Lawyers representing women injured by the Dalkon Shield yesterday proposed suing the top executives of A.H. Robins Co. for about $2.4 billion to hold them personally accountable for the defective contraceptive.

Chairman E. Claiborne Robins, his son, company President E. Claiborne Robins Jr., and former president William L. Zimmer III should be sued for their "misdeeds" and "grossly negligent actions," lawyers said in papers filed in U.S. District Court in Richmond.

The District Court must give permission for the lawsuit to be filed on behalf of the thousands of women who suffered injuries, including infertility or death as a result of using the Robins intrauterine device.

The lawsuit, filed by Murray Drabkin, the lawyer for the Dalkon Shield Claimants Committee, is the first effort to hold A.H. Robins Co. officers and directors financially responsible for the Dalkon Shield and its aftermath, which forced the Richmond company into bankruptcy.

"This motion is nothing more than a continuation of the obstructionist tactics that Mr. Drabkin and the Dalkon Shield Claimants Committee have practiced throughout the Chapter 11 case," said A.H. Robins Co. spokesman Roscoe E. Puckett Jr.

Puckett said the group is "desperately attempting to create a sideshow that would divert energy and attention from the company's reorganization plans," and warned that the move might lead to further delay for Dalkon Shield's claimants."

U.S. District Judge Robert R. Merhige Jr. has set a hearing in Richmond for Aug. 19 -- two days before the second anniversary of Robins' entry into voluntary bankruptcy. The company sought Chapter 11 protection to get relief from massive Dalkon Shield product-liability litigation.

The accounting firm of McGladrey, Hendrickson & Pullen, which audited Robins' books from 1975 to 1982, also should be sued, said Drabkin, who represents about 214,000 women with potential claims against the company.

None of the proposed targets of the lawsuit could be reached for comment.

Drabkin, explaining the timing of the filing in court papers, said statute-of-limitations problems may arise after the Aug. 21 anniversary date. Robins has refused to ask its officers and board to waive the statute, Drabkin wrote.

"Further requests are futile," Drabkin said. Robins, he added, has made no claims against the officers and directors "responsible for the misdeeds" and has specifically rejected a committee request to correct "the unlawful payment of dividends."

The committee motion asserted that the company has plausible claims against the company executives and auditors, based on conduct including "grossly negligent mismanagement, breach of fiduciary duty, fraudulent transfers, {and} illegal dividends."

The motion said the individuals knew or should have known that the IUD "had been poorly designed and inadequately tested" and carried substantial risks of serious injuries, particularly life-threatening pelvic infections that could result in impaired or destroyed fertility.

Yet, the court papers said, the three officers "failed to discharge their responsibilities to the company and its creditors and acted with gross negligence."

The document charged that the elder Robins, his son and Zimmer failed for about a decade after halting sales of the IUD to recall the device or to study the company's potential liability for claims.

Not until April 1985 was a reserve fund for claimants set up.

The CPA firm, the motion alleged, knew or should have known some or all facts about the potential cost to the company and "breached its duty of ordinary care," partly by "failing to report that Robins' financial statements were not in conformity with generally accepted accounting principles."

"McGladrey's negligence deprived Robins' board, particularly the outside directors, of information needed to respond properly to the Dalkon Shield crisis," the committee charged.

The motion estimated the $2.4 billion in damages from the officials and auditors could include: $530 million paid by Robins and Aetna Life & Casualty Co., its Dalkon Shield insurer, to resolve claims before the company filed for bankruptcy. Aetna is seeking a refund from Robins of some of the money it paid. $1.75 billion -- or more -- expected to be paid to Shield claimants under a financial reorganization plan. Dividends of $110 million paid to Robins stockholders in the decade ended in 1984, the last full year before the Chapter 11 filing. By declaring the dividends, the committee motion said, the officers "breached their fiduciary duty of loyalty and good faith ..."

Of the $110 million in dividends 1975 through 1984, the committee estimated, about half -- $55 million -- went to the Robins family.

If the full $110 million isn't refunded, the committee said, the elder Robins and his son should be ordered to pay the estate $50 million, plus interest, costs and legal fees.

During those dividend years, the committee said, the claims by Dalkon Shield victims rose precipitously.

Lawsuits for punitive damages increased from $1.5 billion to $28.5 billion -- and claims for compensatory damages grew from $753,654 to $5 billion.

The net worth of the company, $240.3 million in 1978, fell to a negative $127.9 million in 1984 after deduction of a $615 million reserve for payments to victims.

Zimmer became president and chief executive officer of the company in 1970, when it bought rights to make and sell the Dalkon Shield. Claiborne Robins Jr. succeeded him in 1978.

Staff writer Clay Chandler contributed to this report.