Document 2j7Yzp8mKjm9akRbx5Xe1EB3g

PLAINTIFF'S EXHIBIT NO- S-98-5033CV-C 'OpY FAY MOORE, Individually and as Personal Representative of the Heirs and Estate of Leo Moore, Deceased, Plaintiffs, V. REYNOLDS METaLS COMPANY, et al., Defendants. C Sc Sc IN THE DISTRICT COURT NUECES COUNTV, TEXAS 343rd JUDICIAL DISTRICT DEFENDANT REYNOLDS (VIETALS COMPANY'S RESPONSE TO PLAINTIFF'S RULE 194 REQUEST FOR DISCLOSURE Defendant Reynolds Metals Company ("Reynolds"), by counsel, pursuant to Rule 194 of the Texas Rules of Civil Procedure, responds as follows to Plaintiffs Request for Disclosures: A. The correct names of the panics to the lawsuit. Reynolds states that its correct name is Reynolds Metals Company; it is without knowledge as to the correct names of the other parties to the lawsuit. B. The name, address, and telephone number of any potential parties. At this time, Reynolds is aware not aware of any "potential panics." Reynolds reserves the right to supplement its response to this request. C. The legal theories and, in general, the factual bases of the responding party's claims. Reynolds refers plaintiff to ns Special Exceptions, Original Answer and Affirmative Defenses to Plaintiffs Original Asbestos Petition filed on March 9, 1998. At this time, Reynolds expects that its defense will be based on documentary and testimonial evidence (including lay and expert testimony) that  Decedent Leo Moore ("Moore") was not exposed to harmful levels of asbestos as art employee of Reynolds; ~ Moore's lung cancer was attributable to a cause other than exposure to asbestos, specifically including, but not limited to, his use of tobacco products; Reynolds' did not breach any duty of care owed to Moore; Reynolds was not grossly negligent; and Moore was conm'butorily negligent. D. The amount and any method of calculating economic damages. PiamtifT s cause of action does not give rise to a recovery of economic damages, but only punitive damages for gross negligence. At this lime, plaintiffhas not disclosed the amouni of damages she seeks nor the method of calculating such damages. Although Reynolds generally denies that grounds exist for punitive damages, Reynolds cannot respond specifically ro plaintiff's claimed damages and/or damage calculation. Reynolds therefore reserves the right to supplement its response to tins Request until such time as plaintiff has provided this information., E. The name, address, and telephone number of persons having knowledge of relevant facts, and a brief statement of each identified person's connection with the case. Investigation and discovery is ongoing in this matter, and, at this time, Reynolds does not_ know' each and every' individual who has knowledge of the relevant facts, nor does Reynolds know ax this time whom it may call to testify at the trial ofthis matter. Reynolds therefore reserves the right to supplement its response to this Request in accordance with Rule 193 ofthe Texas Rules of Civil procedure. At this time, Reynolds identifies the following individuals who may have knowledge of relevant facts and who Reynolds may cal! to testify at the trial ofthis matter: 2 1) ~ Plaintiff Mrs. Velena Fay Moore 3114 Main Street Post Office Box 163 Ingleside, Texas 78362 2) Moore's Treating Physicians. Reynolds may call some or all of the following individuals as mal witnesses to offer testimony, including expert testimony, about their care. treatment and diagnosis of Moore; Dr. C. H. Isensee 3302 South Alameda Street Corpus Christi, Texas 78411 Dr. Phyllis J. Noss 4511 Fairway Avenue Dallas, Texas 75219 Dr. Lorraine Stehn 1731 West Wheeler Avenue Aransas Pass, Texas 78356 Dr. E. Brugo 506 East Sau Antonio Street Victoria, Texas 77901 Dr. Kirby C. Barker, Jr. Oncology-Hematology Associates 2601 Hospital Boulevard, Suite 112 Corpus Christi, Texas 78405 (512) 883-8553 Dr. Jerrold L. Abraham State University of New York 750 East Adams Street Syracuse, New York 13210 3) Coworkers Reynolds may call Moore's coworkers as trial wiinesses and reserves the right to supplement its response to this request when it has determined the names and locations of these witnesses. 