Document nb0G8Baq3R5wKdXBRbX7451R

FILE NAME: Baldwin (BALD) DATE: 1997 June 12 DOC#: BALD002 DOCUMENT DESCRIPTION: Letter to Barry Castleman RE Trujillo vs. Sante Fe and Dial Corp. from John Roven & Assoc. JOHN ROVEN & ASSOCIATES, P.C. ATTORNEYS AT LAW 9575 Katy Freeway Suite 400 Houston, Texas 77024 TELEPHONE: 713/465-8522 FAX: 713/465-3658 June 12,1997 Dr. Barry Castleman 1722 Linden Avenue Baltimore, MD 21217 Re: Trujillo v. Santa Fe Railway and Dial Corp. (Successor to the Baldwin Locomotive Works) - Trial Setting: July 28,1997, Albuquerque, New Mexico Dear Dr. Castleman: We are now skirmishing with the Defendants to determine whether the Trujillo trial date will "hold" in July. We believe that it will. I would anticipate that Plaintiffs case will commence on July 29 or July 30th and continue through that week, and possibly into the following week. The purpose o f this letter is two-fold: first, because we have got some advance planning going on, we ju st wanted to check your schedule to see if you have a preferred time to testify. If so, I would appreciate it if you would coordinate this to let us know. Once we have an absolute firm trial commitment from the Court, we can begin travel plans for you. Second; the Defendant Dial (successor to Baldwin) is a relative new comer to asbestos litigation and for that reason, it is probable that they might want to take your deposition. We have sent them some prior transcripts so they can make the decision of whether or not they want to depose you. Their initial inquiiy was to determine whether or not they could do the deposition in Albuquerque. I told them that this was highly unlikely unless they wanted to pay additional airfare to get you there. As you know, the general rule is that the Defendant must travel to you to depose you. However, if you would like to go to Albuquerque for some reason, please let me know. Tentatively,! believe that the ideal week for your deposition would be just following July 4th (the week o f July 7th. Please let us know if you will be available for a deposition date during that week, either at home, or in Albuquerque (your choice). Stacy, my paralegal, will try to set things up so we will have plenty of advance time to confer prior to the deposition. Looking forward to hearing from you soon, I am Sincerely, JOHN ROVEN & ASSOCIATES, P.C. /V.O'/i ///' ' / Join) D. Roven