Document 71zvK3w3qwoVgEYQXMz8E0n0B

BILL PARRISH EDWARD J. CARROLL STEPHEN L KATZ JOSEPH B. PURTEET LA'S' OFFICES OF BILL PARRISH A PROFESSIONAL CORPORATION 1255 POST STREET. SUITE 1100 SAN FRANCISCO. CALIFORNIA 94109 (415) 928-4800 f, , NORMAN GORDON -.0 I l|U^'^fe|STAKT AUG (^WRUSSO ADMINISTRATOR July 5, 1988 Laughhn, Fatoo, Levy & More^ r*y>nriztetl JUL 12 1989 Alfonso J. Moresi, Esq. LAUGHLIN, FALBO, LEVY & MORESI ICEHOUSE II 151 Union Street, Suite 300 San Francisco, CA 94111-1221 RECEIVED f&W RE: . eceased) v. SHERWIN WILLIAMS COMPANY and INSURANCE COMPANY OF NORTH AMERICA WCAB Case No.: OAK 141300 P&A File No.: 2574 Dear Mr. Moresi: This office has been retained by Pacific Employ ers Insurance Company, workers' compensation carrier for Sherwin Williams from August 31, 1982 through July 1, 1984. My initial information is that the insurance coverage only applied to the facility located at 2756 Eldorado Street in San Leandro. I do not yet know where worked. If he worked at that location then obviously there is no insur ance coverage question. If he did not work at that location then we should promptly join the appropriate carrier on behalf of Sherwin Williams. Since you seem to have assumed a coordinating role in this matter, would you please obtain copy from Sherwin Williams of personnel file and provide that to me. Also, because it will be necessary to present evidence regarding asbestos exposure or lack of asbestos exposure as well as evidence regarding safety procedures both as to how they relate to exposure and as how they relate to the negligence issue, would you please provide me with the identity of those people at Sherwin Williams who are in the best position to testify regarding these matters REDACTED N40158 0007-SWP-00580374J CONFIDENTIAL RE: 1 July 5, 1988 Page - 2 REDACTED LG it.t BtriiiriT3 AUb 0 8 labd or in the best position to provide the appropriate docu mentation that may be necessary. Thank you. Very sincerely yours, LAW QFFLKE OF BILL PARRISH BILL PARRISH BHP:ps cc: Insurance Co. of North America Attn: Clayton Johnson 0007-SWP-005803742 CONFIDENTIAL