We share manufacturing information, trade association documentation, including documents, depositions and trial testimony available upon request. We have also spent considerable time interviewing former employees of Cooper Tire, Bridgestone/Firestone and Uniroyal Goodrich. We have verified plant practices and procedures that can contribute to tread belt separations. Many of these witnesses are reluctant to testify, but the information they provide is invaluable. Surprisingly, some of these former employees have the courage to come forward and provide sworn testimony. It is an unfortunate reality that tire companies insist on overbroad protective orders and routinely protect not only trade secret documents but "dirty laundry." Appropriate sharing of information substantially reduces the burden on courts and attorneys, reducing the unnecessary burden of multiple hearings on motions to compel discovery from defendants. Increasingly, courts are recognizing the benefits of sharing provisions for judicial efficiency and to reduce discovery disputes. Accordingly, we urge everyone to request appropriate sharing provisions in any protective order they enter into.

Bruce R. Kaster, PA is available to assist you in the evaluation of cases, sharing information, and as consulting counsel or co-counsel.

BRUCE R. KASTER, PA
125 NE 1st Ave.
Box 100, Suite 3
Ocala, Florida 34478-0100

Phone: (352) 622-1600
E-mail: brk@tirefailures.com