Scope and Contents

Approximately 550 linear feet of court documents; pleadings; court hearings and deposition transcripts; trial exhibits; government discovery documents; case law files; correspondence; memoranda; summaries; drafts; reports; studies; and internal communication created and/or used during the Agent Orange Product Liability Litigation. Most of the materials in the collection appear to have been created or gathered by the Budd Larner Law Firm, who represented Defendant Thompson Chemicals Corporation. Materials of note include the defendants’ motions, memoranda and exhibits for summary judgment based on the Government Contract Defense; Pretrial Orders 26, 33, 51 and 91; the settlement agreement and its drafts; the May 24, 1984 Plaintiffs’ Conference; and the plaintiffs’ and defendants’ fairness briefs.

The collection is arranged into five series: (1) Discovery and Reference, (2) Internal Communication, (3) Trial Records, (4) Deposition and Exhibits, and (5) Medical Records. Due to the breadth of distinctive topics and focus areas of the litigation, each series has also been divided into subseries.

(1) Discovery and Reference
The first series, Discovery and Reference, includes materials gathered during the litigation by defendants and defendants’ legal discovery firms. Defendant discovery and database firms included Carr, Jordan, Coyne & Savits (firm); The Travelers Insurance Company; and J. Feuerstein Systems, which all assisted in the document production and selection process. The series has five subseries,
(1.1) Discovery, (1.2) Weldon Spring Chemical Plant, (1.3) Military Documentation, (1.4) Scientific, and (1.5) Case Law.

(1.1) Discovery (30 linear ft.)
The Discovery subseries includes correspondence; memoranda; government documents; document digests; reports; studies; contracts; legislative bills and transcripts; interview, conference and meeting summaries; FOIA requests; database searches and disease profiles created or gathered by defendants or defendants’ legal discovery firms. The U.S. Department of Justice facilitated the production of government documents during the discovery process, sending documents in batches based on defendant and plaintiff document requests. The subseries is arranged chronologically with materials within previously bound volumes arranged numerically by volume number.

(1.2) Weldon Spring Chemical Plant (13 linear ft.)
The Weldon Spring Chemical Plant subseries includes proposals; correspondence; memoranda; manuals; specifications; schematics; diagrams; equipment lists; agreements; requests for quotations; purchase orders; meeting summaries; weekly reports of activities; progress reports; an environmental impact statement; and inventories related to the Thompson Chemicals Corporation and Stearns-Roger joint venture at Weldon Spring Chemical Plant in their failed attempt to turn the government owned facility into an Agent Orange production facility. The subseries also includes document reference sheets; coding forms; database searches and correspondence by Thompson Chemicals and other chemical companies who felt the evidence provided by these documents was strong enough to get Thompson Chemicals reinstated in the trial after being granted summary judgment in May 1983. The subseries is arranged chronologically with oversize schematics placed either at the end of the subseries or at the end of the inventory.

(1.3) Military Documentation (9 linear ft.)
The Military Documentation subseries includes reports; studies; correspondence; memoranda; manuscript drafts; map and book photocopies; manuals; briefings; evaluations; summaries; situation reports; daily staff journals; database searches; and medical statistics and reports from U.S. military departments and related officials. The subseries also contains analyses of representative plaintiffs’ exposure to herbicide while in Vietnam based on their known stationed locations. The subseries is arranged chronologically.

(1.4) Scientific (14 linear ft.)
The Scientific subseries includes reports; studies; congressional hearings and statements; literature reviews; conference proceedings; progress reports; workshop drafts; and book sections related to scientific research and discussion on Agent Orange, herbicides and dioxin. The subseries contains some of the Bionetics Research Laboratories reports, whose results influenced the government to halt the usage of Agent Orange in 1970. It also includes Thompson Chemicals Corporation/Superior Solvents site documents related to the positive samples of 2,3,7,8-tetrachlorodibenzo-p-dioxin found by the EPA in the soil where the chemical company was located. The subseries is arranged chronologically with oversize materials placed at the end of the inventory.

