Complaint in Wenham v. Johns-Manville Products Corporation (1961)

A four-page complaint filed February 23, 1961, in the U.S. District Court for the District of New Jersey on behalf of Fred C. Wenham, an insulation materials applicator, by his daughter as administratrix, against Johns-Manville Products Corporation. It alleges that until February 24, 1959, Wenham handled J-M products containing asbestos, that J-M "knew or should have known of the dangerous and toxic qualities of its products," and that it failed "to provide any or adequate warnings or instructions as to the use and handling of same." Wenham died on May 31, 1960, "as a result of the occupational disease contracted in his employment."

What it shows

The complaint pleads three counts (negligence, breach of warranty and wrongful death), seeking $100,000 on each. Its central claims are that a maker of asbestos insulation should have known of the danger and had a duty to warn the men who installed it. Together with the Faciane petition filed the next month in Louisiana, it shows insulators' families suing J-M as a product maker by early 1961.

In Johns-Manville's chronology

Johns-Manville's own chronology of what the company knew describes this document as follows:

Wenham v. J-M, insulator civil claim.