Document 2Rvd1pJY9GOygOrkaL2knDzeg

JUL. 10.00* 0031 8 Kasowitz, Benson, Torres & Friedman llp 700 LOUISIANA STREET, SUITE 3200 HOUSTON,TEXAS 77002 1301 AVENUE OF THE AMERICAS NEW YORK, NEW YORK 10019-6022 2 l 2-506-1700 713-220-8800 FACSIMILE: 713-222-0843 writer's direct dial number 713-220-8878 ONE GATEWAY CENTER SUITE 2600 NEWARK, NEW JERSEY 07 102 973-6A5-9A62 July 7, 2000 Via Certified Mail Return Receipt Requested Alicia J. Haff, Esq. Baron & Budd 3102 Oak Lawn Ave., Ste. 1100 Dallas, TX 75219 Re: Np. 4333*RM98; Vicente Moreno Rodriguez v. Owens Corning, et al.; In the 149th Judicial District Court of Brazoria County, Texas Dear Ms. Haff: Enclosed please find Defendants CNA Holdings, Inc. and Celanese Ltd.'s Supplemental Rule 194 Disclosures in the above-referenced matter. Very truly yours, EMG/cr Enc. tda Meadough Graham 64070 1 Kasowitz, Benson, Torres & Friedman llp 700 LOUISIANA STREET, SUITE 2200 HOUSTON,TEXAS 77002 1301 AVENUE OF TH AMERICAS NEW YORK, NEW YORK 10019-6022 212-506-1700 7(3-220-8800 FACSIMILE: 713-222-0843 writer's DIRECT OIAL number (713) 220-8878 ONE GATEWAY CENTER SUITE 2600 NEWARK, NEW JERSEY 07 102 973-6*5-9*62 July 7, 2000 Via Certified Mail Return Receipt Requested Mr. Jerry Deere District Clerk, Brazoria County 111 East Locust Street Angleton, Texas 77515 Re: Cause No. 4333-RM98; Vicente Moreno Rodriguez v. Owens Corning, etai\ In the 149th Judicial District Court of Brazoria County, Texas Dear Mr. Deere: Enclosed for filing in the above-referenced matter is an original and one copy of Defendants CNA Holdings, Inc. and Celanese Ltd.'s Certificate of Written Discovery regarding Celanese's Supplemental Rule 194 Disclosures. Please file-stamp the extra copy and return it to us in the enclosed stamped, selfaddressed envelope. Thank you for your assistance. Very truly yours, Erica Meadough Graham EMG/cr Enclosure cc: Plaintiffs' Counsel (with enclosure) Defense Counsel (without enclosure) 64068.1 NO. 4333*RM98 VICENTE MORENO RODRIGUEZ Plaintiff, V. OWENS CORNING (a/k/a OWENS CORNING CORPORATION), ET AL,, Defendants. 9 K9 IN THE DISTRICT COURT OF BRAZORIA COUNTY, TEXAS 149TH JUDICIAL DISTRICT DEFENDANTS CNA HOLDINGS, INC. AND CELANESE LTD.'S SUPPLEMENTAL RULE 194 DISCLOSURES In accordance with Rule 194 of the Texas Rules of Civil Procedure, and as a supplement to Plaintiffs' Request for Disclosure, Defendants CNA Holdings, Inc. and Celanese Ltd. This disclosure is necessarily partial and Celanese reserves the right to supplement its responses, because plaintiffs deposition testimony has not been obtained and plaintiffs independent medical examination has not been completed. (c) Defendants owed no duty, legal or otherwise, to plaintiff and are therefore not liable for any of plaintiffs alleged injuries or damages. (e) See Defendants' Persons with Knowledge List for Plaintiff Rodriguez, attached hereto as Exhibit A. (f) See Defendants CNA Holdings, Inc. and Celanese Ltd.'s Designation of Expert Witnesses, served on plaintiff June 7, 2000, which is incorporated herein by reference as if fully set forth at length. Further, Defendants designate the following additional expert witnesses: 1) William L. Dyson, PhD., C.I.H., Workplace Hygiene, llc, 1022 Jefferson Road, Greensboro, North Carolina 27140 Dr. Dyson is a certified industrial hygienist. He received a bachelor of science 63971 1 degree from North Carolina State University in 1973, a master's degree in environmental health engineering from Northwestern University in 1971, and received his doctorate in environmental health engineering from Northwestern University in 1975. From 1967 through 1969, Dr. Dyson worked as a field industrial hygiene engineer for the U.S. Public Health Service providing industrial hygiene services to the public. From 1973 through 1982, Dr. Dyson worked extensively as a practicing industrial hygienist in American industry. Dr. Dyson has worked as a self-employed industrial hygiene consultant from that time through the present. Dr. Dyson is a fellow of the AIHA, a member of the American Academy of Industrial Hygiene, a diplomate of the American Board of Industrial Hygiene, a member of the American Society of Safety Engineers and other professional organizations reflected on the attached curriculum vitae. Dr. Dyson will provide testimony regarding the history of industrial hygiene, industrial hygiene methods, exposure levels which trigger diseases associated with dust exposure, good housekeeping measures, and other related matters. He is prepared to testify about respirator history, what constitutes good hygiene practice, and the periods of time from an industrial hygiene standpoint when people and companies became aware of associated health risks. Dr. Dyson may give testimony regarding the level of fiber release, if any, from asbestos-containing products in the occupational setting and may testify regarding the availability of materials as substitutes for asbestos-containing products. He may testify as to issues involving re-entrainment and fiber drift. Dr. Dyson may also testify regarding work practices applicable to various types of occupations using products that contain asbestos, and he will provide a retrospective assessment or estimate of plaintiffs likely exposure to asbestos in a Celanese work environment based on historical literature and the facts available in this case. Dr. Dyson has personal knowledge of relevant facts, but he also possesses generalized expertise in his field based on his specialized knowledge, skills and training. He may provide testimony regarding the applicability of the ACGIH, OSHA and EPA guidelines as they relate to occupational exposures to various types of asbestos-containing products. Dr. Dyson may testify regarding the size, construction, layout and working environment of facilities such as where plaintiff worked. He may testify about the nature of the working environment in such locations. He may testify about his knowledge of the composition and asbestos content, if any, of products present in the plaintiffs workplace and may testify concerning the ability of such products to emit asbestos fibers under certain conditions. Dr. Dyson may testify to the dust levels produced by particular occupational operations and products, to include those associated with the use of pipe and block insulation. 63971 1 2 Dr. Dyson may testify about the development of literature and information about asbestos-related diseases as they relate to the gradual development of knowledge within industry and within the field of industrial hygiene about asbestos exposure and appropriate control measures. He will address the evolution of workplace practices available to control exposures, to include the historical development of the use of respiratory protection in association with the handling of asbestos-containing products. Dr. Dyson will testify regarding the development over time of governmental standards and regulations pertaining to asbestos, to include the historical evolution of permissible exposure levels to asbestos developed by professional organizations and government agencies. He will discuss his own research into asbestos-related diseases as they relate to industrial hygiene, the carcinogenicity of various fiber types as they relate to industrial hygiene, and the relationship, if any, between asbestos and various diseases. Dr. Dyson will provide testimony regarding the epidemiology of asbestos-related diseases, latency, stateof-the-art, and other related matters as they impact industrial hygiene. Based on the above evidence developed in this case, Dr. Dyson will testify that the plaintiff at issue had little or no opportunity for any harmful exposure to asbestos while working at a Celanese facility because of the nature of plaintiffs occupation and particular working environment, and he will also testify that Celanese's approach to the handling and control of any asbestos-containing materials on its premises was reasonable in light of available information and industrial hygiene practices at different points of time. He may also testify as to any matter raised by experts called by plaintiff or any co-defendants in this action. 