(1.5) Case Law (6 linear ft.)
The Case Law subseries includes correspondence; class briefs; legal opinions; judgments and orders; petitions for writ of mandamus; state statutes; notices of lien reports; articles and court transcripts from other court cases and legislature that appeared to relate to the litigation and the defendants’ positions and arguments. The subseries is arranged chronologically.

(2) Internal Communication
The second series, Internal Communication, concerns materials created and/or received by the defendants during the litigation in preparation for the trial that generally were not intended to serve as official court documents. In addition to the materials defendants created for themselves as resources for the litigation, these materials capture communication within a firm, particularly Budd Larner who represented Thompson Chemical, and communication between defendants, plaintiffs, legal discovery firms, clients, and/or other groups. The series is divided into four subseries: (2.1) Correspondence, (2.2) Trial, (2.3) Deposition, and (2.4) Financial.

(2.1) Correspondence (8 linear ft.)
The Correspondence subseries includes correspondence and lists of mail received with notices to all counsel; deposition scheduling; meeting summaries; motions; memoranda; document lists; government documents; affidavits; case law; bills and invoices; allocations; and briefs that were received or created by the Budd Larner law firm and other defendants during the litigation. The subseries also contains internal Budd Larner office memoranda related to the litigation. The subseries is arranged chronologically.

(2.2) Trial (8.5 linear ft.)
The Trial subseries includes trial books; interoffice communication; meeting summaries; memoranda; notes; filing procedures; jury analysis data and opt-out lists. The defendants used trial books, which contain a summary on a particular organization or topic; plus relevant testimonies and documents, to provide an internal overview on a topic. The subseries is arranged chronologically. Boxes 87 and 88A contain restricted materials and are closed until 2061.

(2.3) Deposition (8 linear ft.)
The Deposition subseries includes outlines; witness/deponent lists and profiles; deposition summaries; medical records requests; schedules; and notes relating to the defendants’ preparations for depositions. The subseries is arranged chronologically and then alphabetically if applicable.

(2.4) Financial (1 linear ft)
The Financial subseries includes bills; timesheets; and invoices related to trial matters such as transcriptions; discovery; and databases. The subseries is arranged chronologically.

(3) Trial Records
The third series, Trial Records, contains materials created during the litigation as part of the official court record. The series contains 17 subseries: (3.1) Court Proceedings, (3.2) Pleadings, (3.3) Complaints, (3.4) Interrogatories, (3.5) Document Production, (3.6) Government Contract Defense, (3.7) Class Certification, (3.8) Plaintiff Pleadings and Correspondence, (3.9) Statutes of Limitations, Venue, and Jurisdiction, (3.10) Liability, (3.11) Jury Selection, (3.12) Media Coverage, (3.13) Settlement, (3.14) Attorney’s Fees, (3.15) Opt-Out and Appeal Cases, (3.16) Joint Appendices, and (3.17) Working Files. The ordering of the subseries within the series generally attempts to mimic the progressions of the trial with elements that began earlier such as complaints, document requests and the Government Contract Defense preceding liability, settlement and opt-out and appeal cases. The subseries also attempts to reflect the arrangement and categories chosen by the collection’s creators.

(3.1) Court Proceedings (16 linear ft.)
The Court Proceedings subseries includes orders; opinions; recommendations; and hearing transcripts, primarily from Agent Orange Product Liability Litigation court officials. The subseries also contains procedural motions and memoranda from defendants and plaintiffs. The subseries is arranged chronologically with volumes being grouped together with the date of the last volume in the set determining where the set is placed within the subseries. Joint hearings transcripts with two court officials listed in the title are placed separately from transcripts with only a single listed official.

