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B&W lawyers had devised an ingenious method for avoiding discovery of sensitive information: have it "shipped offshore" a practice one attorney referred to as "document management." It was the suggestion of Kendrick Wells, an attorney in B&W's legal department, that staff be told that this effort was "to remove deadwood," and that no one "should make any notes, memos or lists." Wigand later testified that another law firm, Covington & Burling, sometimes edited scientific information on additives