3 4) Reynolds Personnel. (a) Sherwin Alumina Planr Personnel Reynolds may call some or all of the following individuals who were employed at various times at the Sherwin Alumina Plant to testify as to their personal knowledge concerning plant operations and plant conditions; the use of asbestos-containing products in plant operations; the elimination and abatement of asbestos; Reynolds' safety procedures, both in general and as they relate to asbestos (including the use of respirators); Moore's potential for asbestos exposure; and, other mailers relevant to plaintiffs claims and/or Reynolds' defenses: Dr. John Fraadolig ^ RR 1, Box 358 Lake Geneva, WI 53147 Dr. FrandoJig was the Shetwin Alumina Plant Medical Director from 1989-91. He may be called to testify about his knowledge regarding the Respiratory Swveillance Program at the Sherwin Alumina Plant, Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about his knowledge related to asbestos exposure procedures. Dr. Guy Racette J 8122 Deck Street Corpus Christi, TX 78412 Dr. Racene was the Sherwin Alumina Plant Medical Director from 1991-93. Het; _ may be called io testify about his knowledge regarding the Respiratory Surveillance Program at the Sherwin Alumina Plant, Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about his knowledge related to asbestos exposure procedures. Dr. Wendell Roberts 620 West Johnson Avenue Arkansas Pass, TX Dr. Roberts is the current Sherwin Alumina Plant physician. He may be called to testify about his knowledge regarding the Respiratory Surveillance Program at the Sherwin Alumina Plant, Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos He may also be called to testify- about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses y Deloris Ulke Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Ms. Ulke was the Head Nurse at Sherwin Alumina Plant Medical Department. She is familiar with the Respiratory Surveillance Program Thai was instituted in approximately 1975 at the Sherwin Alumina Plant. She may be called to testify about her knowledge about Reynolds' attitude toward employee health in general, as well as general information regarding the Medical Department at the Sherwin Alumina Plant. She may also be called to testify about her knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses. C. Arlon Boatman ^ Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory,TX 78469 Mr Boatman is the Health &. Safety Manager for the Sherwin Alumina Plant who may be called to tesnfy about his knowledge of Reynolds' safety procedures and the use of asbesxos-conraining products at the Sherwin Alumina Plant, as well as other information. He may also be called to testify about the operation of the Sherwin Alumina Plant Medical Department, including the Respiratory Surveillance Program. He may also be called to testify about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses. * 5 Terry N. Roubidoux Shervvin Alumina Flam P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Roubidoux was the Safety Coordinator for the Sherwin Alumina Plant from 1992-June 1997. He is currently the Area II Business Unit Superintendent at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safery procedures and the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. He may also be called to testify about his knowledge related to asbestos exposure procedures and other marters relevant to plaintiffs claims and/or Reynolds' defenses. A.S. ^Stan" Millsap ^ 5541 Bear Lane, Sie. 236 Corpus Christi, TX 78405 Mr. Millsap was the Safery Coordinator at the Sherwin Alumina Plant. He may be called to testify about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding OSHA and MSHa requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be called to testify about his knowledge regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training. He may further be called to testify' about his knowledge of asbestos abatement at the Sherwin Alumina Plant Darrell L. Lentz ^ 2406 West Frank Street Apartment 114 Lufkin, Texas (409) 632-9345 - Mr. Lentz was the Safety Director at the Sherwin Alumina Plane from 1977November 1982. He may be called to testify about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding OSHA and MSHA requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures He may also be called to testify about his knowledge regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training He may further be called to testify about his knowledge of asbestos abatement at the Sherwin Alumina Plant Ernest L. Sweet 114 Glenwood Drive Liverpool, New York 13090 (315) 652-6543 Mr Sweet was the Superintendent for Environmental Health and Safety from 19S0- October 1985 He may be called to testify' about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding OSHA and MSHA requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be called to testify about his knowledge regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training. He may further be called to testify about his knowledge of asbestos abatement at the Sherwin Alumina Plant. William E. Hamblin Sherwin Alumina Plant P.O. Box 9911 Highway 36l Gregory, TX 78469 Mr. Hamblin was a Senior Maintenance Engineer at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Lou Suffredini ^ Austin, Texas Mr. Suffredini was the Plant Manager of the Sherwin Alumina Plant. He was employed at the Sherwin Alumina Plant from the early 1950s-1977. He may be called to _ testify about rus knowledge of Reynolds' safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as olher information. Timothy D. Woods ^ Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Woods is the Plant Controller at the Sherwin Aiumma Plant. He may be called to Testify about his knowledge of Reynolds' safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. 