although we appreciate the good quality and performance our suppliers are committed to, we are ever striving to improve.

Appendix D.

mwMimmm ________________ _______ AHERA: SCIENCE HAD NOTHING TO DO WITH IT Congress Moved Vigorously into the Asbestos Controversy in Response to EPA's Inaction So Science Had Little to Do with AHERA: Now EPA Must Conform to Congressional Specifications--and Dates By Michael J.

22516 Federal Register / Vol. 51.

Federal Register / Vol. 51, No. 119 / Friday, June 20, 1986 / Notices 22553 collections in excess of the maximum lawful price for gas sold to Texas Eastern Gas Pipeline Company (Texas Eastern) from the Rogers "R" No. 1 Well located in the Carter Sand of Siloam .

Federal Register / .Vol. 51, No. 119 / Friday, June 20, 1986 / Notices 22579 'e (1) All applicants Tor designation must training services within an established comply with the requirements found at service area.

ill ill Iji'(i , ill Source: Product Catalog, Asbestos Control Technologies, Inc., Maple Shade, N.|., 1985.

1989 letter responds to plaintiffs' November 23, 1989 letter, which deals exclusively with matters other than the Orzinuovi Dumps These letters are completely irrelevant to matters in controversy in this litigation " Pis ' Resp to Defs ' Suppl 56 1 U 63 *9 Moreover, Plaintiffs' improper conduct included a covert campaign to generate grounds for their indemnity demands against Defendants Despite Defendants' request that the parties work together in dealing with government officials, Plaintiffs pursued a campaign of secrecy and concealment regarding their dealings with Italian authorities See Defs Supplemental 56 1 U 91, Tab 12 For example, during one of Plaintiffs' private meetings with the Mayor of Orzinuovi about the landfills, Plaintiffs' representative asked the Mayor whether "it is possible to have from him a mandatory request to proceed" with Plaintiffs' already proposed remediation project See id f 100, Tab 26 Plaintiffs' campaign also involved coaxing the Mayor to issue the January 23, 1993 order requiring plaintiffFrendo to undertake a landfill cleanup project, an order that Plaintiffs' counsel secretly drafted and requested See id ^ 109, Tabs 56, 57 In addition to this, after informing Plaintiffs that the order was invalid and without legal effect, Plaintiffs' lawyer then stated, "I assume these developments should not be disclosed to Abex " Roberts Aff H 20, Ex S In pressing their indemnity rights here.

inter Office O Employee Relations Staff / J, H.

tr t > United States Environmental Protection Agency Office of Public Affairs (A-107) Washington DC 20460 Environmental Backgrounder November 1988 Overview Health Concerns 4 Asbestos Asbestos is the name of a group of naturally occurring minerals that separate into strong, microscopic fibers that are heat-resistant, odorless, and very durable.

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