Document 0yw8DgVXemRj3jRYdm6DNbnJ
FILE NAME: National Gypsum (NG)
DATE: 1988 DOC#: NG076
DOCUMENT DESCRIPTION: Legal - Response of Defendant National Gypsum to Plaintiffs' Request for Production
margaret ann rose
D e H a y de B l a n c h a r d
ATTORNEYS AND COUNSELORS PLAZA OF THE AMERICAS
2 5 0 0 S O U T H T O W E R LB 201 DALLAS TEXAS 75201-2880
1214) 8 5 3 - 1 3 1 3
Septeiber 9, 1988
TELEX-5101002109 A N S W E R B A C K -D E H A Y DAL UO T E L E C O P I E R 12141 2 2 0 - 0 4 3 9
Ms. Lisa Blue Baron & Budd Tenth Floor, Dallas Federal
Savings Tower 8333 Douglas Avenue Dallas, Texas 75225
Re: Cause No. 87-16079-D; Georgiann Rowell, et al. v. Armstrong World Industries, Inc, et al.
Dear Lisa:
Enclosed please find Response of Defendant National Gypsum Company To Plaintiffs' Request For Production filed in the above-referenced matter.
Sincerely,
MAR/lkt Enclosure
cc: Mr. C. Edward Fowler, Jr Mr. Joe Michael Russell M r . Joe Riddles Mr. James T. Foley Mr. Herbert Boyland
I /y& y
No. 87-16079-D
GEORGIA:;:-; ROWELL, et al.,
Plaintiffs,
v.
ARMSTRONG WORLD INDUSTRIES
INC., et al.
Defendants
IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 95TH JUDICIAL DISTRICT
RESPONSE OF DEFENDANT NATIONAL GYPSUM COMPANY TO PLAINTIFFS' REQUEST FOR PRODUCTION
Defendant, NATIONAL GYPSUM COMPANY ("National Gypsum") re
sponds to Plaintiffs' Request for Production submitted by
Plaintiffs, GEORGIANN ROWELL, Individually and as Personal Representative of the Estate and Heirs of WINFORD ROWELL; BESSIE
S. SHEPHERD, Individually and as Personal Representative of the
Estate and Heirs of THOMAS P. SHEPHERD; LARRY D. HAYS and DONNA
HAYS; VER: N URBAN and EMO JEAN URBAN; OLIVER J. MORGAN and
MARGUERITE MORGAN ("Plaintiffs") as follows:
GENERAL OBJECTIONS
Defendant National Gypsum objects to any request or instruc
tion that purports to impose upon Defendant any obligation not
expressly set forth in the Texas Rules of Civil Procedure.
RESPONSE
1. The last known address of the following individuals:
(a) Jack E. Jones (b) F.R. Griffin (c) J.C. Quinly (d) C.D. Harless (e) R. Beitz (f) W. Withrock
RESPONSE : National Gypsum objects to this interrogatory on
RESPONSE OF DEFENDANT NATIONAL GYPSUM COMPANY TO PLAINTIFFS' REQUEST FOR PRODUCTION - Page One
the basis that the requested information is not relevant to this action, in the absence of some explanation from Plaintiffs' counsel which establishes relevance. National Gypsum objects to this interrogatory because it is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving these objections, National Gypsum states that Mr. Quinley is scheduled to be deposed on August 30, 1988, that Nati'nal Gypsum has agreed to consider producing Mr. Withrock following Mr. Quinley's deposition, and that National Gypsum provided Mr. Jones' address to Plaintiffs' counsel in another case. Jack E. Jones' address is 12 Summertree Lane, P.O. Box 1271, Shallotte, North Carolina 28459.
2. Complete and legible copies of the three letters which are attached hereto and marked Exhibits A, B and C.
RESPONSE: More legible copies of the three letters are attached to these responses.
Respectfully submitted
DeHAY & BLANCHARD
J. CARLISLE DeHAY
SBN 05644000
Plaza of the Americas
2500 South Tower, LB 201
Dallas, TX 75201
(214) 953-1313
ATTORNEYS FOR NATIONAL GYPSUM
COMPANY
*
HOYLE, MORRIS & KERR One Liberty Place, Ste. 1650 Market Street Philadelphia, PA 19103 OF COUNSEL
4900
RESPONSE OF DEFENDANT NATIONAL GYPSUM COMPANY TO PLAINTIFFS' REQUEST FOR PRODUCTION - Page Two
CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the fore going document was sent to Lisa Blue, Baron & Budd, 8333 Douglas Avenue, 10th Floor, Dallas, TX 75225 by U.S. Certified Mail, Return Receipt Requested and by regular U.S. Mail, postage pre paid to all other counsel of record in the above-referenced matter on the 9th day of September, 1988.
RESPONSE OF DEFENDANT NATIONAL GYPSUM COMPANY TO PLAINTIFFS' REQUEST FOR PRODUCTION - Page Three