Document wD5ddRBxp5d7BxM9VpKxnN0rE

11:54 From:MHCM 2156239257 To:12145201181 P.4'7 1 Law Offices WILLARD, HOLWEGER, CHILD & MARTON 2 Bradford T. Child - Slate Bar No.: 96350 700 South Flower Street, Suite 3050 3 Los .Angeles, CA 90017-4101 Telephone No. (M3) 627-3113; Facsimile No. (213 ) 623-0237 4 5 Attorneys for Defendant, FLAMEMASTER CORPORATION 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 11 .ANDREW SCHNABEL and AUDREY SCHNABEL, 12 Plaintiffs, 13 vs. 14 BORGWARNER MORSE TEC,. INC., (sued 15 individually and as successor-in-interest to BORG-WARNER NORSE TEC, INC., AND 16 BORG-WARNER CORPORATION) et al. 17 Defendants. 18 ) Case No. BC 392554 ) (Assigned to Hon. Irving S. Feffer, Dept ) "51") ) ) ) DECLARATION OF JOSEPH MAZLN ) RE: THE USE OF ASBESTOS IN ) FLAMEMASTER PRODUCTS I I ) ) ., ) Complaint Filed: June 11,2008 19 I, Joseph Mazin, declare as follows: 20 1. I am the Chief Executive Officer' of Flamemaster Corporation. I have been the 21 CEO of Flamemater Corporation since June 6, 1984 . As the CEO, one of my duties is to 22 coordinate and supervise litigation on behalf of the Flamemaster Corporation. In connection with 23 those duties, I have reviewed and maintained the corporate records regarding the use of abestos in Flamemaster products. I have personal knowledge set forth herein and if called upon to do so, I could and would competently testify thereto under oath. 2. Flamemaster Corporation was founded in 1942. Originally known as Dynatherm Corporation, the entity changed its name to Flamemaster Corporation, on August 23, 1973. _L-___________________________________________________ DECLARATION OF JOSEPH MAZIN RE: THE USE OF ASBESTOS IN FLAMEMASTER PRODUCTS JUL-21-2010 11:55 From:MHCM m n l. i t i w r-t K Ik ** f ' 136239237 ISO TAYLOR STREET. P.D BOY 365, MONROVIA, CALIFORNIA 91016 To:12145201131 P.6'7 uug ivumuci |2I3| 3S7-3J47 83026 lent Dynatherm Corporation ate rial/Sample Identity Work Order P. 0, Number 6270-01 4629 Rebd Due Sampling Program for Asbestos in Air 9/6/73 9/8/73 ^quested By Sample Disposition ime: Dr. Roger Peterson- Phone:982-1650 ;po rt/ Ship T o: Dynatherm Oorporat ion 598 W, Avenu-e 26 Los Angeles, CA 90065 a cure of Work and. Into rmation Desired Air Sampling-for Asbestos Fibers imm&ry of Laboratory Report . . ' . Q. C. Level In a room 12* x 16' with only a single closed door, there was sprayed approximately 30 gallons of Flame mastic '71-A onto a plastic sheet laid on the .floor* Two filter samples were taken simultaneously during the spraying--one at the operator's left shoulder, the other about 8 ft. to his right. The test duration was 30 minutes at an air flow of 1 liter peT minute through each filter, A blank, was run for comparison* The test ws.s witnessed by Mr, Stanley Zwick.er of Region IX, Environmental Pro tection Agency. - . '' Microscopic examination according to the publication, "Occupational Exposure to Asbestos," HSM 72-10267,.., 1972, showed no. asbestos fibers ,in either the blank-or the samples. ' , if * ,il protection to client*. this report is submitted :or the encWive use of the client to 'Attorn it is addresed. T-.-.s ,-tr: rt aoplir* only ip the sampif > tested and is r.M nfeet fiarily Indicat ive of the qualities *; apparently similar r idsr.ticai prodads. L`se of thi$ report w hether ir, whsle dt in part, or of any teals or tr.sipma c:,r,heeled therewith, r'.itinc or publicity matter, -a f.houi priqr anS'.tr. -lull ' ' ' '' naly st Book - Page Date T .. ---------------________________________________ _____9/7/73 Re sear An and Devplrttimanf JUL-21-2010 11:55 From:MHCM 2136259257 To:12145201181 ANALYTICAL RESEARCH LABORATORIES, INC. 2 60 TAVLQR STREET, P.0, BDX 36. MONROVIA, CALIFORNIA 93036 - (2131 357-3247 P. 7^7 7 September 1973 LL 83026 Dynatherm Corporation personnel carried out a spray test of Flame mas tic 71A in an utiventilated room 12' x 16' x B'. The white cable protection material was sprayed in a manner which simulated an actual field applica tion under the most difficult conditions which could be anticipated with, respect to airborne asbestos fibers* An earlier test (ARLI 33038) conducted under less rigorous conditions had shown no airborne asbestos fibers were produced during the spray application of Flamemastic 71A* Thirty-gallons of'mafcerial was sprayed in a period of thirty minutes using Graco airless Hydra Spray equipment with a Grace Hydra Spray Gun and Tip 4 PIN 2-0?-901 as described in the Dynatherm Application Bulletin #004. Two filter samples were taken simultaneously during the spraying --- one at the operators left shoulder, and the other about eight feet to his right. The air .flow was 1 liter per minute through each filter during the 30 minute test. Prior to the spray test a blank was nid for 30 minutes to provide a comparison with the. test filters. ' .7 It was observed that no visible emission of asbestos material was released, to . the atmosphere of the room during the spray test, ; ' , Microscopic examination of the filter discs performed according to "Occupa tional Exposure to Asbestos", HSM 72.-10267, 1972, published by NIOSH, showed no asbestos fibers in either the blank or the sample,' "" . , .