Clyde A. Szuch to Dr. David Ozonoff Seeking a Medical Historian for Raybestos-Manhattan (1980)

A two-page letter of March 6, 1980, from Clyde A. Szuch of Pitney, Hardin & Kipp, national coordinating counsel for Raybestos-Manhattan, to Dr. David Ozonoff of the Boston University School of Medicine. Szuch explained that Raybestos-Manhattan was a defendant in suits by shipyard workers and insulation mechanics, not its own employees, and that "the exigencies of the war effort took priority over consideration of working conditions." He asked Ozonoff to meet about testifying as a medical historian on "the general state of occupational medicine" from the 1930s through the World War II years.

What it shows

Szuch told Ozonoff that the company expected "to be able to demonstrate that Raybestos-Manhattan has always acted as a responsible member of the corporate community in undertaking to insure the health and safety of those individuals known to have been at risk from asbestos exposure." The letter shows the defense planning to put the history of medical knowledge, and the wartime shipyards, at the center of its case against outside workers' claims.

In Johns-Manville's index

Johns-Manville's legal department indexed the Motley 1,000 in 1984. Its index describes this document as follows:

Clyde A. Szuch (Pitney, Hardin & Kipp, counsel for R-M) letter to Dr. David Ozonoff (Boston University School of Medicine), 3/6/80, re third party lawsuits filed against R-M. Szuch asks if Dr. Ozonoff would testify on behalf of R-M concerning the general state of occupational medicine as it existed in this country from the 1930's through the World War II years. Szuch tells Dr. Ozonoff that "on the basis of the information which has come to light in this litigation, we would expect to be able to demonstrate that R-M has always acted as a responsible member of the corporate community in undertaking to insure the health and safety of those individuals known to have been at risk from asbestos exposure."

About this copy

This is document 820 of the Motley 1,000, from the set the Manville Personal Injury Settlement Trust's records facility certified as true copies, pages CRMC-Motley1000-Subj-004387 to CRMC-Motley1000-Subj-004388.