11/28/2018 Case Number: AC 17-0694 Exhibit D From: Kennedy C. Ramos To: "Allan McGarvey"; "Dustin Leftridge" Cc: Edward Longosz (
[email protected]); (
[email protected]) Subject: Dr. Sicilia Date: Wednesday, November 28, 2018 5:24:02 PM Attachments: ZURICH-HUTT - SICILIA EXPERT REPORT HUTT (11-20-2018) (N0307325xA35AA).pdf Allan and Dustin, Plaintiff is aware of Dr. Sicilia’s general opinions as they relate to the use of, requirements surrounding, and dissemination of information about asbestos in twentieth century America. We have provided multiple dates for Dr. Sicilia’s deposition, including November 6, 13, 15, and 16. Those dates have passed and we have still not heard from Plaintiff whether Plaintiff intends to depose him. Since there has been no response to the deposition dates, and after recently deposing plaintiff’s experts, Dr. Spear and Dr. Hart, Dr. Sicilia’s opinions are reflected in the attached report, with a supplement to follow if necessary when Dr. Hart’s deposition is received. We are providing this report in lieu of the deposition such that Plaintiff will adequately have a complete understanding of the opinions that Dr. Sicilia intends to provide at trial. As before, he remains available for deposition. Please let us know if you would like us to obtain additional dates. Regards, Kennedy C. Ramos, Esq. | Associate **Admitted in Alabama, Virginia and DC ECKERT SEAMANS CHERIN & MELLOTT, LLC 1717 Pennsylvania Avenue, N.W. • 12th Floor • Washington, DC 20006 (202) 659.6675
[email protected] eckertseamans.com Expert Report of David B. Sicilia November 20, 2018 I am an Associate Professor of History and hold the Henry Kaufman Chair of Financial History at the University of Maryland, College Park, MD.