2) William G. Hughson, M.D., PhD., Center for Occupational and Environmental Medicine, UCSD Medical Center, 200 West Arbor Drive, San Diego, California 92103-8800 Dr. Hughson received his bachelor of science degree from the University of Calgary in 1970 and his medical degree from that same institution in 1973. He received his doctorate in epidemiology from Oxford University in 1977. Dr. Hughson is board certified in internal medicine with subspecialty certifications in pulmonary medicine and occupational medicine. Dr. Hughson has taught medicine at the University of California, San Diego for many years through the present. Dr. Hughson is a fellow of the American Thoracic Society, The American College of Chest Physicians, The American College of Occupational and Environmental Medicine and other professional organizations reflected on the attached curriculum vitae. Dr. Hughson will testify about the pathology of asbestos-related diseases, his research into asbestos-related diseases, the carcinogenicity of various asbestos fiber types, the potential for asbestos-related disease as a result of exposures to the different types of fibers and the relationship, if any, between asbestos and various illnesses. Dr. Hughson will also testify regarding the general pulmonary aspects of asbestos exposure, including matters such as dose response, latency and the required fiber burden associated with asbestos-related illnesses. Dr. Hughson is 63971 1 3 expected to testify about alleged occupational exposure - as described by plaintiff and plaintiffs witnesses - and whether, based on his own experience and his review of the medical, scientific and/or technical literature and the opinions and conclusions contained in that literature, whether any exposure at a facility owned or operated by Celanese could be considered a substantial contributing factor to plaintiffs alleged disease. Dr. Hughson has personal knowledge of certain relevant facts but also possesses general expertise in his field based upon specialized knowledge, skills and training. Based upon his own experience and his review of the medical, scientific and/or technical literature and the opinions and conclusions contained in that literature, Dr. Hughson will provide historical state-of-the-art testimony on the gradual development of knowledge within the medical profession about the various diseases associated with asbestos and about the asbestos exposure levels thought to be associated with each disease. Dr. Hughson will testify regarding the reasonableness of Celanese's historical usage and control of asbestos in its workplace from a medical standpoint based on the information available in the general medical literature and on the types of preventative measures considered by the general medical community as appropriate in the different decades from 1900 through the present. r Dr. Hughson is expected to testify about the principles of epidemiology and what is involved in an epidemiologic study. He is expected to testify that studies of particular groups or occupations of people are not necessarily applicable to other groups or occupations. Dr. Hughson is expected to testify as to the information necessary to determine whether a group of people are at risk of contracting a particular asbestos-related disease, and whether it is scientifically possible to attribute a disease to a particular exposure. Dr. Hughson is expected to discuss epidemiological analysis of asbestos and how such analysis may be applied to the evidence in this case and to the plaintiff. Dr. Hughson may testify regarding plaintiffs medical condition, cigarette smoking and lung disease, and generally about the pulmonary system and its functions as well as the diagnosis and prognosis of asbestos-related markers and diseases, and the risks associated with developing cancers. Dr. Hughson is also expected to testify about any matter raised by experts called by plaintiff or any co-defendant, including but not limited to plaintiffs medical condition, the state of medical knowledge concerning asbestos, asbestos-related disease and other occupational diseases. 3) Peter J. Barrett, M.D., 300 Boylston Street, Suite 714, Boston, Massachusetts 02116-3923 Dr. Barrett received his bachelor of arts degree from the College of The Holy Cross in 1964 and his medical degree from Tufts University School of Medicine in 1968. 63971 1 4 Dr. Barrett is board certified in diagnostic radiology and nuclear medicine. Dr. Barrett has taught radiology at Harvard University and at other institutions over the years. He is a NIOSH certified "B" reader and is a fellow of the American Thoracic Society, the American College of Chest Physicians, the American College of Radiology and other professional organizations reflected on the attached curriculum vitae. Dr. Barrett is expected to testify generally about radiologic concepts and evaluation and their relation to the diagnosis of pulmonary diseases. He will testify specifically regarding his evaluation of x-rays and CT scans in the diagnosis of occupational pneumoconiosis. It is anticipated that Dr. Barrett will testify generally as to his interpretation of the plaintiffs chest images, the presence or absence of any asbestos-related condition as evidenced by those films, and the presence of other abnormalities or conditions unrelated to any exposure to asbestos. In addition, Dr. Barrett is expected to testify generally about the pulmonary affects of asbestos exposure including matters such as dose response, pathogenicity, carcinogenicity and the potential for asbestos-related disease as a result of exposure to the different types of fibers. Dr. Barrett may testify regarding plaintiffs general medical condition, cigarette smoking history and lung disease, and generally about the pulmonary system and its functions as well as the diagnosis and prognosis?of asbestos-related markers and diseases, and the risks associated with developing cancers. Dr. Barrett is also expected to testify about any matter raised by experts called by plaintiff or any co-defendant, including but not limited to plaintiffs medical condition, the state of medical knowledge concerning asbestos, asbestos-related disease and other occupational diseases. In that sense, his testimony may be dependent upon the prior testimony of other experts and cannot be specifically predicted. Dr. Barrett may testify live at trial or by deposition transcript. Dr. Jess R. Lambujon Dr. Alex Milian Dr. Bryan E. Simons Matagorda General Hospital 1115 Avenue G Bay City, Texas 77414 (409) 245-6383 Treating Physicians 63971 1 5 (k) Celanese is in possession of various medical records of plaintiff Rodriguez by virtue of authorizations furnished by him. Please see the list of those records below. Because the records are voluminous, they are not being produced herewith. The records are available, however, for inspection and copying during regular business hours at the offices of Kasowitz, Benson, Torres & Friedman LLP, 700 Louisiana, Suite 2200, Houston, Texas 77002. 1) Medical records from Matagorda General Hospital Respectfully submitted, KASOWITZ, BENSON, TORRES & FRIEDMAN-LLP jA State Bar No. 12888280 Angela R. Hoyt / State Bar No. 00796783 Erica Meadough State Bar No. 24002589 700 Louisiana Street, Suite 2200 Houston, Texas 77002-2730 (713) 220-8800 (713) 222-0843 (Facsimile) HAWKINS & PARNELL, LLP Michael E. Hutchins 4000 SunTrust Plaza 303 Peachtree Street, N.E. Atlanta, Georgia 30308 (404) 614-7400 (404)614-7500 (Facsimile) ATTORNEYS FOR DEFENDANTS CNA HOLDINGS, INC. AND CELANESE LTD. 63971.1 6 OF COUNSEL: Marc E. Kasowitz Hector Torres KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 1301 Avenue of the Americas New York, New York 10019 (212) 506-1700 (212) 506-1800 (Facsimile) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served via facsimile and/or hand delivery and/or U.S. mail, postage prepaid, to all counsel of record on this 7th day of July, 2000. 