(3.2) Pleadings (16 linear ft.)
The Pleadings subseries is a set of previously bound volumes of court records from the litigation that appears to have been created by the defendants and arranged numerically by volume. The Court of Appeals, Second Circuit volumes are placed at the end of the subseries. Materials within the volumes include legal memoranda; motions; correspondence; interrogatory answers; orders; recommendations; statements; petitions; notices; and objections. Most volumes have an index at the end of the volume. Pleading volume 32 does not appear in this subseries.

(3.3) Complaints (2 linear ft.)
The Complaints subseries includes complaints from the plaintiffs toward the defendants and towards the United States government and Veterans’ Administration. The subseries also contains defendants’ answers and responses to the complaints as well as defendants’ third-party complaints against the United States. The subseries is arranged chronologically with previously bound volumes being grouped together with the date of the last volume in the set determining where it is placed chronologically.

(3.4) Interrogatories (5 linear ft.)
The Interrogatories subseries includes interrogatories, responses and answers from the plaintiffs, defendants, and the United States, as well as recommendations and orders from the special master and magistrate. The subseries is arranged chronologically with volumes being grouped together with the latest date determining where the volume set is placed.

(3.5) Document Production (7 linear ft.)
The Document Production subseries includes document requests; confidentiality and protective orders; correspondence; memoranda; and other documents related to the litigation discovery process for all parties involved. The subseries also covers the United States’ claims of privilege, such as state secrets; responses to a 1983 Diamond Shamrock company memorandum regarding document destruction; attempts to focus and consolidate government document discovery; and the hiring and recommendations of Special Master Sol Schreiber. The subseries is arranged chronologically.

(3.6) Government Contract Defense (11 linear ft.)
The Government Contract Defense subseries includes defendants’ Agent Orange contracts with the government; relevant pretrial orders; and motions for summary judgment with exhibits and legal memoranda. After Judge Pratt determined that four of the defendants could be dismissed using the Government Contract Defense to gain summary judgment, the subseries focuses on the memoranda and motions for reconsideration that brought Thompson Chemicals Corporation and Hercules Incorporated back into the case, and defendants’ arguments based on the Defense Production Act. The subseries is arranged chronologically.

(3.7) Class Certification (4 linear ft.)
The Class Certification subseries includes a determination of what cases should be transferred into the multidistrict litigation and be part of the class; dissemination of the class notice including how to locate veterans and what media to use; motions for intervention; decertification; and class notice certificates. The series is arranged chronologically with the certifications arranged numerically with the latest date determining where the set is placed within the subseries.

(3.8) Plaintiff Pleadings and Correspondence (7 linear ft.)
The Plaintiff Pleadings and Correspondence subseries includes transfer orders, summons and complaints; communication between plaintiffs and defendants; planned in extremis depositions; and exclusion request forms for individual plaintiffs. Except for the Michael Ryan files, which is the class certified case, each file represents a case that was transferred to MDL 381. Many of these plaintiffs chose to either opt-out of the class or opposed this transfer. The subseries is arranged alphabetically by the plaintiff’s last name or organization name.

(3.9) Statutes of Limitations, Venue, and Jurisdiction (2 linear ft.)
The Statutes of Limitations, Venue, and Jurisdiction subseries includes case files; legal memoranda; and proposed transfer orders. These materials cover issues such as the application of federal common law to the case; claims that the plaintiffs failed in the legal process of officially naming Thompson Chemicals Corporation as a defendant and the impact this would have on proper jurisdiction; individual states’ statute of limitations laws on personal injury and wrongful death claims; and the choice of the Eastern District of New York as the venue for all multidistrict cases in the litigation. The subseries is arranged chronologically.

(3.10) Liability (7 linear ft.)
The Liability subseries includes complaints; legal memoranda; insurance information; correspondence; memos; scope of issues; petitions for writ of mandamus; and motions related to the issues of causation and liability regarding Agent Orange. The subseries includes the questions of whether the United States had any liability in the case due to the Feres Doctrine; whether Hooker Chemicals/Occidental had any liability for providing the base supplies the chemical companies used for Agent Orange; and whether 2,4-D and non-phenoxy herbicides used during Vietnam should be included in the trial. The subseries also includes a determination of the chemical companies’ liability insurance policies. The subseries is arranged chronologically.

