Kip Johnson to Dennis H. Markusson on Plant Physicians in Gibson v. J-M (1976)

A one-page memo of April 21, 1976, from Kip Johnson to Dennis H. Markusson, headed "Gibson v. JM." Johnson had discussed Interrogatory No. 14 with Bill Reitze, who reviewed a list of plant physicians Johnson had compiled. Reitze "is concerned that we will have another 'Kenneth Smith' situation on our hands especially at those plants where physicians were fired." Johnson added that "there were so many errors in the information previously supplied to Mr. Ris" that he hoped the interrogatory answers would be checked before filing, since the list of plant physicians would not "match up with the list of plant operations which was given to him."

What it shows

Dr. Kenneth W. Smith, J-M's former medical director, had testified about the company's past in a deposition three months earlier (Smith's January 1976 deposition). The memo shows that those preparing J-M's answers worried that other former plant doctors, especially ones the company had dismissed, might testify the same way. Three lines at the foot of the memo are blacked out.

In Johns-Manville's chronology

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

Memorandum to Dennis H. Markusson from Kip Johnson, 4/21/76, regarding Gibson v. J-M, Mr. Johnson discusses Bill Reitze's concern regarding plant physicians: "He is concerned that Manville will have another "Ken Smith" situation on its hands especially at those plants where physicians were fired."