7 Frank Strickland Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory.TX 78469 Mr. Strickland is the Purchasing Manager for Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safery procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. D. T. Greeson ^ Sberwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Greeson is a Purchasing Agenc for Sherwin Alumina Plant. He may be called to testify- about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information James C. Tiffany ^ Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Tiffany was the Plant Engineer ax the Sherwin Alumina Plant from approximately 1973-76 and was a General Engineer, Maintenance Superintendent, and Senior Engineer for various periods from 1964-73 and 1985 to the present. He may be called to testify about his knowledge of the use of products that contained asbestos, the elimination of some asbestos-containing products, and asbestos abatement. He may also be called to testify about his knowledge of Reynolds' safery procedures, and use of safetyequipment at the Sherwin Alumina Plant, as well as oiher information. Jack C. Oates ^ Shenvin Alumina Plant P.O. Box 9911 Highway 361 Gregory', TX 78469 Mr. Oaies was xhe Plane Engineer at the Sherwin Alumina Plant from ! 9S0-S4 and was Maintenance Engineer, Project Engineer, and Project Manager for various periods between 1967-74 and 1977-91. He is currently the Senior Engineering Supervisor at the Sherwin Alumina Plant. He may be called to testily about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Paul Manila ^ Sherwin Alumina Plant P.O. Box 9911 Highway 36l Gregory, TX 78469 Mr. Maiula is a Designer in the Engineering Department of Sherwin Alumina Plant. He may be called to testily about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Mario Rivera ^ Sherwin Alumina Plant P.O. Box 9911 Highway 36l Gregory, TX 78469 Mr. Rivera was a maintenance supervisor in Area 50 of Sheiwm Alumina Plann _ _ He is currently in the Industrial Hygiene Department of the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as oiher information. 9 Charles Chapman Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 ' Mr. Chapman was a maintenance supervisor m Area 50 of Shenvin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Jeffrey Downs ^ Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory , TX 78469 Mr. Downs is the current maintenance supervisor in Area 50 of Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Gary Cedotal " Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Cedotal was the maintenance supervisor for Areas IV and V of the Sherwin Alumina Plant from 1989-93 He is currently the Shift Maintenance Supervisor He may be called to testify about his knowledge of Reynolds' safety procedures, safety u equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Ernest Coulter ^ Sherwin Alumina Plan: P.O. Box 9911 Highway 361 Gregory , TX 78469 Mr. Coulter was the Maintenance Supervisor and General foreman in the Maintenance Department at the Sherwm Alumina Plant from 1963-90. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos ax the Sherwin Alumina Plant, as well as other information. 10 LudwigJahn Sherwin Alumina Plant P.O. Box 9911 Highway 36l Gregory, TX 78469 Mr. Jahn has been the Maintenance Supervisor in the Maintenance Department a the Sherwin Alumina Plant since 1989. Prior to this position, Mr. Jahn held numerous jobs in the Maintenance Department in the 1970s. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbesios at the Sherwin Alumina Plant, as well as other information. Hector De La Garza t'_ Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. De La Garza is in the Environmental Department of the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Adan J. Villarreal ^ Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregoiy , TX 78469 Mr. Villarreal is a Cost Accountant at the Sherwin Alumina Plant. He may be I called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbesios, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Lester Charles Homan Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Homan is a Senior Accountant at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Ernest Boulware 215 Seco Ponland, TX 78374 Mr. Boulware is a retired carpenter, laborer and maintenance mechanic from the Sherwin Alumina Plant He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information Frank Hall, Jr. ^ 401 Rabbit Run Road Arkansas Pass, TX 78336 Mr. Hall is a building and trade mechanic, employed with the Sherwin Alumina Plant since the late 1950s. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Weldon Hesseltine Sherwin Alumina Plant f.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Hesseltine is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1955. He may be called to testify concerning his knowledge ofthe work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. I Leroy Rhoads ^ Sherwin Alumina Plant P.O.Box 9911 Highway 361 Gregory, TX 78469 Mr. Rhoads is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1969. He may be called to testify concerning his knowledge of the work environment Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, the involvement of the Union in safety matters at the Sherwin Alumina Plant, as well as other information. 12 Howard Cave Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Cave is a member of the Maintenance Department at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Ronald Hesseltine *"' Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Hesseltine is a supervisor, employed with the Sherwin Alumina Plant. He worked as an hourly equipment cleaner from 1965-88. He was promoted to supervisor in 1988 and worked as a supervisor in Areas IV and V from 1994-96. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of producxs which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Jimmie Lehman ^ Sherw in Alumina Plant P.O. Box 9911 Highway 361 Gregory,TX 78469 Mr. Lehman is a building and trade mechanic, employed with the Sherwin u Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Howard Bittel ^ Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Bittel is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1987. He may be called xo testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. 13 n Chuck Coulter Sherw in Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Coulter is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Willie Enriquez *-/ Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregor)', TX 78469 Mr. Enriquez is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning Jus knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Mike Gonzales, Jr. Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Gonzales is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, _ _ and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. A. Littlejohn Sherwin Alumina Plant P.O.Box 9911 Highway 361 Gregory, TX 78469 Mr. Littlejohn is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information 14 Tony Dunn -- Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Dunn was the Process Engineer at the Sherwin Alumina Plant from 1963-70 and was Technical Manager and Superintendent, and Operating Superintendent for various periods between 1974*76 and 1978-95. He is currently the Training Manager at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. (b) Reynolds Corporate Personnel. Reynolds may call some or all of the following individuals to testify regarding their personal knowledge on matters of safety, medical and industrial hygiene issues on the corporate level and/or at the Sherwin Alumina Plant specifically; plant operations and conditions, the use, elimination and/or substitution of asbestos- containing products; and, on other matters relevant to plaintiffs claims and/or Reynolds' defenses: Dr. Woolson W. Doane 14 Runswick Drive Richmond, Virginia 23233-5413 Dr. Doane was Reynolds' Corporate Medical Director from 1993-June 1997. He may be called to testify- about his knowledge concerning corporate medical issues and the Respiratory Surveillance Program at the Sherwin Alumina Plant. ~ David Warren, M-D. 8705Tarytown Drive Richmond, Virginia 23229 Dr Wanen was the acting Corporate Medical Director from 1992-93. He may be called to testify about his knowledge concerning corporate medical issues and the Respiratory Surveillance Program at the Sherwin Alumina Plane. 