(3.11) Jury Selection (6 linear ft.)
The Jury Selection subseries includes defendant’s legal memoranda opposing a jury trial; the questionnaires provided to the potential jury of the trial; and transcripts for court hearings before Judge Weinstein and Magistrate Scheindlin where the parties chose the jury pool that would appear in court. Drafts of the questionnaires can also be found in the subseries. The subseries is arranged chronologically.

(3.12) Media Coverage (.5 linear ft.)
The Media Coverage subseries includes protective orders; defendants’ briefs; and news clippings and articles written by the press during the litigation. Part of the subseries focuses on CBS’ requests for discovery materials from both parties and the response that led to protective orders placed on the material to restrict CBS’ access. Another part focuses on the media coverage of the settlement of the case. The subseries is arranged chronologically.

(3.13) Settlement (6.5 linear ft.)
The Settlement subseries includes correspondence; legal memoranda; fairness briefs; settlement agreements; objections; certified mail; meeting, hearing and conference transcripts; allocations; insurance coverage and fund materials related to the settlement of the litigation that occurred on May 7, 1984, and its aftermath. The subseries includes correspondence sent by plaintiff veterans responding to the settlement. The subseries is arranged chronologically with the numbered certifications arranged together numerically.

(3.14) Attorney’s Fees (10 linear ft.)
The Attorney’s Fees subseries includes timesheets; work journals; legal memoranda; transcripts; applications; reviews; and joint appendices related to the plaintiff attorneys’ applications to receive payment for their services from a portion of the settlement fund. The subseries contains both the plaintiffs’ own records and writings on their work during the litigation as well as the defendants’, Judge Weinstein’s and Magistrate Scheindlin’s reviews, orders and recommendations for fee allotment for each plaintiff attorney or legal firm. The subseries is generally arranged chronologically with the initial plaintiff applications for attorney’s fees arranged numerically by a court assigned number and with the joint appendices arranged by volume number.

(3.15) Opt-Out and Appeal Cases (10 linear ft.)
The Opt-Out and Appeal Cases subseries includes exclusion request forms; lists of opt-out plaintiffs; notices; complaints; appeals; writs of mandamus; orders; legal memoranda; correspondence; motions; and United States Court of Appeals for the Second Circuit briefs. The subseries includes materials related to individual plaintiffs’ opt-out cases. The subseries is arranged chronologically.

(3.16) Joint Appendices (7.5 linear ft.)
The Joint Appendices subseries includes dockets; legal memoranda; complaints; transcript and deposition excerpts; exhibits; motions; appeals; orders; and correspondence, which served as gathered evidence for appeals to the United States Court of Appeals for the Second Circuit. These appeals included appeals to the class action; opt-out appeals; civilian cases appeals; the defendants’ appeal of the lifting of the protective order; and appeals relating to the liability and dismissal of the United States from the litigation. The subseries is arranged chronologically with the volumes of Joint Appendices arranged numerically.

(3.17) Working Files (2.5 linear ft.)
The Working Files subseries includes pleading copies; pending motions; legal memoranda; file lists and indexes; complaints; reports; briefs; jury instructions; exhibit lists; trial books; and interrogatories that were kept as files during the litigation by the defendant attorney firm, Budd Larner. A Budd Larner attorney, Joseph J. Schiavone, organized and/or created many of the files within the subseries. The subseries is arranged chronologically and then numerically by assigned file number. Not all file numbers are represented as some numbers are skipped.

(4) Deposition and Exhibits
The fourth series, Deposition and Exhibits, contains materials created to form evidence and testimonies that would be used to support each side’s arguments during the trial. The series contains seven subseries: (4.1) Alphabetical, (4.2) Post Settlement, (4.3) Master List Exhibits, (4.4) Plaintiffs’ Exhibits, (4.5) Defendants’ Exhibits, (4.6) Supplemental, and (4.7) Opt-Out Affidavits.