63971 1 7 EXHIBIT A Vincente Rodriguez, v. Owens-Corning Fiberglas Corp., et al., In the 149th Judicial District of Brazoria County, Texas; Cause No. 4333*RM98 PERSONS WITH KNOWLEDGE PLAINTIFF AND PLAINTIFF'S RELATIVES: Vincente Moreno Rodriguez 412 East Hugo Yoakum, Texas 77995 (512) 741-2186 Plaintiff Carmel Estrada Address and telephone number unknown Plaintiffs ex-wife (1994) Joe Louis Rodriguez 2009 Golden Avenue Bay City, Texas Telephone number unknown Plaintiffs Son Nancy Nelson Lake Jackson, Texas Full address and telephone unknown Plaintiffs Daughter number Jesse Lee Rodriguez Houston, Texas Full address and telephone unknown Plaintiffs Son number Houston, Texas Full address and telephone unknown Plaintiffs Son number Norma Rodriguez Sugar Valley, Texas Full address and telephone unknown Plaintiffs Daughter number Nora Rodriguez Houston, Texas Full address and telephone unknown Plaintiffs Daughter r number Eric Rodriguez West Columbia, Texas Full address and telephone unknown Plaintiffs Son number PLAINTIFF'S MEDICAL PROVIDERS: Dr. Jackson and/or Custodian of Records and/or Designated Representatives Full address and telephone number unknown Bay City, Texas Van Vincent Rodriguez Unknown physician and/or Custodian of Records EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 1 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., et al. 62790 2 and/or Designated Representatives Bay City, Texas Full address and telephone number unknown Unknown physician and/or Custodian of Records and/or Designated Representatives Full address and telephone number unknown Plainview, Texas Physicians at Phillips Petroleum Corporation and/or Custodian of Records and/or Designated Representatives Full address and telephone number unknown Old Ocean, Texas Unknown Physician Full address and telephone unknown Hadisville, Texas number Dr. Jones and/or Custodian of Records and/or Designated Representatives P.O. Box 65 Full address and telephone number unknown Sweeny, Texas 77480 Dr. Black and/or Custodian of Records and/or Designated Representatives Full address and telephone number unknown Lake Jackson, Texas Dr. Jess R. Lambujon Dr. Alex Milian Dr. Bryan E. Simons and/or Custodian of Records and/or Designated Representatives Matagorda General Hospital 1115 Avenue G Bay City, Texas 77414 (409) 245-6383 Dr. Peter A. Petroff and/or Custodian of Records and/or Designated Representatives 4647 Medical Drive San Antonio, Texas 78284 (210)614-6378 Matagorda General Hospital and/or Custodian of Records and/or Designated Representatives 1115 Avenue G. Bay City, Texas 77414-3544 (409) 245-0Q87 Columbia Detar Hospital and/or Custodian of Records and/or Designated Representatives 506 East San Antonio Street Victoria, Texas 77901-6060 (361)788-6504 PLAINTIFF'S FORMER EMPLOYERS: Jean H. Sefton Jean Sefton & Co. and/or Custodian of Records and/or Designated Representatives 413 West Jackson Harlingen, Texas 78550 Telephone number unknown Porter S. DeWitt DeWitty Poultry Farm and/or Custodian of Records and/or Designated Representatives EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 2 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., et at. 62790.2 Route 1 Harlingen, Texas Telephone number unknown Valley Concrete Pressure Pipe Company and/or Custodian of Records and/or Designated Representatives Harlingen, Texas 78550 Telephone number unknown FMC Corp. and/or Custodian of Records and/or Designated Representatives 200 E. Randolph Dr. Chicago, II 60601-6436 Telephone number unknown Reynolds Metals Co. and/or Custodian of Records and/or Designated Representatives P.O. Box 85587 Richmond, VA 23285-5587 (804) 281-2000 E J and H R Baass and/or Custodian of Records and/or Designated Representatives Rt. 3 Box 19 Victoria, Texas 77901 (361) 572-0011 Sheridan C. Lewis, Jr. The Serry Lewis Co. and/or Custodian of Records and/or Designated Representatives 4518 Cornelia Cir N. Corpus Christi, Texas Corpus Christi Septicco Inc. and/or Custodian of Records and/or Designated Representatives 4701 Highway 9 Corpus Christi, Texas William W. Dominy & William P. Alexander Dominy Lumber Company and/or Custodian of Records and/or Designated Representatives Route 2 Box 915 D. Corpus Christi, Texas 78408 (361)289-1414 City of Bay City City Secretary and/or Custodian of Records and/or Designated Representatives 1901 5th Street Bay City, Texas 77414 (409) 245-5311 W. H. Knowles Knowles Flowers and/or Custodian of Records and/or Designated Representatives Box 388 Bay City, Texas 77414 Telephone number unknown J.W. Horton Horton Tile Co. and/or Custodian of Records and/or Designated Representatives Route 2 Bay City, Texas 77414 Telephone number unknown Arthur L. Holloway Arthur Holloway Exterminating Ser. and/or Custodian of Records and/or Designated Representatives Box 481 Bay City, Texas 77414 Telephone number unknown EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 3 Vincente Rodriguez v. Owens-Coming Fiberglas Coq>., et at. 62790.2 City Ice Company of Bay City Inc. and/or Custodian of Records and/or Designated Representatives Box 673 Austin, Texas 78767 Telephone number unknown Henry Duffy and/or Custodian of Records and/or Designated Representatives 2609 4 St. Bay City, Texas 77414 Telephone number unknown A.W. & L.P. Hearn Hearn Bros. Motor Co. and/or Custodian of Records and/or Designated Representatives 2910 7th St. Bay City, Texas 77414 Telephone number unknown J.E. Baker and/or Custodian of Records and/or Designated Representatives Box 767 Odessa, Texas 79760 Telephone number unknown Retail Supermarkets Inc. and/or Custodian of Records and/or Designated Representatives 1301 SE 59th St. Oklahoma City, OK 73129-7307 Telephone number unknown Raymond R. Stridde Continental Oil Company and/or Custodian of Records and/or Designated Representatives Box 426 Bay City, Texas 77414 Telephone number unknown Bossleys Dryer Inc. and/or Custodian of Records and/or Designated Representatives Box 453 Bay City, Texas 77414 (409) 245-2043 Abernathy Company and/or Custodian of Records and/or Designated Representatives 2615 Kipling Street Houston, Texas 77006 Telephone number unknown Spergeon W. Shearer Shearer Electric Company and/or Custodian of Records and/or Designated Representatives 3200 14th Bay City, Texas 77414 Telephone number unknown Robert V. Bell and/or Custodian of Records and/or Designated Representatives P.O. Box 824 Bay City, Texas 77414 Telephone number unknown Tri State Construction & Equipment Co. Inc. and/or Custodian of Records and/or Designated Representatives P.O. Box 1431 807 North Cedar St. Borger, Texas 79007 (806) 273-2104 EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 4 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., et al. 62790.2 Paul Affolter Affolter Contracting Co. and/or Custodian of Records and/or Designated Representatives Box 188 Rio Hondo, Texas 78583 Telephone number unknown William Smith Sr. and/or Custodian of Records and/or Designated Representatives 1301 Adell Bay City, Texas 77414 Telephone number unknown Brangan & Bossley Delta Electric Co. and/or Custodian of Records and/or Designated Representatives Box 346 Bay City, Texas 77414 Telephone number unknown Felder Electrical Contractors Inc. and/or Custodian of Records and/or Designated Representatives 106 West 3 St. Sweeny, Texas 77480 Telephone number unknown and/or Designated Representatives Rt. 6 Box 234 Lubbock, Texas 79400 Telephone number unknown Fish Engineering & Construction Inc. and/or Custodian of Records and/or Designated Representatives P.O. Box 22535 Houston, Texas 77227-2535 Telephone number unknown Vickery Nelson & Thompson V & N Construction Company 202 37 and/or Custodian of Records and/or Designated Representatives Box 834 Lubbock, Texas 79408 Telephone number unknown Curry & Middleton Vies Office Supply and/or Custodian of Records and/or Designated Representatives 114 N. Velasco Angleton, Texas 77515 Telephone number unknown Lathrop Industries of Texas Inc. and/or Custodian of Records and/or Designated Representatives 8420 Manchester Houston, Texas 77012 Telephone number unknown C.E. Haymes Haymes Electric and/or Custodian of Records Olsen Engineering Corporation and/or Custodian of Records and/or Designated Representatives 7830 Westpark Houston, Texas 77036 Telephone number unknown Brown & Root Inc. and/or Custodian of Records and/or