Document e7x7k8V8RwD2KzbXpxpRDY7Bp

FILE NAME: INC D ATE: 2010 May 17 DOC#: INC006 D O CU M EN T D E S C R IP T IO N : Email to B C 5/27/2010 Gmail - International Nickel byCoagfe- Albert Donnay <albertdonnay@gmail.com> International Nickel 1 message Barry Castleman, ScD <barry.castleman@gmail.com> To: ADonnay@jhu.edu * new file, all attachments except "Expert Witness Disclosure..." Include the e-mail in file. Mon, May 17, 2010 at 5:22 PM -------- Original M e ssage ------S u b je ct:FW: Inco Docs for Dr. Castleman DateiMon, 17 May 2010 16:13:22-0400 From:Dave Chervenick <dchervenick@gpwlaw.com> T O : Barry Castleman < barry.castleman@gmail.com> Hi Dr. Castleman. I have 6 cases in the upcoming WV trial group and will be on the phone for your depo tomorrow. International Nickel Co. plant in Huntington WV from 1965-1995. I have attached some INCO docs provided on a disk, they were among several thousand docs provided by INCO. As you can see, there is a 1935 memo from a meeting dealing with silicosis which deals with ways to prevent silicosis. I have included several safety memos mentioning asbestos cloth and the need to put the cloth back on the shelf, but no warnings about breathing the dust emitted from the cloth, I have also included a 1965 IHF report by Morton Corn which discusses the TLV, but not for asbestos, and makes it clear that the TLV was not a bright line between hazardous and non hazardous. I have some old interrogatory answers from INCO, not included here, wherein they state that they didn't even hear about a TLV until 1976. They admit to being members of the NSC from the 1940's through the 1980's, and they say that they were members of the IHF. I have some IHF surveys of their plant going back into the 1940's.. Since my client was employed there, we need to prove "deliberate'intent", which is basically gross negligence. Dave Chervenick 10 attachments Expert 14K Witness Disclosure Castleman _June 2010 TG_.pdf a UE&C. - Notes of Shop Stewards Safety Meeting No. 4.PDF H 7ok 10-22-35 Memo to Shoffstall.pdf 106K ; mmu. IHF - Report on Industrial Hygiene Survey of Selected Plant Ope rationsfor Huntington Alloy Products.PDF yd 4ok a Notes of UE&C Safety Meeting No. 15 _.PDF id 62K a Notes of UE&C Safety Meeting No. 59.PDF ^3 66K ^ Notes of UE&C Safety Meeting No. 81.PDF m 54K a Notes of UE&C Safety Meeting No. 104.PDF *3 80K a Notes of UE&C Safety Meeting No. 135.PDP 18 71K $ S UE&C 51K Notes of Safety Meetig - No. 140 _.PDF https://maiLgoogle.com/mail/?ui=2&ik...