Document mbr9XOwRZ37MOrqaLyq3EMwYb

FILE NAME: Sperry Rand (SR) DATE: 2019 July 31 DOC#: SR008 DOCUMENT DESCRBCIPTION: Letter to BC B IR IB IS BROOKMAN ROSENBERG BROWN SANDLER A T T O R N E Y S AT L A W MELVIN BROOKMAN (1926-2000) HOWELL K. ROSENBERG LAURENCE H. BROWN CARY L. SANDLER JOHN M. DIDONATO" STEVEN J. COOPERSTEIN DAVID B. HALPERN" PAUL J. RILEY RIKI R. STROSSER** "Also member of New Jersey Bar. Dr. Barry I. Castleman P.O. Box 188 Garrett Park, MD 20896 July 31, 2019 Re: Sperry/Unisys Michael Lombardo v. Unisys P.C.C.P. April Term 2015, Nn. 2140 Dear Dr. Castleman: Thank, you for agreeing to review the above-captioned matter. As we discussed on the phone, our client, Michael Lombardo, worked at Sperry/Unisys (the company became Unisys in 1985/1986) as a computer programmer. He worked in the Blue Bell, Pennsylvania facility from 1974 through the early 1990s. I have enclosed an Affidavit from Thomas Morrison, a co-worker, who describes renovations that took place at Blue Bell beginning in 1974 until the 1990s. This renovation turned an old manufacturing plant into an office facility. We contend as a result of the dust created from removing asbestos products ineluding tiles and pipe covering, Mr. Lombardo was exposed to asbestos dust causing his death from mesothelioma. For your review, I have also enclosed the 1951 National Safety Council (NSC) meeting for the National Safety Congress. You will note that Thomas Morgan, Chairman of the Board at Sperry, (p. 97), was a member of the NSC. AdditionailyfT Have"sent to you a copy o f the American Industrial Hygiene Association Me nbership Book for 1970-1971. On page 58 you will see that one o f the members was E. R ose. e Evavold o f Sperry. In addition to those documents, you should know that Kevin Krueger, corporate representative o f Unisys, recently testified. Mr. Krueger admitted that before 1985, Sperry/Unisys did not have any program to determine if employees were exposed to asbestoscontaining dust from the Blue Bell renovation He also acknowledged that Sperry/Unisys did not know what NIOSH had to say about asbestos irom 1974 through the mid-1980s. Finally, Mr. ONE PENN SQUARE WEST, 17th FLOOR, 30 SOUTH 15th STREET, PHILADELPHIA, PA 19102 215.569.4000 800.369.0899 FAX: 215.569.2222 '\ir\IT Kt-Vvc r- Page 2 Krueger testified that despite hiring an abatement company in 1986 to complete renovations, asbestos dust continued to be an issue at Unisys necessitating a 1991 operating manual finally informing employees regarding asbestos dust still being created at the facility. The bottom line from Unisys is that they claim they did not know the products in the renovation contained asbestos until the mid-1980s and, that, regardless, the 1972 OSHA requirements were not applicable to their business. We would request you review this matter and provide a report which discussed the state of the art with specific reference to what, if any, knowledge Sperry/Unisys did or should have had from 1974 through 1991. Please feel free to contact me should you have any questions. Very truly yours, Brook/nan^Losenber; Brown and Sandler BY: V * PJR/ag