Designated Representatives P.O. Box 3 EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 5 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., et al. 62790. Houston, Texas 77001-0003 (409) 962-6530 Daniel Wolstein Ampere Electric Company and/or Custodian of Records and/or Designated Representatives 2320 Ave. C Bay City, Texas 77414 Telephone number unknown Howard P. Foley Co. in Bkrpcy William C. White TTEE and/or Custodian of Records and/or Designated Representatives 14000 Thunderbolt PI. A Chantilly, VA 22021-3227 Telephone number unknown Electric Constructors Inc. and/or Custodian of Records and/or Designated Representatives Post Office Box 241 Houston, Texas 77001 Telephone number unknown Local Union 716 IBEW Vacation Fund and/or Custodian of Records and/or Designated Representatives 6001 Gulf Freeway Houston, Texas 77023 (713) 861-5881 Katy Constructors Inc. and/or Custodian of Records and/or Designated Representatives 3605 Katy Freeway Suite 200 Houston, Texas 77007-3694 Telephone number unknown Gerald Barr Economy Electric Company and/or Custodian of Records and/or Designated Representatives P.O. Box 1343 Bay City, Texas 77414 Telephone number unknown F.J. Brangan and/or Custodian of Records and/or Designated Representatives P.O. Box 346 Bay City, Texas 77414 Telephone number unknown Vincente Rodriguez All Electric Service and/or Custodian of Records and/or Designated Representatives 2007 Ave. I P.O. Box 55 Bay City, Texas 77414 Telephone number unknown KCI Constructors Inc. and/or Custodian of Records and/or Designated Representatives 7231 Old Galveston Rd. Houston, Texas 77034 Telephone number unknown Austin Industrial Inc. and/or Custodian of Records and/or Designated Representatives 702 1st Ave. P.O. Box 1590 Dallas, Texas 75221-1590 Telephone number unknown Gulf States Inc. and/or Custodian of Records and/or Designated Representatives P.O. Box 856 EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 6 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., at al. 62790.2 Freeport, Texas 77542-0856 (409) 233-5555 Delta Engineering Corp. and/or Custodian of Records and/or Designated Representatives 16415 1/2 Jacinto Port Blvd. P.O. Box 520 Channelview, Texas 77530-0520 (281)452-7383 Plant & Field Service Corporation and/or Custodian of Records and/or Designated Representatives 10114 Shoemaker Ave. Santa Fe Springs, CA 90670-3404 Telephone number unknown Process Services Inc. and/or Custodian of Records and/or Designated Representatives 12301 Coursey Blvd. P.O. Box 266245 Houston, Texas 77207-6245 Telephone number unknown Electro Technology Inc. and/or Custodian of Records and/or Designated Representatives P.O. Box 1596 Lake Jackson, Texas 77566-1596 Telephone number unknown United Electrical & Instrumentation Inc. and/or Custodian of Records and/or Designated Representatives P.O. Drawer 448 Clute, Texas 77531-0448 (409) 265-1256 Slaughter Electric Inc. and/or Custodian of Records and/or Designated Representatives 715 N. Gulf Blvd. P.O. Box 2380 Freeport, Texas 77541-2380 Telephone number unknown Braun Constructors Inc. and/or Custodian of Records and/or Designated Representatives P.O. Box 4000 Alhambra, CA 91802-4000 Telephone number unknown GSI of California and/or Custodian of Records and/or Designated Representatives P.O. Box 856 Freeport, Texas 77542-0856 (409) 233-5555 1 Belmont Constructors Inc. and/or Custodian of Records and/or Designated Representatives P.O. Box 310 Middlebury, CT 16762-0310 Telephone number unknown PLAINTIFF'S CO-WORKERS: J.O. Jackson Address and telephone number unknown Paul O'Hare Address and telephone number unknown Gene Phillips Address and telephone number unknown Terry Hills Address and telephone number unknown John Young EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 7 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., et al. 62790 2 Address and telephone number unknown Emmanuel Adolph Ermis 421 Azalea Drive Lake Jackson, Texas 77566 (409) 297-4609 Curtis Ray Goode, Sr. 2801 Algie Street Victoria, Texas 77901 (361) 575-5776 Charles Remlinger, Jr. 2303 Perryman Palacious, Texas 77465 (512) 972-3320 Arnold Carlos Overstreet Route 1, Box 281 Grove Hill, Alabama 36451 (334) 246-7338 James Conrad McDonald 313 Bayou Woods Trail Angleton, Texas 77515 (409) 849-0916 Jose R. Beltran P.O. Box 1104 Odem, Texas 78370 (512) 368-7284 Solomon Paul Howie Route 2, Box 2646 Quitman, Texas 75783 (903) 878-2590 PLAINTIFF'S DESIGNATED EXPERTS: Dr. Richard Cohen and/or Custodian of Records and/or Designated Representatives 19242 Panorama Dr. Saratoga, CA (415) 424-5156 Dr. Barry Castleman and/or Custodian of Records and/or Designated Representatives 1722 Linden Avenue Baltimore, MD 21217 (410) 462-5135 Dr. Joseph K. Wagoner Telephone number and address unknown Dr. Gerritt Schepers and/or Custodian of Records and/or Designated Representatives 9513 Locust Hill Drive Great Falls, Virginia 22066 (703) 757-9714 Dr. David Ozonoff and/or Custodian of Records and/or Designated Representatives Boston University School of Public Health Bldg. A-501 80 E. Concorde St. Boston, MA 02118 (617) 638-4620 Dr. Thomas Mancuso and/or Custodian of Records and/or Designated Representatives 5127 Elsworth Pittsburgh, PA (412) 683-6321 EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 8 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., et al. 62790.2 Dr. David Egilman and/or Custodian of Records and/or Designated Representatives South Shore Health Center 759 Granite Street Braintree, MA 02184-5328 (617) 848-1950 Dr. David Lilienfeld and/or Custodian of Records and/or Designated Representatives Box 1057 Mt. Sinai School of Medicine 1 Gustave Levy Place New York, NY 10029-6574 (212)241-4785 Dr. Robert G. Fraser and/or Custodian of Records and/or Designated Representatives 2766 Summit Circle Birmingham, AL 35216 (205) 979-1123 OR Padanarum Road P.O. Box 558 Bolton Landing, NY 12814 (518) 644-2220 Dr. Arthur N. Rohl and/or Custodian of Records and/or Designated Representatives 10 Stouts Valley Road Easton, PA 18042 (610) 258-5965 James E. Girard, Ph.D. and/or Custodian of Records and/or Designated Representatives 6328 Karmich St. Fairfax Station, VA 22039 (703) 425-4770 John D. McCann and/or Custodian of Records and/or Designated Representatives 195 Bouffard LaSalle, Ontario British Columbia N9J1E9 (519) 734-7889 Roger Shack and/or Custodian of Records and/or Designated Representatives P.O. Box 356 Montevallo, AL 35115 Telephone number and address unknown Nathan Fochtmann and/or Custodian of Records and/or Designated Representatives Route 6, Box 49 Montevallo, AL 35115 Telephone number and address unknown Dr. John Dement and/or Custodian of Records and/or Designated Representatives 109 Kirlbreck Drive Cary, North Carolina 27511 (919) 387-2252 Dr. Richard A. Lemen and/or Custodian of Records and/or Designated Representatives 3495 Highgate Hills Drive Duluth, GA 30155 (770) 497-0770 Mr. Alan M. Segrave Materials Analytical Services, Inc. and/or Custodian of Records and/or Designated Representatives 3597 Parkway Lane, Ste. 250 Norcross, GA 30092 (404) 448-3200 EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 9 Vincente Rodriguez v. Owens-Coming Fiberglas Co/p., et al. 62790 2 Dr. Bill Johnson and/or Custodian of Records and/or Designated Representatives 2948 Foxhall Circle Augusta, GA 30907 (706) 863-4270 E. Lynn Schall and/or Custodian of Records and/or Designated Representatives 510 Edgewood Drive Collingswood, NJ 08108 (609) 858-0003 or (609) 967-313 Dr. Gerald E. Markowitz and/or Custodian of Records and/or Designated Representatives 600 West 111th Street New York, NY 10025 (212) 237-8458 Mr. George M. Kraus and/or Custodian of Records and/or Designated Representatives 11 Drake Lane Upper Saddle River, NJ 07458 (201) 327-2105 Dr. Christine Oliver and/or Custodian of Records and/or Designated Representatives Pulmonary and Critical Care Unit Massachussetts General Hospital Boston, MA 02114 (617) 726-1721 Dr. Edwin C. Holstein and/or Custodian of Records and/or Designated Representatives Environmental Health Associates, P.A. 20 Park Plaza, Ste. 1028 Boston, MA 02116 (617) 357-4901 Stephen Berger and/or