Document 3nppdbnj0LEVkmK2Om9N3JLJ

FILE NAME Mundet Cork MCK DATE 2009 May DOC MCK030 DOCUMENT DESCRIPTION BC Affidavit Iowa Court IN THE IOWA DISTRICT COURT FOR POLK COUNTY JAMES P. O'BOYLE DOB 1/16/1930 and JOAN O'BOYLE DOB 9/17/1932 his wife Plaintiffs VS. A.W. CHESTERTON COMPANY et al Defendants ~fi CASE NO CL106817 1 | | | | AFFIDAVIT OF | BARRY I. CASTLEMAN Sc.D | \ | | | | AFFIDAVIT OF BARRY I. CASTLEMAN Sc.D. STATE OF MARYLAND COUNTY OF MONTGOMERY AND NOW COMES the undersigned Affiant Barry I. Castleman Sc.D. who being of proper age and duly sworn states the following 1 live at 4406 Oxford Rd Garrett Park Maryland 20896 In 1968 I obtained a Bachelor's Degree in Chemical Engineering from Johns Hopkins University In 1972 I was 2 awarded a Master's Degree in Environmental Engineering from Johns HofopSkciinesncUeniDveegrsrietey iwnhHiecahltwhasPolmiaciynlfyroimn areas related to air pollution control In 1985 I was awarded a Doctor Johns Hopkins School of Hygiene and Public Health back over 30 years in the area of asbestos and other occupational and My professional experience goes and environmental health policy which is a branch of environmental health problems My field is occupational Public Health mainly oriented towards the recognition of risk factors and the prevention of disease from industrial activities My Doctoral degree was awarded for two years of course work various examinations and the writing of a doctoral and dissertation The course work was mainly in the areas of toxicology epidemiology biostatistics physiology public health policy These are the tools that are used to understaonfd vhaoriwoutshesbtuoddiyeswoorfkpseoapnldecasntubdieesdaomfaagneidmablsy toxic substances how these effects can be identified by means experimentally exposed and so on Doctoral thesis was Asbestos An Historical Case Study of Corporate Response to an Industrial Health Hazard My 1984 by Prentice Hall Law and Business called Asbestos Medical and is largely identical to a book published in and Legal Aspects now in its 5th Edition 2005 Affidavit of BARRY 1. CASTLEMAN Sc.D. O'Boyle v A.W. Chesterton Company et al -13 6 7 8 0 The doctoral thesis is an historical review of the asbestos problem as a public health problem in society worldwide but mainly in the United States It encompasses a comprehensive review of medical literature of all kinds as well as other literature available in libraries and published sources such as government publications safety magazines engineering journals trade magazines insurance publications encyclopedias popular magazines and newspapers The doctoral thesis also involved research based on unpublished government records The government records included workers compensation claims files where claims had been made by individuals alleging that they had asbestos diseases of the lungs claims against various companies that were their employers some of which companies were also manufacturers of asbestos insulation products these individuals has used in the course of their work This specifically includes workers compensation claims made against Mundet Cork Company For a discussion of the history of workers compensation claims made against insulation insulation contractors including Mundet Cork Company please see Chapter 3 of my book and Legal Aspects 5th Ed 2005 pages 133 to 214 which is attached hereto as Exhibit hereof manufacturers and Asbestos Medical 1 and made a part I have reviewed the following exhibits identified by the plaintiffs in the instant case and I am familiar with them having researched and located these and other workers compensation records beginning in 1978 through legal discovery and direct approaches to workers compensation boards in a number of states Exhibit a WC b 5142 C. 5143 d 5155 e 5156 f 8046 g KN h 5151 . 5145 j 5149 k 5144 I 8047 m 5153 n 5159 0 5146 p 515 Description Mundet Workers Compensation Documents Edward Campbell 1954 Mundet Workers Compensation Documents Jack Cuthberson 11/10/1954 Mundet Workers Compensation Documents John E. Swartout 12/28/1955 Mundet Workers Compensation Documents L. J. Streithorst 4/27/1960 Mundet Workers Compensation Documents William & Mary Dean 9/27/1960 Mundet Workers Compensation Documents Clarence Faciane 3/15/1961 Mundel Workers Compensation Documents Rescomb E. Borden 3/22/1961 Mundel Workers Compensation Documents James J. Reilly 6/14/1965 Mundet Workers Compensation Documents John D. Staples 5/17/1962 Mundet Workers Compensation Documents Steve Gilivich 12/14/1964 Mundet Workers Compensation Documents John Wyss 1/10/1962 Mundet Workers Compensation Documents Edward Meyer 12/17/1962 Mundet Workers Compensation Documents Leonard Charles Brokenshire 9/25/1978 Mundet Workers Compensation Documents Arthur H. Miller 2/21/1962 Mundet Workers Compensation Documents Robert O. Goans 8/8/1963 8/8/1963 Mundet Workers Compensation Documents John Faulkner 9/18/1963 Affidavit of BARRY I. CASTLEMAN Sc.D. O'Boyle v A.W. Chesterton Company et al Fl-y06 3 10 Based on my knowledge and experience in researching the hazards of asbestos for many years including researching the workers compensation claims filed against various insulation manufacturers and insulation contractors including Mundet Cork the foregoing records itemized in paragraph 9 p in my opinion are a public records recorded or filed in a public office and from the public office where items of this nature are kept and b documents in a form and in such a condition as to create no suspicion concerning their authenticity and C. were found in a place where they if authentic would likely be and d have been in existence for more than 30 years FURTHER AFFIANT SAYETH NOT Pad Barry 1. Castleman Sc.D. TO AND SWORN on this SUBSCRIBED BEFORE ME day of MAY , 2009 to certify which witness my hand and seal of office 3/23/11 Affidavit of BARRY I. CASTLEMAN Sc.D. O'Boyle v A.W. Chesterton Company et al -3