Document x5gxGqkENNBJ76KrN2Oa6m76g

FILE NAME: National Safety Council (NSC) DATE: 2003 DOC#: NSC159 DOCUMENT DESCRIPTION: Barry Castleman Notes Page 1 of 1 Dr. Barry Castleman From: To: Sent: Attach: Subject: "Dr. Barry Castleman" <bcastleman@earthlink.net> "Anna Costa" <acosta@levinslaw.com> Friday, December 0 5 ,2 0 0 3 5:30 PM Report of Barry L. Castleman.doc; ATT00014.htm Re: Proposed declaration Anna, here's a draft to start with. They were a member o f the.National Safety Council, which had a Public Utilities section. The 1951-63 publications of the NSC listed under officers of the section, CA Fischback, Safety Supervisor, Southern California Edison Company, L.A. as a member of various committees of the section. Draft an added par. to the effect that as a member of the NSC from at least the years 1950-63, the company had access to numerous NSC documents on dust hazards including Industrial Dust (a pamphlet first issued in 1939 that discussed asbestosis) and articles and abstracts in the NSC monthly publication National Safety News referring to asbestos (e.g., "Asbestosis, Carcinoma of the Lung" Sept. 1960; "Dusts, Fumes and Mists in Industry", data sheet published in National Safety News in Sept., 1963). Added background on, NSC in my book, ch. 10. Barry ---- Original Message----From: Anna Costa To: bcastleman@earthlink.net Sent: Wednesday, December 03,2003 5:10 PM Subject: Proposed declaration Hi Barry We met a while ago when I worked for Paul, Hanley and Harley. I now work for Levin, Simes and Kaiser, which also specializes in asbestos cases. We have a client Charles Ross who worked as general foreman of insulators at Four Comers Power Plant in New Mexico from 1968 until August 1970. This site was owned by Southern California Edison Company. So Cal has filed a motion for summary judgment in this case and I need to supply a declaration re what they knew or should have known regarding the hazards o f asbestos during that time period. If I provide a proposed decl, would you be able to take a look and perhaps sign it? Also, do you know anything specifically about Southern California Edison? Thank you very much for your help. Anna Costa 12/5/03