Custodian of Records and/or Designated Representatives 10564 Eastborne Ave. Los Angeles, CA 90024 Telephone number unknown Dr. Gaeton D. Lorino and/or Custodian of Records and/or Designated Representatives 6701 Airport Blvd., Ste. A-101 Mobile, AL 36609 (334) 633-8880 Dr. Steven Levin and/or Custodian of Records and/or Designated Representatives Department of Environmental Medicine Mt. Sinai Medical School One Gustave Levy Place ?" New York, NY (212) 241-7810 Dr. Mark Clark and/or Custodian of Records and/or Designated Representatives Pulmonary & Critical Care Consultants 1305 West 34th Street, Ste. 400 Austin, TX 78705 (512) 459-6599 Dr. James Ballard and/or Custodian of Records and/or Designated Representatives Princeton Diagnostic 817 Princeton Avenue Birmingham, AL (205) 783-3700 EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 10 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., et al. 62790.2 Dr. Steven Dikman and/or Custodian of Records and/or Designated Representatives One Gustave Place Annenberg Bldg. 15/58 Department of Pathology New York, NY 10029 (212) 241-7343 (212) 241-8014 Dr. Eugene Mark and/or Custodian of Records and/or Designated Representatives Massachusetts General Hospital Department of Pathology 32 Fruit Street, Warren II Boston, MA (617) 726-8891 Dr. Martin Lewis and/or Custodian of Records and/or Designated Representatives Palms of Pasadena Hospital 1501 Pasadena Avenue South St. Petersburg, FL (813) 341-7505 Dr. David H. Groth and/or Custodian of Records and/or Designated Representatives 8953-C Harper Points Drive Cincinnati, OH 45249 (513) 489-6351 Dr. Jerrold Abraham and/or Custodian of Records and/or Designated Representatives Department of Pathology State University of New York 750 East Adams Street Syracuse, NY 13210 (315) 464-4750 Dr. Sam Hammar and/or Custodian of Records and/or Designated Representatives Diagnostic Specialties Laboratory 700 Lebo Blvd. P.O. Box 2171 Bremerton, WA 98310 (206) 479-7707 Dr. Victor Roggli and/or Custodian of Records and/or Designated Representatives Durkham VA Medical Center Department of Pathology (113) 508 Fulton Street, F3196 Durham, NC 27705 (919) 286-0411 Mr. John D, McAllister, deceased (By deposition) Dr. Kenneth Wallace Smith, deceased (by Deposition) Dr. Richard Gaze, deceased (by Deposition) Dr. Robert W. Johnson and/or Custodian of Records and/or Designated Representatives 4970 El Camino Real, Ste. 250 Los Altos, CA 94022 (415) 494-2413 Mr. Richard L. Hatfield Materials Analytical Services and/or Custodian of Records and/or Designated Representatives 3945 Lakefield Court Suwanee, GA 30024 (770) 448-3200 EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 11 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., et al. 627902 Maceo Cook and/or Custodian of Records and/or Designated Representatives 1070 Legion Club Road Salisbury, NC 28144 (704) 279-3089 Reverend Louis Turner and/or Custodian of Records and/or Designated Representatives 406 Pine Tree Drive Salisbury, NC 28144 (704) 636-9558 Charles E. Evans, Jr. and/or Custodian of Records and/or Designated Representatives P.O. Box 568 East Spencer, NC 28039-0568 Telephone number unknown Edward Allebach and/or Custodian of Records and/or Designated Representatives 109 Emerald Avenue Westmont, NJ (609) 854-9120 Dr. Eliott Kagan and/or Custodian of Records and/or Designated Representatives Department of Pathology Uniformed Services University of the Health Sciences F. Edward Hebert School of Medicine 4301 Jones Bridge Road Bethesda, MD 20814-4799 (301)295-3492 Scott R. Bickford Martzell & Bickford and/or Custodian of Records and/or Designated Representatives 338 Lafayette Street New Orleans, LA 70130 (504) 581-9065 Willie Fields and/or Custodian of Records and/or Designated Representatives 4239 South Claiborne Street New Orleans, LA 70118 (504) 891-5544 Arnold R. Brody, Ph.D. and/or Custodian of Records and/or Designated Representatives Tulane University Medical Center School of Medicine - Department of Pathology & Laboratory Medicine SL79 1430 Tulane Avenue New Orleans, LA 70112-2699 (504) 588-5224 Thomas Adkins and/or Custodian of Records and/or Designated Representatives 38252 River Drive Lebanon, OR 97355 (503) 258-2147 William Longo, Ph.D. Materials Analytical Services and/or Custodian of Records and/or Designated Representatives 3945 Lakefield Court Suwanee, Georgia 30024 (770) 448-3200 James Hubbard Senior Materials Scientist Materials Analytical Services EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 12 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., et al. 62790.2 and/or Custodian of Records and/or Designated Representatives 3945 Lakefield Court Suwanee, Georgia 30024 (770) 448-3200 Dr. Dominic Gaziano and/or Custodian of Records and/or Designated Representatives Chest Medical Services, Inc. 3100 MacCorkle Avenue, Southeast Suite 404 Charleston, WV 25304 (304) 346-1811 Dr. Brian G. Forrester Director, Occupational Medicine Regional FirstCare and/or Custodian of Records and/or Designated Representatives 485 Highway 29N Athens, Georgia 30601 (706) 353-6000 Dr. Frank Mazza Pulmonary & Critical Care Consultants and/or Custodian of Records and/or Designated Representatives 1305 West 34th Street, Suite 400 Austin, Texas 78705 (512) 459-6599 Dr. Jay Segarra and/or Custodian of Records and/or Designated Representatives 414 Ward Avenue Ocean Springs, Mississippi 39564 (228) 875-2954 Alan Eggleston, Ph.D. Eggleston, Holmes and Associates, Environmental Consultants and/or Custodian of Records and/or Designated Representatives 13625 Pond Springs Blvd., Ste. 206 Austin, Texas 78729 (512) 250-0727 Frank Parker Environmental Technology Incorporated and/or Custodian of Records and/or Designated Representatives 200 Brantley Lane P.O. Box 210 Magnolia, Texas 77353-0210 (281) 356-6038 Vernon Rose and/or Custodian of Records and/or Designated Representatives 8046 Oakwod Hollow Houston, Texas 77040 (713) 466-6332 Professor Robert Ragazzo University of Houston Law Center and/or Custodian of Records and/or Designated Representatives Houston, Texas 77004 (713) 743-1000 Chris Kelly Glass & Associates and/or Custodian of Records and/or Designated Representatives 5956 Sherry Lane, Suite 2001 Dallas, Texas 75225 (214) 696-4659 Sharon Katz, Ed. D. 1674 Hill Road, Suite #10 Boise, Idaho 83702 (208) 385-9677 Dr. Peter A. Petroff and/or Custodian of Records and/or Designated Representatives EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 13 Vincente Rodriguez v. Owens-Coming Fiberglas Corp., et al. 62790.2 4647 Medical Drive San Antonio, Texas 78284 (210) 614-6378 DEFENDANTS CNA HOLDINGS. INC. AND CELANESE LTD.'S DESIGNATED EXPERTS: J. LeRoy Balzer, Ph.D. 408 Horse Trail Court Alamo, California 94507 (925) 274-0826 Lawrence R. Birkner, CIH, CSP McIntyre, Birner & Associates, Inc. 2026 El Monte Drive Thousand Oaks, California 91362-1822 (805) 494-8173 James D. Crapo, M.D. National Jewish Medical & Research Ctr. 1400 Jackson Street Denver, Colorado 80206 (303) 398-1436 Dorsett D. Smith, M.D. 4310 Colby Avenue, Suite 201 Everett, Washington 98203 (425) 259-5171 Mark R. Stenzel, CIH P.O. Box 850235 Richardson, Texas 75085-0235 (972) 404-3207 Ernest M. Dixon, M.D., Sc.D. 6305 Evermay Drive McLean, Virginia 22101 Charles S. Laubly 2225 North Tucson Boulevard Tucson, Arizona 85716 Herbert J. Kolodner, Ph.D., P.E. 777 Pebble Beach Drive Crescent City, California 95331-3634 John R. Holcomb, M.D. 4410 Medical Drive San Antonio, Texas 78229-0373 (210)692-9400 William L. Dyson, PhD., C.I.H. Workplace Hygiene, LLC 1022 Jefferson Road Greensboro, NC 27140 William G. Hughson, M.D., PhD Center for Occupational & Environmental Medicine - UCSD Medical Center 200 West Arbor Drive San Diego, California 92103-8800 Peter Barrett, M.D. 300 Boylston Street, Suite 714 Boston, Massachusetts 02116-3923 DEFENDANTS CNA HOLDINGS. INC. AND CELANESE LTD.'S FACT WITNESSES: Ernest M. Dixon, M.D., Sc.D. 6305 Evermay Drive McLean, VA 22010. Charles S. Laubly 225 North Tucson Boulevard Tucson, AZ 85716 Herbert J. Kolodner, Ph D., P.E. 777 Pebble Beach Drive Crescent City, CA 95331-3634 EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 