George F. Evans to Clark Burnham on Asbestos Use at Lompoc in Dias v. Johns-Manville (1982)

A one-page letter of February 12, 1982, from George F. Evans, a senior attorney at Johns-Manville, to Clark Burnham of the Oakland law firm Moore, Clifford, Wolfe, Larson & Trutner, J-M's outside counsel in Joseph Dias v. Johns-Manville. Burnham had asked whether asbestos was used at J-M's Lompoc, California, diatomaceous earth plant between 1932 and 1942, as J-M's answers to interrogatories said. Evans replies that "these answers are probably incorrect" and that "it appears that asbestos was used in only two products at Lompoc between 1951 and 1977." He planned to look into it further during discovery at Lompoc.

In Johns-Manville's chronology

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

In a letter dated 2/12/82 from George Evans to Clark Burnham, Esq. of Moore, Clifford, Wolfe, Larson & Trutner Re: Joseph Dias v. Johns-Manville, Evans suggests that Manville's answers to interrogatories regarding whether asbestos was used at Lompoc between 1932 and 1942 are probably incorrect. Evans states "it appears that asbestos was used in only two products in Lompoc between 1951 and 1977."