15 E. Claiborne Irby, M.D. 11-1/2 Tapoan Road Richmond, Virginia 23226 Dr. Irby was an Associate Corporate Medical Director from 1959-77, and Corporate Medical Director for Reynolds from 1977 until his retirement in 1992. He may be called as a factual witness, but because he also qualifies as an expen, he may offer expen, he may offer expert testimony m the fields of occupational medicine, state-of-the-art, governmental regulations, and medical issues in general as they may relate to occupational asbestos exposures. James MacMillan, M.D. 306 Gunby Drive Richmond, Virginia 23229 Dr. MacMillan was the Corporate Medical Director of Reynolds from 1956-77. He may be called to testify about his knowledge concerning corporate medical issues and the Respiratory Surveillance Program at the Sherwin Alumina Plant. Mr. Homer Mac Cole Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 (804) 281-3506 Mr. Cole is the Corporate Director of Industrial Hygiene and Toxicology at Reynolds. He has been an industrial hygienist at Reynolds since 1972. Mr. Cole performed industrial hygiene surveys at the Sherwin Alumina Plant and may testify regarding such surveys as well as other factual matters based on his personal experience and knowledge, including, but not limited to, plant conditions, various uses of asbestos^ _ containing products in plant applications, the elimination and substitution of asbestoscontaining products, and general issues related to industrial hygiene and safety. Although Mr. Cole will testify as a factual witness, he qualifies as an expen and may offer expert testimony in the fields of industrial hygiene, occupational health and safety, state-of-theart, governmental regulations of workplace exposures, threshold limit values, the measurement of occupational asbestos exposures as well as other potential occupational hazards, respiratory protection, and proper work practices. 16 Mr. Ronald . Benton Reynolds Mmis Company 6601 West Broad Street Richmond, Virginia 23230 Mr. Benton is Manager of Industrial Hygiene and Safety Services at Reynolds. He has been at Reynolds since 1974. He performed industrial hygiene surveys at the Shemin Alumina Plant and may testify regarding such surveys as well as other factual marters based on his personal experience and knowledge. Mr. Benton may testify as a factual witness, but because he qualifies as an expert, he may offer expert testimony in the fields of industrial hygiene, occupational and environmental health and safety, state-of-the-art, governmental regulations of workplace exposures, threshold limit values, the measurement of occupational asbestos exposures as well as other potential occupations! hazards, respiratory protection, and proper work practices. Ms. Linda Maillet Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 Ms. Maillet was The Regional Industrial Hygienist at the Corporate Headquarters of Reynolds for the Eastern Region. She is currently the Principal Health, Safety and Regulatory Affairs Scientist at the Cotporate Headquarters. Ms. Laurie Shelby Reynolds Merals Company 6601 West Broad Street Richmond, Virginia 23230 Ms. Shelby was the Manager of Industrial Hygiene Programs at the Corporate " _ Headquarters of Reynolds. She is currently the Manager of Health and Safety Programs. Mr. Richard Mansur 1416 Coronet Drive Richmond, Virginia 23229-4806 (804) 282-4438 Mr. Mansur was the Manager of the Industrial Hygiene Department at the Corporate Headquarters of Reynolds from 1969-75. Mr. James D. Davidson Mr. Davidson was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1976-82. 17 Ms. Stacey Hansen 12701 Mirror Pond Way Midlothian, Virginia 23113 (804) 794-1736 Ms. Hansen was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1990-93. Mr. Dale Prokopchak 2704 Empress Court Richmond, Virginia 23233 (804) 360-3301 Mr. Prokopchak was a Staff Industrial Hygienist at the Corporate Headquaners of Reynolds from 1988-89. Ms. Deborah R. Hudgins Ms. Hudgins was a Siaff Industrial Hygienist atthe Corporate Headquaners of Reynolds from 1984-88. Mr. Harry L. Skalsky 6910 West Grace Street Richmond, Virginia 23261 Mr. Skalsky was a Medical Corporate Toxicologist at the Corporate Headquarters of Reynolds 1979-85. Ms. Karen Kestle 1336 Merrymeade Avenue Glen Alien, Virginia 23060 (806) 264-1789 ^ Ms. Kestle was the Senior Insurance Administrator at the Corporate Headquaners of Reynolds Mr. Bobby J. Sasser Mr, Sasser was the Corporate Safety Director for Reynolds from 1973-95. 