14 Vincente Rodriguez v. Owens-Corning Fiberglas Corp., et at. 62790 2 T. Rodgers Shandley 234 Turpin Drive Lewisville, TX 75077 L. William Hartman P.O. Box 383 Orange Grove, TX 78372 C. James Duey 7 Stoney Brook Lane Bay City, TX 77414 Ronnie O'Neal 1905 Baywood Drive Bay City, TX 77414 Carl King Route 2, Box 139 Bay City, TX 77414 Carrol W. Whaley, CIH, CSP 3403 Yerba Buena Road San Jose, CA 95135 Gary George 2929 La Vista Bay City, TX 77414 Jimmy Farmer Route 2, Box 132G Bay City, TX 77414 Each of the above individuals were employed in various capacities by Celanese in the field of industrial medicine, industrial hygiene, environmental safety and health or purchasing. Each will provide testimony regarding workplace conditions at the Celanese plants at issue, evolving principles and methodologies in their fields and their application to Celanese, and the historical development of information and knowledge on the part of Celanese regarding the particular hazards associated with asbestos exposure. Among the above, Dr. Dixon, Mr. Laubly, Dr. Kolodner and Mr. Stenzel will provide testimony regarding Celanese's corporate awareness of and approach to asbestos health issues. Mr. Laubly, Mr. Stenzel, Mr. Whaley, Mr. Kong, Mr. George, and Mr. Farmer will provide testimony regarding air monitoring and other steps taken at the relevant facilities to determine and control exposures to asbestos and other substances. Mr. Shandley will provide testimony regarding the purchase of asbestos-containing materials by Celanese and by the plants, and the discontinuation thereof. EXHIBIT A - PERSONS WITH KNOWLEDGE - Page 15 Vincente Rodriguez v. Owens-Corning Fiberglas Corp., et al. 62790.2 CURRICULUM VITAE WILLIAM L. DYSON, PhD, CIH ADDRESS: EDUCATION. Workplace Hygiene, LLC 1022 Jefferson Road P.O. Box 49176 Greensboro, NC 27410 Telephone: 336-297-1642 Facsimile: 336-297-1643 e-mail: wdyson@bellsouth.net B.S., Chemical Engineering, North Carolina State University, Raleigh, North Carolina, 1966. M.S., Environmental Health Engineering, Northwestern University, Evanston, Illinois, 1971. Thesis title: Reduction of Toluene Diisocyanaie in Air by Water Vapor Pta.D., Environmental Health Engineering, Northwestern University, Evanston, Illinois, 1975. Dissertation title: The Reaction of Sulfur Dioxide with Zinc Oxide Fume in Air Miscellaneous: Graduate work in chemical engineering, North Carolina State University, 1966; Ten week industrial hygiene training course, U.S. Public Health Service, 1967; Business courses, University of Cincinnati, 1967. Numerous short courses and seminars - toxicology, ventilation, asbestos, formaldehyde, indoor air quality, management, and other topics - 1973 to present. PROFESSIONAL EXPERIENCE: 1998 co Present Workplace Hygiene, LLC, Greensboro, North Carolina Consultant in Industrial Hygiene Provide industrial hygiene consultation and services to businesses and employers nationwide. 1991 to 1998 Health & Hygiene, Inc. Greensboro, North Carolina President Managed multidisciplinary team of occupational health professionals. Personally provided indoor air quality, litigation support, and chemical exposure assessment services for customers nationwide. WORKPLACE HYGIENE i Industrial Hygiene 5v>i Curriculum Vitae 1982 to 1991 1976 to 1982 1973 to 1976 1967 to 1969 1967 Summer 1966 William L. Dyton, PhD, C1H Page 2 of 6 Health & Hygiene, Inc. Greensboro, North Carolina Vice President/Industrial Hygiene Developed industrial hygiene department and supervised staff in multiple locations. Oversaw numerous asbestos abatement projects. Personally conducted industrial hygiene studies as a consultant to industry, commercial clients and governmental agencies. Emphasis was on chemical safety and environmental characterization. Dealt with problems involving asbestos, formaldehyde, ethylene oxide, anesthetic gases, noise, indoor air quality and other stressors. Burlington Industries, Greensboro, North Carolina Corporate Industrial Hygienist Supervised corporate-wide programs on chemical health and safety. Taught numerous short courses on chemical safety to plant personnel, nurses, and others. Responsible for company compliance with TSCA. Handled chemical aspects of product safety. Interacted extensively with corporate management, trade associations, regulatory agencies, chemical suppliers, and customers. Initiated asbestos management program for corporation. IBM, Lexington, Kentucky Manager, Industrial Hygiene Responsible for industrial hygiene activities at development and manufacturing facility with 6,500 employees. Planned and implemented programs in hearing conservation, radiation protection, hazardous materials control and general industrial hygiene. Handled health hazard aspects of product safety, including vendor toxicology studies and customer inquiries. U.S. Public Health Service, Cincinnati, Ohio Industrial Hygiene Engineer Provided technical assistance to government agencies and industry in industrial hygiene including hazard and stress evaluation, sampling, and recommendations for control. Planned and helped supervise an eight-hundred plant survey of potential occupational health problems in Chicago metropolitan area. Monsanto Company, Luling, Louisiana Technical Assistance Engineer Provided chemical engineering services in an agricultural chemicals plant. E.I. DuPont de Nemours, Belle, West Virginia Engineer Intern Worked with special design group for new urea plant. [IIndustrial Hygiene Strviq \ -- Curriculum Vitae Summers 1964 & 1965 Wffiam L. Dytou, PhD, C!H Page 3 of 6 Union Carbide, Institute, West Virginia Operator and Engineer Intern Operated polyethylene glycol production unit and conducted special project for acrylonitrile unit. ACADEMIC EXPERIENCE. 1979 1971 to 1976 North Carolina A & T State University, Greensboro, North Carolina Adjunct Assistant Professor Taught an introductory occupational safety and health to undergraduate students. course in Northwestern University, Evanston, Illinois Teaching assistant Staff member of experimental freshman engineering program. Taught primarily in areas of mathematics (calculus and statistics) and computer programming. 1970 1966 Northwestern University, Evanston, Illinois Laboratory teaching assistant Assisted students in a sanitary biology laboratory. North Carolina State University, Raleigh, North Carolina Laboratory leaching assistant Assisted students in a chemical engineering unit operations laboratory. CERTIFICATION: Certified by the American Board of Industrial Hygiene in the Comprehensive Practice of Industrial Hygiene (1978). Certification No. 1457 AFFILIATIONS: American Industrial Hygiene Association -Fellow Member American Academy of Industrial Hygiene -Member American Board of Industrial Hygiene -Diplomate wSSjIndutfritl Hygiene Services) \ Cumettlum ^nr William L. Dyson, PhD, CIH Page 4 of 6 Carolmas Section AIHA -Member American Society of Safety Engineers -Professional Member Sigma Xi PROFESSIONAL ACTIVITIES: American Industrial Hygiene Association Air Pollution Technical Committee 1975-1979 Conference Program Committee 1979, 1982-1986 Treasurer 1996 -1998 American Academy of Industrial Hygiene Secretary-Treasurer 1980-1983 Vice-President 1984 President-Elect 1985 President 1986 American Board of Industrial Hygiene Director 1989-1995 Treasurer 1991-1995 American Textile Manufacturers Institute Chemical Substances Subcommittee 1976-1982 Dye Task Group 1981 N.C. Triad Association of Occupational Health Nurses Advisory Board 1978-1983 Numerous talks and lectures; American Industrial Hygiene Conference North Carolina Statewide Safety Conference Professional Conference on Industrial Hygiene American Furniture Manufacturers Association American Association of Textile Colorists and Chemists Carolinas Section AIHA Industrial Hygiene Service^ Curriculum Vitae William L. Dytoa, PhD. C1H Page S of 6 PAPERS AND PUBLICATIONS. Heath, George A. and William Dyson: Handling Powder Dyes: Workplace Exposure, Textile Chemist and Colorist, Vol. 22, No. 4, pgs. 25-31, April 1990. Dyson, William L.: Guidelines for Safe Handling of Dyes, ETAD, pgs. 1-15, November 1989. Powell, Charles H, Duncan