(4.1) Alphabetical (203 linear ft.)
The Alphabetical subseries includes deposition transcripts; exhibits; and searches for relevant deponents from documents found in the defendants’ trial databases. The deposition transcripts come from government officials from relevant agencies and departments such as Edgewood Arsenal; Fort Detrick; U.S. Public Health Service; Environmental Protection Agency; President’s Science Advisory Committee; Department of Defense; National Cancer Institute/Bionetics; Air Force Logistics Command; U.S. Department of Agriculture; Food and Drug Administration and the Centers for Disease Control and Prevention; chemical company employees; representative plaintiffs; and defendants’ and plaintiffs’ expert witnesses. The subseries is arranged alphabetically by deponent’s last name and then first name if applicable.

(4.2) Post Settlement (5 linear ft.)
The Post Settlement subseries includes deposition transcripts and exhibits for depositions that were conducted after the class action litigation was settled on May 7, 1984. This subseries focuses on civilian and opt-out plaintiffs and is arranged alphabetically by deponent’s last name.

(4.3) Master List Exhibits (2 linear ft.)
The Master List Exhibits subseries includes reports; studies; minutes; memoranda; correspondence; trip reports; and statements that defendants planned to use as exhibits for multiple government witness depositions. The subseries is arranged numerically by exhibit number with additional potential exhibits being placed at the end. Some exhibit numbers are skipped.

(4.4) Plaintiffs’ Exhibits (13 linear ft.)
The Plaintiffs’ Exhibits subseries includes reports; studies; contracts; chemical analyses; shipping information; minutes; case law; and bibliographies that the plaintiffs planned to use as potential exhibits during the trial. The subseries is generally arranged by exhibit number with the pretrial orders at the beginning of the subseries containing an index and summary of each exhibit. Original order of runs was preserved when possible. Plaintiffs’ exhibits begin with the letter P. Some exhibit numbers are skipped.

(4.5) Defendants’ Exhibits (63 linear ft.)
The Defendants’ Exhibits subseries includes contracts; specifications; manuals; reports; studies; chemical analyses; invoices; daily staff journals; minutes; trip reports; transcripts; memoranda and correspondence that the defendants planned to use as potential exhibits during the trial. The subseries is arranged by chemical company. At the start of each chemical company’s exhibits is a pretrial order that lists all the exhibits with short summaries for the company. Within each company’s exhibits, it is arranged by exhibit number with company specific exhibits first and then joint exhibits, which applied to all chemical company defendants. Company exhibits usually start with the first letter of the company with Diamond Shamrock using DS and T.H. Agriculture and Nutrition using TH. Joint exhibits start with a W. Some exhibit numbers are skipped.

(4.6) Supplemental (5 linear ft.)
The Supplemental subseries includes deponent and witness lists; legal memoranda; deposition notices; schedules; calendars; orders; scope of discovery; exhibit document lists; medical examination lists and documents; and Federal Rules of Procedure Rule 26 (b) (4) (A) (i) statements. These documents appear to be used to organize the deposition process with court rulings on issues such as closed and in extremis depositions; with Rule 26 statements that stated the qualifications of each expert witness a party potentially planned to use during the trial; and with schedules and procedures established for deposition scheduling and medical examinations. The subseries is arranged chronologically. Volumes are grouped together with the date of the last volume in the set determining where the set is placed chronologically.

(4.7) Opt-Out Affidavits (1 linear ft.)
The Opt-Out Affidavits subseries includes affidavits; checklists of medical problems; curricula vitae and exhibits from plaintiffs who opted out of the class action settlement and from physicians who observed these plaintiffs. The firm Ashcraft & Gerel represented all the opt-out plaintiffs who provided affidavits in this subseries. The subseries is arranged chronologically.

(5) Medical
The Medical Records series contains restricted materials and is closed until 2061.

