Supplemental and Amended Petition in Faciane v. Travelers Insurance Company (1961)

A 12-page supplemental and amended petition filed in March 1961 in the 19th Judicial District Court for East Baton Rouge Parish, Louisiana, by Mrs. Gladys Faciane, widow of the insulator Clarence A. Faciane, against the Travelers Insurance Company and more than twenty other defendants. It alleges that from 1954 to 1959 Faciane installed asbestos, asbestos mud, fiberglass and foam glass on Louisiana jobs "without the benefit of respirators or other protective devices," became ill in 1958, and died on or about March 20, 1960. Johns-Manville Sales Corporation and Johns-Manville Products Corporation are named among the manufacturers said to have failed "to warn the decedent of the dangers inherent in the products."

What it shows

The defendants fall into three groups: Faciane's insulation contractors (sued for failing to warn him and to give him a safe place to work), the makers of the materials he installed (J-M, Owens Corning Fiberglas, Keasbey & Mattison, Eagle-Picher, Pittsburgh Corning and others), and the two tobacco companies whose cigarettes he smoked. The petition asks for wrongful death damages of about $204,832 for the widow and further sums for two minor children, or in the alternative workmen's compensation from the employers and Travelers. It is an early example of an insulator's family suing asbestos product manufacturers directly, more than a decade before such suits became common.

In Johns-Manville's chronology

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

Complaint and amended complaint in Faciane v. Travelers, a Louisiana direct action by an insulator's widow against insurers, asbestos and fiberglass manufacturers, and tobacco companies. J-M and Travelers were among the defendants.

Editor's note: J-M's description refers to a complaint and an amended complaint. This file holds only the supplemental and amended petition filed in March 1961; the original complaint is not in it.