Document 0gY0vN2z0DLG3L7rxjbLZONNM

FILE NAME: Celanese (CEL) DATE: 1999 May 21 DOC#: CEL001 DOCUMENT DESCRIPTION: BC Correspondence WALLACE and GRAHAM, P.A, ATTORNEYS AT LAW MONA LISA WALLACE t WILLIAM M. GRAHAM RICHARD L. HUFFMAN RICHARD J.LU TZEL ft CHRISTOPHER D. M AURIELLO ftf PETER F. MORGAN fftf M. REID ACREE, JR . tTTtt CHRISTOPHER J. HICKEY tttttt BARBARA L. CURRY 525 NORTH MAIN STREET SALISBURY, NORTH CAROLINA 28144 May 21,1999 TELEPHONE; (704) 633-5244 FACSIMILE: (704)633-9434 (704)633-0619 t Also licensed in SC ft Also licensed in NY, DC and SC ttt Also licensed in NY, FL and SC tttt Also licensed in VA tftft Also licensed in GA and SC tttttt Also licensed in OH Via Facsimile to 410/448-2368 Dr. Barry I. Castleman 2412 Pickwick Road Baltimore, Maryland 21207 Mr. Steven L. Berger 4418 Pleasant Valley Court Oakland, California 94611 RE: Claims against HNA Holdings, Inc. (a/k/a Fiber Industries, Celanese, ICI, etc.) Dear Barry and Steve: I did receive in the mail the Form 10 K and 20 K filings o f both ICI and Celanese. I am forwarding to each of you the earliest filings that I have received. In regards to Celanese, the filings indicate that Celanese, was incorporated in Delaware in 1918 with executive offices on Fifth Avenue in New York. Since that time, Celanese has been a large manufacturer o f fibers, chemicals, plastics, paints and industrial coatings. The 10 K filing I have on Celanese (fiscal year 1971) indicates "Celanese is one o f two US producers o f acetate cigarette filter tow." Said document also indicates "Commencing in 1958, Celanese diversified its fiber operations by its entry into the non-cellulosic field through its interest in Fiber Industries, Inc. (owned 62 A % by Celanese and 37 lA by Imperial Chemical Industries, LTD. I still have not been able to find out how long Celanese and ICI have been involved in the joint venture as Fiber Industries, but they certainly were in this capacity as o f 1958. A review o f the ICI 10 K filing also indicate that Fiber Industries, Inc. is jointly owned by Celanese and Imperial Chemical. Dr. Barry I. Castleman Mr. Steven L. Berger Page 2 May 21,1999 Also o f interest, yesterday I spent the day going through boxes o f documents in defense counsel's office regarding Fiber Industries and Hoechst Celanese. We were able to find the original insulation specifications drafted by Celanese Corporation in 1962. These were the specifications that were in effect in 1965 when this plant was constructed. The specifications have a schedule o f preference of insulating material. Thermobestos, Kaylo and other asbestos products were the number one preferential product. These documents are being copied and as soon as I received them, I will forward them on to you. They will be o f extreme interest to Steve in regards to alternative products available at the time. Next, we do have confirmation that Celanese and its original safety superintendent in 1965, Mr. Sam Swearingin was a member o f the National Safety Council and would have received all of the historical publications. I ju st wanted to keep you updated. Thank you for your assistance in this regard. Very truly yours, /smf