Biographical / Historical

In 1978, Victor J. Yannacone, Jr. filed the first lawsuits in the Southern and Eastern Districts of New York and the Northern District Court of Illinois on behalf of veterans against the chemical companies who manufactured Agent Orange, a carcinogenic defoliant, during the Vietnam War. These chemical companies were Diamond Shamrock (previously Diamond Alkali), Dow Chemical, Hercules, Hoffman-Taff, Monsanto, Riverdale, Thompson Chemicals Corporation (sometimes referred to as Thompson Chemical Company), T.H. Agriculture and Nutrition, (previously known as Thompson-Hayward), and Uniroyal. On May 9, 1979, the Judicial Panel on Multidistrict Litigation consolidated eight related cases into what would be known as Multidistrict Litigation No. 381 (MDL No. 381), Agent Orange Product Liability Litigation. All of these cases and later transferred cases were brought to the United States District Court of the Eastern District of New York under Judge George C. Pratt (1979-1983) and later Judge Jack Weinstein (1983-). On December 26, 1980, Judge Pratt issued Pretrial Order 26, which ruled that the Feres Doctrine applied to the case and that the United States was not an official party in the case. The Feres Doctrine, established from the 1950 Supreme Court case, Feres v. United States, prevents soldiers and veterans from suing the government for damages related to service during a tort action. Pretrial Order 26 also tentatively certified the case as a class action (Michael F. Ryan et al. v. Dow Chemical Company, et al.) and declared Pratt’s intent of having separate trials for specific issues. Pratt decided that the Government Contract Defense would be the first issue to be brought to trial.

The Government Contract Defense provides protection for military weapons manufacturers who followed government orders to produce these weapons from lawsuits and damage claims if certain criteria are met. In February 1982, Judge Pratt specifically outlined the conditions for the defendants to receive summary judgment and not be liable for any of the other issues in Pretrial Order No. 33, “1. That the government established the specifications for ‘Agent Orange’; 2. That the ‘Agent Orange’ manufactured by the defendant met the government’s specifications in all material respects; 3. That the government knew as much as or more than the defendant about the hazards to people that accompanied use of ‘Agent Orange’;” “These three elements if established at the Phase I trial will insulate a defendant from liability based on its having supplied the ‘Agent Orange’ pursuant to the government contract.”

Judge Pratt originally scheduled the Government Contract Defense trial for June 1983 but delays due to the defendants requesting more discovery time and Pratt’s appointment to the Court of Appeals by President Reagan altered this schedule. Instead, in April 1983, Judge Pratt allowed the chemical companies to move for summary judgment for the Government Contract Defense, which resulted in the dismissal of four defendants: Hoffman-Taff, Riverdale, Thompson Chemicals and Hercules. Pratt then declared that the next phase of the litigation, presided over by a new judge, would focus on all the issues, including liability, causation, and the Government Contract Defense, in one trial. At this time, Yannacone & Associates stepped down as lead plaintiff counsel, and the Plaintiffs’ Management Committee took over, consisting of the remaining plaintiff attorneys and new attorneys who provided funding.

In October 1983, Judge Jack Weinstein became the new judge in the litigation and aimed to get the case resolved in a timely fashion, scheduling the trial for May 1984. The Court reconsidered the summary judgment ruling for Thompson Chemicals and Hercules, which brought those two defendants back into the litigation. Discovery for the plaintiffs and defendants shifted to liability and causation issues. One of the main obstacles of the case for the plaintiffs was their inability to definitively prove which company’s Agent Orange mixture harmed individual veterans and their families. In Pretrial Order 91, Weinstein argued that the United States government was potentially liable to the claims of spouses and children who may not be bound by the Feres Doctrine and brought the United States as an active party in the case in February 1984. For the causation issues, the court ordered both sides to designate expert witnesses from scientific and academic fields to provide testimony during the trial and for the plaintiffs to designate representative individuals to represent the class.