A. Holady, Mildred A. Kendrick, and William L. Dyson, The Preliminary Survey: A Technique for the Assessment of the Nation's Occupational Health Requirements, Transactions of the 30th Annual Meeting of the ACGIH, pgs. 60-72, 1968. McCarl, G.W., R. E. Reifschneider and W. L. Dyson: Study of an Episode of Illness at Lasko Metal Products Company, Franklin, Tennessee, Bureau of Occupational Safety and Health, Division of Occupational Injury and Disease Control, May 1969. Dyson. William, and G. Warren McCarl: Vehicle Exhaust Exposure at El Paso and Laredo, Texas, Border Crossing Stations, U.S. Department of Health, Education, and Welfare, Public Health Service, Consumer Protection and Environmental Health Service, Environmental Control Administration, TR-58, November 1968. Dyson, William and Edward R. Hermann: Reduction of Atmospheric Toluene Diisocyanate by Water Vapor, American Industrial Hygiene Association Journal, Vol. 32. Number 11, November 1971. Imbus, Harold R., Ralph Buncher, William L. Dyson, John A. Thomas, and G.Z. Nothstein: Health Professionals as Experts, Toxic Torts, Litigation of Hazardous Substance Cases, Trial Practice Series, pgs. 542-584. Dyson, William L. and James E. Quon. Reactivity of Zinc Oxide Fume with Sulfur Dioxide in Air, Environmental Science & Toxicology, Vol. 10, No. 5, pgs 476-481, May 1976. Imbus, Harold R., and William L. Dyson: A Review of Nasal Cancer in Furniture Manufacturing and Woodworking in North Carolina, the United States, and Other Countries, Journal of Occupational Mediciner Vol 29, No. 9, pgs. 734-740, September 1987. WORKPLACE HYGIENE Hygiene Services^ <* \. Curriculum Vitae WUliatn L. Dyson, PhD, CtU Pag* 6 aft Rose, Vernon E, and William L. Dyson: Occupational Health Survey of the Chicago Metropolitan Area, U.S. Department of Health, Education and Welfare, Bureau of Occupational Safety and Health, October 1969. WORKPLACE HYGIENE Industrial Hygiene itrvKnfJ^g CURRICULUM VITAE HT1GHSOW. WILLIAM G. Dace of Birth.: Place of Birth: Marital Status: January 7, 1951 Calgary, Alberta, Canada Married - Joanne Lloyd Hughson EDUCATION 1968: Graduated from secondary education with'a first-class diploma. 1968-70: Enrol 1 ed in the Faculty of Arts and Science of the University of Calgary in pre-medical studies. Academic record of 4.0 gradepoint average. 1970: Entered the Faculty of Medicine of the University of Calgary. Graduated 1973. POST GRADUATE TRATNTNO Straight Intern (Medicine) at the Royal Victoria Hospital, Montreal. Resident in Obstetrics and Gynecology at the Foothills Hospital, Calgary. Department of Social aud Community Medicine, Oxford University. Completed a Doctor of Philosophy degree. Title of thesis "A study of Some Aspects of the Epidemiology and Treatment of Peripheral Vascular Disease". Resident III in Medicine at the Royal victoria Hospital, Montreal. July 1973-June 1974 July 1974-Oct. 1974 Oct. 1974-Sept. 1977 Oct. 1977-June 1978 Resident IV in Medicine at the Royal Victoria Hospital, Montreal. First-year Fellow in the Division of Pulmonary Medicine and Critical Care Medicine. University of California, san Diego. Second-year Fellow in the Division of Pulmonary Medicine and Critical Care Medicine. University of. California, San Diego. Third-year Fellow in the Division of Pulmonary Medicine and Critical Care Medicine. University of California, San Diego. BOARD CERTIFICATIONS AND OTTAITFTCATTONS Board Certified, American College of Physicians. Specialty in Internal Medicine. Fellow, Royal College of Physicians and Surgeons of Canada. Specialty in Internal Medicine. Board Certified, American College of Physicians: Specialty in Pulmonary Medicine. Certified NIOSH "A" Reader. Board Certified, American Board of Preventive Medicine. Specialty in Ornipat.innfll Medicine. William Q. Hugfcu*on, M.D. Page 2 July 1978-June 1979 July 1979-June 1980 July 1930-June 1981 July 1981-June 1982 1979 1979 1 989. 1982 1987 William <3. Hughaon, M.D. Page 3 APPOTNTMENTS Assistant Clinical Professor of Medicine. University of California, San Diego. Director, Occupational Health Center Center, UCSD Medical Center. Independent Medical Examiner for the Division of Industrial Accidents for the State of California. Medical Director, UCSD Employee Employee Health Program. Lecturer, Graduate School of Public lealth, San Diego State University. Teaching PH 635, Occupational Medicine. Associate Clinical Professor of Medicine. University of California, San Diego. Associate Adjunct Professor, Division of Occupational and Environmental Health, Graduate School of Public Health, San Diego State University. Qualified Medical Evaluator, State of California. Clinical Professor of Medicine. University of California, San Diego. July 1982-June 1990 January 1984-present January 1984-present September 1985-present 1987 & 1988 July 1990-June 1996 August 1991-present 1995-1998 July 1996-present ACADEMIC AWARDS University Honor Prize viscount; Bennecc Scholarship Imperial Oil Scholarship (full tuition) 1969 1969 1969-1972 Teag1e Foundation Scholarship Rhodes Scholarship for Alberta William <3. Hughson, M,D. Page 4 1969-1973 1974 PROFESSIONAL ORGANIZATION'S American Association of Rhodes Scholars American College of Occupational and Environmental Medicine American College of Chest Physicians American College of Physicians American Thoracic Society California Thoracic Society Canadian Association of Rhodes Scholars Royal College of Physicians & Surgeons of Canada Western Occupational and Environmental Medical Association COMMITTEES Member, Scientific Advisory Panel on Occupational Medicine. California Medical Association. July 1985-present Member, Environmental and Occupational Health Committee. American Lung Association of California. July 1985-present Member, Executive Committee of the San Diego Pulmonary Society. Society President 1988-1989. 1985-1989 Member, Occupational Health Training Advisory Board. San Diego State University. 1986-present Member, Committee for Clinical Affairs. UCSD Division of Pulmonary and Critical Care Medicine. 1987-present Member, Science Resources Panel. Subcommittee of Quality of Life Board advising the City of San Diego .regarding the Sander Trash-to-Energy February 1987-June 1988 Project. William G. Kughson, K.D. Page 5 Chairman, UCSD Medical Ethics Committee. July 1988-June 1990 Member, UCSD Health and Safety Advisory Council. August 1988-preeent Member, Preventive Pulmonary Education Committee. July 1989-preseiit Member, UCSD Medical Center Safety Management Program Committee. July 1989-present Member, Subcommittee on Non-Biological Contaminants. Subcommittee of the Toxic Waste Advisory Committee of the Port of San Diego, dealing with pollution problems in San Diego Bay. August 1989-August 1990 Jhairman, UCSD Medical Center Bylaws Committee. July i991-June 1994 Member, UCSD Administrative Services QMP Steering Committee. April 1992-1994 Member, Occupational and Clinical Toxicology Committee, American College of Occupational and Environmental Medicine. April 1993-present Member, UCSD Department of Medicine Committee on Appointments and Promotions (DOMCAP). April 1997-June 1998 Member, American Lung Association of California Research Program Research Training Fellowship Review Committee. July 1997-present publications l. Hughson wg, Mann JI, Tibbs DJ, woods hf, Walton I. Intermittent Claudication: Factors Determining Outcome. British Medical Journal 1070;1:1377-1379. William <3. Hughoon, M.D. Page 6 2. Hughson WG, Mann JI, Garrod A. Intermittent Claudication: Prevalence and Risk Factors. British Medical Journal 1978;1:1379-1381. 3. Mann JI, Hughson WG, Holman RR, Honour AJ, Thorogood M, Smith A, Baum JD. Serum Lipids in Treated Diabetic Children and Their Families. Clinical Endocrinology 1978;8:27-33. 4. Hughson WG, Friedman PJ, Feigin DS, Resnik R, Moser KM. Postpartum Pleural Effusion: A Common Radiographic Finding. Annals of Internal Medicine 1982;97:856-858. 5. Guidotti TL, Abraham JL, Hughson WG, Krems AD, Neuman TS, Bryson AL, Heramb BI. Taking the Occupational History. Annals of Internal Medicine 1983;99:641-651. 6. Hughson WG. Pleural Diseases Associated with Asbestos: Medical and Legal Implications. Pulmonary Perspectives 1985;2(4):6-8. 