18 Mr. Joseph Nichols 2300 Cedarfield Parkway Apartment 161 Richmond, Virginia 23233 (804) 282-8245 Service Environmental Co. P.O.Box 2355 Beaumont, TX 77704 Performed insulation and/or asbestos abatement work ax the Sherwin Alumina Plant. Accordingly, certain agents or employees of Service Environmental Co. may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as otheT information. industrial Specialist Inc. P.O. Box 1630 Lake Jackson, TX 77569 Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Industrial Specialist Inc. may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at ihe Sherwin Alumina Plant, as well as other information. Estes Refractory & Insulation 6300 Highway 70 N. P.O. Box 600 Belle Rose, LA 70544 Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Estes may be called to testify concerning Reynolds' safety procedures, safery equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. 19 TGI Stephens 777 N. Eldrige, Suite 315 Houston, TX 77079 Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant Accordingly, certain agents or employees of TGI Stephens may be called to testify concerning Reynolds' safety procedures, safety equipmem, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Thermo Tech. Inc. P.O.Box 3109 Orange, TX 77631 Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Thermo Tech may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Shenvin Alumina Plant, as well as other information. Gilman Insulation Co. P.O. Box 4074 Corpus Chrisii, TX 78469 Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Gilman Insulation may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Piant, as well as other information. Falcoo Associates P.O. Box 7777 Philadelphia, PA 19175 U Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Falcon Associates may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Brand Remediation Services, Inc. 1914 Austin Street Orange, TX 77630 Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Brand Remediation may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information Norrfawinds Abatement, Inc. 903 Port Houston Street Houston, TX 77029 Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Nonhwinds Abatement may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos ax the Sherwin Alumina Plant, as well as other information. Casanova Industrial Insulation P.O. Box 4761 Corpus Chrisri, TX 78408 Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Cassanova Industrial may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Northwest Envirocon, Inc. 16811 El Camino Real Suite 119 Houston, TX 77058 ~ Performed asbestos audits and abatement work ax the Sherwin Alumina Plant. Accordingly, certain agents or employees of Northwest Envirocon may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. 21 Alex Baca Baca Safety Consulting 6214 Battery Lane ~ San Antonio, Texas 78233 (210) 657-0705 Mr. Baca is a retired inspector for the United States Department of Labor Mine Safety Health Administration. He was a Federal Mine Safety and Health Inspector from 197 until January, 1998 with duties to enforce the Safety and Health Regulations on Mining Operations and to gain compliance with such regulations. Pursuant to this position, Mr. Baca inspected the Sherwin Alumina Plant. Mr. Baca may testify regarding such inspections as well as to other factual matters based on his personal experience and knowledge. Robert E. Ruckstuhl Proactive Safety Consultants Company, Inc. Post Office box 260955 Corpus Christi, Texas 78426-0955 (512) 767-1663 Mr. Rucksmhl is a consultant who specializes in the area of asbestos safety and training. He has performed consulting functions and training seminars related to asbestos safety and asbestos abatement issues at the SheTwin Alumina Plant and may testify regarding such consulting services and training seminars as well as other factual matters based on his personal experience and knowledge. 6) Records Custodians. Reynolds may call the individuals, live or by deposition or affidavit, to authenticate relevant records. 7) Other Parties* Witnesses. Reynolds reserves the right to call and/or elicit testimony from any individual identified by Plaintiff and any other party to this lawsuit and, accordingly, will supplement its response to this request when those individuals have been identified. 8) Reburtal/Imneachment Witnesses. Reynolds reserves the right to call rebuttal and/or impeachment witnesses and will supplement its response to this request ifand when it has sufficient information to determine the need for such testimony. 