Sub-series 6: Miscellaneous AHR Documents Providing an Overview of the Company and Dalkon Shield Production and Sales

In 1975 a Multi-District Litigation Panel was set up to consolidate over one hundred Dalkon Shield personal injury tort cases pending in federal district courts in over a third of the states. The pretrial proceedings were held before U. S. District Judge Frank Theis in Wichita, Kansas. Bradley Post, a Wichita lawyer who had represented Connie Deemer, the first woman to win a verdict against Robins for her Dalkon Shield injuries, was chosen lead lawyer in the consolidated cases. Post led the court-ordered discovery proceedings that ran from 1976 through the late 1970s and resumed in 1981 and 1982.

AHR was ordered to produce copies of tens of thousands of documents and to store them at the Richmond offices of McGuire, Woods & Battle, the law firm handling its defense. The collection of documents became known as the Source Files. Documents in the following subject categories were requested, copied and numbered at various times from 1976 through 1982: Research & Development, Adverse Reaction, Manufacturing, Administration, Commercial, Government, International, FDA (Food and Drug Administration), and Bibliography.

In 1991, by administrative order, the Trust was directed to "maintain a document depository in Richmond, Virginia, containing substantially all documents which the Trust, using its best efforts, has identified as having been produced without qualification by Robins in pre-petition Dalkon Shield personal injury tort litigation." The depository, to be made accessible to claimants and their attorneys, was comprised of documents previously in the custody of McGuire, Woods and was located at Datastor, a facility on the east end of the city.

The A.H. Robins Company documents consist of the master group, the Source Files, produced under the direction of Judge Frank Theis in the late 1970s and early 1980s. In addition, there are a number of subsets of the Source Files gathered and arranged by plaintiffs' attorneys, and additional documents produced under orders from other judges in the mid-1980s.