7. Hughson WG. Evaluation of the Solitary Pulmonary Nodule. Computer program presented at the annual California Medical Association Conference, February 1986. 8. Hughson WG. Occupational Lung Disease. Computer program prepared for Medical Information Diagnostic Systems, Inc., September 1986. 9. Hughson WG. Pulmonary Function Tests. In LaDou J (ed) ; Occupational Medicine. Norwalk, Connecticut, Appleton & Lange 1990;221-222. 10. Hughson WG. Occupational Asthma. In LaDou J (ed) : Occupational Medicine. Norwalk, Connecticut, Appleton & Lange 1990;222-227. 11. Hughson WG. Rehabilitation; Re-entry Into the Workplace After Treatment for Cancer. In Moossa AR, Schimpff SC, Robson MC (eds) : Comprehensive Textbook of Oncology. Baltimore, Williams & Wilkins 1991;1820-1823 . 12. Hughson WG. Coal Workers Pneumoconiosis. In Bordow RA, Moser KM (eds): Manual of Problems in Pulmonary Medicine. Third Edition. Boston, Little, Brown & Company 1991;357-360. 13. Hughson WG. Pulmonary Disability Evaluations. Pulmonary Perspectives 1991/0(4 > ;4-G. William Q. Hug-hson., m.d. Page 7 14. Hughson WG. Epidemiologic Considerations in Occupational Asthma, Immunology and Allergy Clinics of North America 1992;12:697-710. 15. Mooney V, Hughson WG. Resurgence of Work-Hardening Programs. Western Journal of. Medicine 1992/156:410. 16. Cujt CB, Hughson WG. "Making the connection". Videotape concerning Occupational Asthma produced for Office of Learning Resources - TV UCSD, Preventive Pulmonary Series, 1993. 17. Hughson WG. Coal Workers Pneumoconiosis. In Bordow RA, Moser KM (ede)i Manual of Problems in Pulmonary Medicine. Fourth Edition. Boston, Little, Brown & Company 1996: 367-370. 18. Hughson WG. Occupational Asthma. In Bordow RA, Moser KM (eds): Manual of Problems in Pulmonary Medicine. Fourth Edition. Boston, Little, Brown & Company 1996: 373-376. 19. Hughson WG. Approaches to Occupational-Environmental Lung Disease. In Bordow RA, Moser KM (eds) : Manual of Problems In Pulmonary Medicine. Fourth Edition. Boston, Little, Brown & Company 1996: 361-364. 20. Hughson WG, Fedoruk MJ. Occupational and Environmental Causes of Lung Cancer and Esophageal Cancer. Xn Aisner >J, Arriagada R, Green MR, Martini N, Perry MC (eds): Cnmprehensive Textbook of Thoracic Oncology. Baltimore, Williams & Wilkins 1996:66-89. 21. Fedoruk MJ, Logan DC, McDiarmid MA, Forrester BG, Hughson WG, Holland C, Newby HE, Saunders JH. American College of Occupational and Environmental Medicine (ACOEM) Reproductive Hazard Management Guidelines. Journal of Occupational and Environmental Medicine 1996/38:83-90. 22. Hughson WG. Guest Editorial: The Undercover Advocate. RT/The Journal for Respiratory Care Practitioners. April/May 1997:18,117. 23. Hughson WG. Occupational and Environmental Medicine in an Academic Medical Center. Western Journal of Medicine 1998 (in press). 24. Hughson WG. Silicosis, Coal Workers' Pneumoconiosis and Byssinosis. In Bowler R, Cone J (eds): Occupational Medicine Secrets. William O. Hughson, M.D. Page 8 Philadelphia, Hanley & Belfus 1998 (in prcs3). ABSTRACTS 1. Hughson WG, Lonky SA. The Effect of Exposure to Ozone on the Protease-Antiprotease System of the Dog. American Review of Respiratory Disease 1982;125:148. hughaon.cv. H; \t*p51 9-8-98 CURRICULUM VITAE PETER J. BARRETT, MD, FACR 300 BoyIstem Street, Suite 714 Boston, MA 02116-3923 (617) 426-2110 ACADEMIC HISTORY St. John's Preparatory, Danvers. Massachusetts 1960 (honors) College of the Holy Cross, Worcester, Massachusetts B.A.. Pre-Med. Chemistry, 1960-1964 Tufts University School of Medicine, Boston. Massachusetts M.D.. 1968 ' internship, St. Elizabeth's Hospital of Boston, Brighton. Massachusetts Internal Medicine, 1968-1969 Residency, Tufts New England Medical Center Hospital, Boston, Massachusetts 1969-1972 BOARD CERTIFICATION Diplomat, National Board of Medical Examiners. 1968 Diplomat. American Board of Radiology. Diagnostic Radiology, 1973 Diplomat, Massachusetts. State Board of licensure. 1969 Diplomat, California State Board of Licensure. 1969 Diplomat. American Board of Nuclear Medicine. 1977 Diplomat. Special Competency in Nuclear Medicine, American Board of Radiology. 1976 Certified *B* Reader. Department of Health and Human Services. National institute for Occupational Safety and Health (NIOSH). August 1. 1984 through July 31.2000 TEACHING, UNIVERSITY APPOINTMENTS. AND HOSPITAL AFFILIATIONS Clinical Professor of Radiology. Tufts Medical School. 1993-Present Associate Clinical Professor of Radiology. Tufts Medical School. 1986-1993 Assistant Clinical Professor of Radiology. Tufts Medical School. 1980-1985 instructor of Radiology, Tufts Medical School. 1975-1980 Staff Radiologist. Quincy Hospital Director of Radiologic Services. Massachusetts Respiratory Hospital. 1987-Present s* - Curriculum Vitae Peter J. Barrett. M.D. Page 2 TEACHING, UNIVERSITY APPOINTMENTS, AND HOSPITAL AFFILIATIONS (Continued) Staff Radiologist. Massachusetts Respiratory Hospital 1973-1987 Visiting lecturer in Radiology. Boston V.A. Hospital Clinical Professor and Visiting Radiologist. New England Medical Center Hospital Visiting lecturer in Radiology, Massachusetts General Hospital. 1973-1979 Lecturer in Pneumoconiosis. Harvard School of Public Heatth. 1989-1993 Instructor of Radiology, Harvard Medical School. 1972-1975 Assistant in Radiology. Massachusetts General Hospital 1972-1974 PROFESSIONAL APPOINTMENTS AND SOCIETIES Member, American College of Radiology Member. American Roentgen Ray Society Member, American Thoracic Society Fellow. American College of Chest Physicians Consultant to U.S. Department of Labor Slack Lung Program. *B* Reader. 1988-Present Fellow. American College of Radiology, 1995-Present Member, Radiological Society of North America Associate Chief of Radiology. Quincy Hospital. 1996-Present Director, Nuclear Medicine Diagnostic and Therapeutic Laboratory. Quincy Hospital. 1995-Present Chief of Radiology. Quincy Hospital 1987-1989 President of Medical Staff. Quincy Hospital. 1986-1988 Member. Admissions Committee. Tufts University School of Medicine. 1982-1988 President. Massachusetts Radiological Society. 1996-1997 President Elect. Massachusetts Radiological Society, 1995-1996 Vice President ana Board Member. Massachusetts Radiological Society, 1994-1995 Treasurer and Board Member. Executive Committee. Massachusetts Radiological Society, 1991-1993 Board Member. Committee on Finance. Massachusetts Medical Society, 1994-1995 Member. New England Society of Ultrasound in Medicine Curriculum Vitae Peter J. Barrett. M.D. Page 3 PROFESSIONAL APPOINTMENTS AND SOCIETIES (Continued) Member. Society of Nuclear Medicine Member, American Medical Association Member. Massachusetts Radiological Society Member. Massachusetts Medical Society, Norfolk-South District Counselor. American College of Radiology, 1995-1998 PUBLICATIONS 1. The Internal Cerebral Vein, Normal and Pathological Variations in Position and Configuration. New. Wolpert and Barrett, Neuroradiology, 7(2), 1974. 2. Unusual Duodenal Ulcers (Monograph: Roentgen Conference Number One). WarnerChilcott, P.J. Barrett, and L.L. Robins. 3. Double Tracking in The Sigmoid Colon. Radiology, 120. Aug. 1976. 307-312. Ferrucci. Ragsdale, Barrett, Vickery, Dreyfus. 4. Asbestos Related Abnormalities Among United States Merchant Seamen. Correspon dence re:. British Journal of Industrial Medicine, 47(12). Dec. 1990. 844. Barrett. Peter J. 5. Work in progress: Evaluation of 500 asbestos workers from the Coalinga. California, asbestos deposit for the presence or absence of pneumoconiosis. Record review, radiographic analysis, mineralogy partially completed. Grant applications In preparation. Co-authors: Edward llgren. Edward Gaensler, Otto Wong. HONORARY SOCIETIES AND APPOINTMENTS Alpha Sigma Nu National Honor Society Harvard Medical Alumni Association, Honorary Member Chairman, Board of Health, Town of Hingham, 1980-1984 MILITARY SERVICE United States Naval Reserve. Ens. USNR. 1915 Program. 1967-1968 (Chelsea Naval Hospital) United States Navy. Lt. USNR. 1968-1969 (Chelsea Naval Hospital) United States Navy. if. Comdr. USNR. 1969-1973