Document 6OJk4Vn70nkbemX5nRRy80p3

FILE NAME: Wagner (WAG) DATE: 2016 Feb 15 DOC#: WAG036 DOCUMENT DESCRIPTION: Letter to Barry Castleman from Jacobs & Crumpla RE Barlow vs. Wagner Co. Jacobs & Crumplar, RA. Attorneys at Law Robert Jacobs Thomas C Crumplar Elizabeth B. Lewis Jordan J. Perry Raeann C. Warner David T. Crumplar February 15, 2016 BARRY I. CASTLEMAN Environmental Consultant P.O. Box 188 Garrett Park MD 20896 Re: Herbert Barlow v. Charles A. Wagner Co., Inc., et al. C.A. No. 14C-02-024, Del. Super, Ct. Dear Dr. Castleman, I write to request that you testify at trial in Wilmington, DE on June 13, 2016. This trial that involves our plaintiff, Herbert Barlow, who worked at the Dupont Seaford plant from July 1965 until May 1971, during which he used and was exposed asbestos sweeping compound supplied by defendant, Charles A. Wagner Co., Inc. Asbestos Corporation Limited is also a defendant in this case as it supplied fiber to Wagner. For information regarding Wagner, I have enclosed our opening brief on appeal in multi cases that was filed in the Delaware Supreme Court in March 2003, as well as the appendix to the brief which includes supporting documents and testimony regarding Wagner and its presence at the Dupont Seaford plant. In addition, enclosed are the following: 1. W agner's answers to interrogatories; 2. Memo o f National Paint, Varnish and Lacquer Assoc, dated 7/18/39; 3. National Paint, Varnish and Lacquer Assoc.'s Abstract Review o f HAZARDS: Dusts, Fumes, and Mists in Industry, Anon.,-Nat. Safety News, 87, No. 89-93, 95-105 (June 1963); 4. OSHA S&H Bulletin 10, July 19, 1972 to National Paint & Coatings Assoc. Very truly yours, RW:pra EnCt e . h S , M P O B o x . 2 7 1 Wilmington, DE 19899 (302) 656-5445 w w w .jcd e law .co m 202 Dupont Highway Millsboro, DE 19966 (302) 934-9700