Document JvbrObJj7YBVRBKvNjXOnELB

40 Palerson Street New Brunswick, NJ 08901 Tel: (732) 545-4717 Fax- (732) 545-4579 www.hoaglandlongo.com Michael L. Lazarus Of Counsel mlazarus@hoaglandlongo.com A T T O R N E Y S St L A W September 26, 2013 PLAINTIFF'S EXHIBIT W C D -251 Leah Kagan, Esq. Levy, Phillips & Knigsberg. LLP 800 Third Avenue, l lth Floor New York, NY 10022 Rc: Kacnzig Sr, Steven (NJ) vs. Whittaker Clark & Daniels Our File No.: 5965882 -MLL Docket No.: MID-L-4873-12 Dear Ms. Kagan: I am in receipt of your September 24, 2013 letter regarding Judge Le Blon ruling on September 19, 2013. I acknowledge receipt of the contents referred therein. I also acknowledge receipt o f the trail exhibits identified in Plaintiffs pretrial exchange. I will return those materials by October 411' should I decide that testing is appropriate. Finally, as per (he request made by you at Dr. Nolan's deposition and the formal request made by you thereafter I enclose two samples of talcs, no. 1615 and 141. The third talc is not relevant to this litigation based on your expert's opinion. 1will draft an appropriate order regarding the court's decision in short order. Very truly yours, MLLunme Enclosures MICHAEL L. LAZARUS New Brunswick, NJ New York, NY Buffalo, NY Philadelphia, PA Clinton, NJ - Wall, NJ Hammonton, NJ Michael L. Lazarus, Esq. (ID #032211982) HOAGLAND, LONGO, MORAN, DUNST & DOUKAS, LLP 40 Paterson Street, PO Box 480 New Brunswick, NJ 08903 (732)545-4717 Attorneys for Defendant, Whittaker, Clark & Daniels, Inc. Plaintiffs, STEVEN G. KAENZIG, SR., and LINDA KANZIG, vs. Defendants, CHARLES B. CHRYSTAL COMPANY, et al. SUPERIOR COURT OF NEW JERSEY MIDDLESEX COUNTY LAW DIVISION DOCKET NO. MID-Lj-4873-12 CIVIL ACTION ; CERTIFICATION'ROBERT PATRICK NOLAN, PH.D. HOAGLAND, LONOO MORAN, 0UNST & DOUKAS, LLP ATTORNEYS AT LAW NORTH JERSEY OPAItRSONST PO BOX 480 NOV BRUNSWICK. NJ SOUTH JERSEY 701 WITSEYS MURO SUTE 20? HAMMCNT0N.HJ I, Robert Patrick Nolan, Ph.D, do hereby certify as follows: i 1. I have been retained as an expert by the law firm of Hoagland, Longo, Moran, Dunst I & Doukas, LLP, attorneys for Defendant, Whittaker, Clark & Daniels, Int., in this matter. I 2. The enclosed samples of Whittaker, Clark & Daniels talc;products No. 141 and No. 1615 were obtained by my colleague, Arthur M. Langer, Ph.D., in 1977. jh e samples were shipped | to him by Mike Roark of Helena Rubenstein Laboratories, Inc., on or about December 2, 1977. Exhibit A, Correspondence from Mike Roark to Arthur M. Langer dated December 2,1977; Exhibit B, Copy of shipping container including label addressed to Arthur M. Langer and postage stamp i dated December 2, 1977. j 3. The samples provided by Helena Rubenstein Laboratories to Dr. Langer included an i inventory or packing slip from Whittaker, Clark & Daniels, Inc. dated November 9,1977, to show that the samples were Whittaker, Clark & Daniels products. Exhibit C, packinjg slip from Whittaker, Clark t & Daniels, Inc. to H.R. Laboratories, Inc. dated November 9, 1977. 4. The samples were kept in their original packaging in the laboratory I shared with Dr. Langer at Mount Sinai Medical Center. 5. In 1988 Dr. Langerand I relocated to Brooklyn College, where we continued to store the samples in their original packaging. 6. When Dr. Langer left Brooklyn College in 1996, I moved the samples to a storage i facility called Storage Mart in Secaucus, New Jersey. I am the only perspn in possession of a key to this facility. 7. I am temporarily turning over possession of the samples to Michael L. Lazarus, Esq I of the Hoagland, Longo firm, so that he can respond to discovery requests from counsel for Plaintiffs in this matter on behalf of Whittaker, Clark & Daniels. 8. I hereby certify, pursuant to Rule 1:4-4(b), that the foregoihg statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Dated: September 26, 2013 HOAOLAND.IONOO MORAN, tXJNST & IXXKAS.IU ATTORNEYS AT LAW NORTH JERSEY 40 PATERSON ST PO BOX 490 NEWBRUNSWCK.NJ SOUTH JERSEY 701 W USCYSM URD SUTF202 HAMMiDNTCW.MJ EXHIBIT A Mr. Arthur Langer: Enclosed are samples of old talc products from the Helena Rubinstein archives and also recent talc samples. M rk e Roarh 1 2 /2 /7 7 D. M. ROARK EXHIBIT B EXHIBIT C I SAMPLES FROM WHITTAKER, CLARK & DANIELS INC. 1000 COOLIDGE STREET SOUTH PLAINFIELD, NEW JERSEY 07080 To H . B , U b a r a t a r i i M r T n e a irp a n iiM i 1 Northern Bmilevaxd a t E ast K ill .......... i G roem rale. Lana X ela a d . NY 11348 M r* H . P - S c h n e id e r 141 A lp in e T a lc USP B O L o t # 5 - 7 - 8 , Jims 3 , 1974 ( S a n g le not b acteria con trol] ed) i 1613 ASX T a lc BC* Lot 443613, A pril 22, 1974 j (Sam ple not b a c te r ia c o n tr o lle d ) H , 4 .SC H N EID ER 447 3 W hite Snow T a lc L ot 6 7 7 5 8 , A p r il 22, 1974 9 19/7 ov RECEIVED R R K /s d /2 3 Forwarded V ia :........ Date Sent.... D ate...l l / S f / 71. I Exhibit 6