Document E9X7amG0BR711rZnjxbNm5Vb

FILE NAME Riley Stoker RS DATE 2010 Aug 24 DOC RS002 DOCUMENT DESCRIPTION Legal - Declaration of Barry Castleman Excerpt ReSF Complex Ashlitigatioln itigation RILEY POWER 2 57. Until 1972 Riley Power formerly known as Riley Stoker Corporation and 3 hereinafter referred to as Riley incorporated and specified the use of containing 4 component parts into their industrial boilers This would include gasket material packing 5 material insulation material and asbestos rope Riley had actual knowledge of asbestos hazards 6 This is in part evidenced by historical Worker's Compensation claims for asbestos 7 disease which are disclosed in Riley's responses to San Francisco General Order No. 129 8 Standard Interrogatories and which reference asbestos related claims by Ernest Moreno in 1947 9 and Lewis Munger in 1956. True and correct copies of these claims as well as these responses 10 are attached hereto as Exhibits A - D 11 58. These workers compensation claims allege that workers who worked for Riley using 12 12 containing products had sustained injuries for asbestos exposure Thus they are relevant 13 to notice on the part of Riley as to the dangers of asbestos Specifically they show that Riley 1414 had actual knowledge and direct notice as early as 1947 that people working with and around asbestos could sustain potentially disabling and even life threatening illnesses namely 16 asbestosis 16 59. Therefore by the late 1940s Riley was aware of the adverse health effects of its 18 products and yet took no action to disclose or reveal the hazard or protect anyone from known 1919 hazards 2020 I declare under penalty of perjury under the laws of the State of California that the 24 2121 foregoing is true and correct Executed 2222 Maryland day of August 2010 in Garrett Park 22222222 CASTLEMAN BARRY CASTLEMAN 22222222 I. 22222222 22222222 N,, N N ,,,, 17 DEC OF BARRY CASTLEMAN Sc.D. ISO PLAINTIFF'S OPP TO RILEY's MSJ