Document evRxgGLq7mdO2X81oO89yNB79

August 5, 197k Mr* Lee R, Shealy, Claims Manager Liberty Mutual Insurance Company Westgate Plaza Building 20325 Center Ridge Read Cleveland, Ohio ijptA Sei Redacted Bear Lees Thank you for your letter of July 29, 197k and the report on the shore captioned claim* Although it appears* from a strictly evidenciary position* that we have the upper hand# it has been our experience that such claims are often "settled" with the claimant benefiting from a lade of considera tion of the facts* For example* the testimony of two "lay witnessed* would appear to be of very little significance* They can only testify to the effect that there are dust and fumes in our paint factory* Such testimony should tiddly surprise anyone* Nevertheless, the claimant's attorney apparently believes he will gain something from such testimony. In checking our files* we find no indication that any loss prevention surveys were done at the Oakland factory which might document the rnmwmm to Which Redacted *as subject throughout his employment* Dr, Coaentino's report of March 30* 1973 does indicate that x-rays disclosed "perihilar infiltrates" indicative of "somethin more than just congestive heart failure". Might there be some basis for a claim of an aggravated heart condition in this atatassMBt $y Rr. Gosentino? Although 1 will agree that the overall tame of Ur, Cosentino's report is favorable to us* 1 am inclined to hold judgment on our chances of success for the time being, Very truly yours* BBS SHERWIH-\mJLIAHS COMPANY JBKscnj Jack D, Kull, Jr,, Staff Assistant Corporate Insurance Department N40584