After three years in a tentative class action, Weinstein officially certified the class on December 16, 1983, and stated: “The plaintiff class is defined as those persons who were in the United States, New Zealand or Australian Armed Forces at any time from 1961 to 1972 who were injured while in or near Vietnam by exposure to Agent Orange or other phenoxy herbicides, including those composed in whole or in part of 2,4,5-trichlorophenoxyacetic acid or containing some amount of 2,3,7,8-tetrachlorodibenzo-p-dioxin. The class also includes spouses, parents, and children of the veterans born before January 1, 1984, directly or derivatively injured as a result of the exposure.” (Weinstein Memorandum and Pretrial Order). The Court distributed class notices by mail to the plaintiffs identified by the Plaintiffs’ Management Committee. Additionally, the Court used notices and public service announcements in television, radio and popular magazines and newspapers to attempt to reach more people. Plaintiffs were automatically included in the class if they did not respond with an opt-out form by May 1, 1984.

On May 7, 1984, the day the trial was scheduled to start, both sides agreed to settle the class action for $180 million. Afterward fairness hearings were held in five U.S. cities so plaintiffs and others could voice their concerns. Weinstein approved the settlement in September 1984, but it took until July 4, 1988, to authorize the settlement fund’s distribution due to appeals from both parties, and discussions on how to distribute the funds. Direct payments were given to U.S. veterans with 100% disability ratings and to deceased veterans’ family members for death benefits, 2 percent of the fund was given to Australian and New Zealand class members, and a fourth of the fund would be used to create a class assistance program. In February 1985, Weinstein dismissed the U.S. Government from any claims of veterans’ wives and children, ruling that the plaintiffs could not prove causation. While the class action was settled, plaintiff cases against the government, opt-out cases, appeals and civilian cases in MDL No. 381 continued in the ensuing decades.

Series

• Series 1: Discovery and Reference
• Subseries 1.1: Discovery
• Subseries 1.2: Weldon Spring Chemical Plant
• Subseries 1.3: Military Documentation
• Subseries 1.4: Scientific
• Subseries 1.5: Case Law
• Series 2: Internal Communication
• Subseries 2.1: Correspondence
• Subseries 2.2: Trial
• Subseries 2.3: Deposition
• Subseries 2.4: Financial
• Series 3: Trial Records
• Subseries 3.1: Court Proceedings
• Subseries 3.2: Pleadings
• Subseries 3.3: Complaints
• Subseries 3.4: Interrogatories
• Subseries 3.5: Document Production
• Subseries 3.6: Government Contract Defense
• Subseries 3.7: Class Certification
• Subseries 3.8: Plaintiff Pleadings and Correspondence
• Subseries 3.9: Statutes of Limitations, Venue, and Jurisdiction
• Subseries 3.10: Liability
• Subseries 3.11: Jury Selection
• Subseries 3.12: Media Coverage
• Subseries 3.13: Settlement
• Subseries 3.14: Attorney's Fees
• Subseries 3.15: Opt-out and Appeal Cases
• Subseries 3.16: Joint Appendices
• Subseries 3.17: Working Files
• Series 4: Deposition and Exhibits
• Subseries 4.1: Alphabetical
• Subseries 4.2: Post Settlement
• Subseries 4.3: Master List Exhibits
• Subseries 4.4: Plaintiffs' Exhibits
• Subseries 4.5: Defendants' Exhibits
• Subseries 4.6: Supplemental
• Subseries 4.7: Opt-Out Affidavits
• Series 1: Discovery and Reference (Oversize)
• Subseries 1.2: Weldon Spring Chemical Plant (Oversize)
• Subseries 1.4: Scientific (Oversize)
• Series 2: Internal Communication (Oversize)
• Subseries 2.2: Trial (Oversize)
• Subseries 2.4: Financial (Oversize)
• Series 1: Discovery and Reference (Oversize)
• Subseries 1.2: Weldon Spring Chemical Plant (Oversize)
• Subseries 1.4: Scientific (Oversize)
• Series 3: Trial Records (Oversize)
• Subseries 3.13: Settlement (Oversize)