22 F. For any testifying expert: (1) The expert's name, address, and telephone number; (2) The subject raaner on which the expen will testily; (3) The general substance of the expen's mental impressions and opinions and a brief summary of the basis for them, or if the expen is not retained by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; (4) If the expen is retained by, employed by, or otherw ise subject to the control of the responding party: (A) All documents, tangible things, reports, models, or data compilations that have been provided to, reviewed hy, or prepared by or for the expen in anticipation of the expert's testimony; and (B) The expen's current resume and bibliography. Reynolds reserves the right to supplement its response to this Request until 60 days before the end of discovery in this matter. G. Any discoverable indemnity and insuring agreements. Reynolds has insurance coverage sufficient to cover plaintiff's claims with the following insurance companies: Travelers Insurance (9/30/33 through 9/30/66); and . Liberty Murual Group (9/30/66 through 9/30/78). H. Any discoverable settlement agreements. None. I. Any discoverable witness statements. None. 23 J. Ail medical records and bills That are reasonabl) related to the injuries or damages asserted or, in lieu thereof, an authorization permitting the disclosure of such medical records and bills. See Reynolds' Response to Request K.. K. All medical records and bills obtained by the responding party by virtue of an authorization furnished by the requesting part) . Subject to plaintiff's agreement to pay Reynolds one-half of its cost in retrieving these records, Reynolds will produce these records at S 10 per copy or will make them available to plaintiffs counsel for inspection and copying at a mutually convenient time and place. 24 REYNOLDS METALS COMPANY By: fWl David Craig tan (Texas Bar No. 11S63720) John D. Epps (Texas Bar. No. 00796079) Harry M Johnson, III (Texas Bar No. 00797740) HUNTON &. WILLIAMS 951 Easi Byrd Street Riverfront Plaza, East Tower Richmond, Virginia 23219 (804) 788-8200 (804) 788-8218 (facsimile) R. Clay Hoblir (Texas Bar No. 09743100) CHAVES, GONZALES & HOBLIT, L.L.P. 2000 Frost Bank Plaza 802 North Carancahua Corpus Christi, Texas 78470 (512) 888-9392 (512) 888-9187 (facsimile) Attorneys for Reynolds Metals Company certificate of service I hereby certify that on March 4,1999, a true and correct copy of the above and foregoing instrument is being served by UPS Overnight Mail, on the following Plaintiffs counsel. Russell W. Budd, Esq. Alicia J. Haff, sq baron & budd, p.c. The Centrum Suite 1100 3102 Oak Lawn Avenue Dallas, Texas 75219 a copy is also being served on all other known counsel of record by regular United States mail. 26 HUNTON& WILLIAMS May 14, 2001 RIVERFRONT PLaZa, EaST TOWER 9Si East byrd street RICHMOND. VIRGINIA 23219-4074 TEL 804 788 8200 FAX 804 * 788 - 8218 JENNIFER L bORUM DIRECT DIAL 804*788*8528 EMAIL, jeoruni@tmnion.com FILE NO-50084.33 via facsimile Stephanie A. Finch, Esq. Baron & Budd, P,C. The Centrum, Suite 1100 3102 Oak Lawn Avenue Dallas, Texas 75219 Fay Moore v. Reynolds Metals Company, et al. No. S-98-5033CV-C Dear Stephanie: I am in receipt of your letter of today in which you request that I send you another copy of Reynolds' responses to Plaintiffs Requests for Disclosure. As I informed you on May 9 (the date of your inquiry), and as a courtesy to you, I mailed to you on Mav9 via U.S. mail a duplicate copy of the responses which we originally provided to you on March 4,1999. While it is reasonable to assume that the package 1 mailed to you on Wednesday, May 9 is likely to arrive on your desk either today (Monday) or tomorrow, I am providing this document for a third lime, via fax, along with my letter of May 9. as always, if you have any questions, feel free to call me at (804) 788-8528. Very truly yours. Enel. Atlanta Bangkok Brussels charlotte hong kdng knoxvxlle uosdon mclean NEW YORK NORFOLK RaLEIGH RICHMOND WaRSaV. WASHINGTON wunv. humoa.co.Ti mLaMI HUNTON& wmiAMs May 9.2001 VIA REGULAR MAH Stephanie A. Finch. Esq. Baron & Budd, P C. The Centrum, Suite 1100 3102 Oak Lawn Avenue Dallas. Texas 75219 Fr WORKING COPY RIVERFRONT PLaZa. East tower 93) East BYRD STREET RICHMOND. VIRGINIA 2:219-1074 TEL 80* -78S- 8300 FAX S04-7IK-S2I8 JENNIFER L BORU.M DIRECT DIAL. 804 7SS S323 FILE NO: 506S4.:3 al. Dear Ms. Finch: I am in receipt of j to Plaintiffs Requests for Reynolds provided to you Enclosed please fin i Reynolds' responses message today. Enel. ATLANTA BANGKOK BRUSSELS CHaRLOTTE HONG KONG KNOXVILLE LONDON MCLEaN NEW YORK. NORFOLK. RALEIGH RICHMOND WARSAW WASHINGTON hunton.coin MIaMI M.-JU LOu R055VTSO.\ E-.'-Lv.i_ MIK03ESTS0\{gKl.'NTQN COM Hxjnton & Williams H;v53J'23NT . E.-vST Tow'S S^I ivsST Bvss SrSEET "it^PnONi 130-1 7Q3-S2QQ .-c3>-iu.; 130-^1 733-52i3 Fic N'O 50uS4j3 DiKSCTDiu. (804) 735-3 March 4, 1999 Via UPS Overnight Mail Alicia J. Haff, Esquire Baron &. Budd, P.C. The Centrum, Suite 1100 3102 Oak Lawn Avenue Dallas, Texas 75219 Re: Fay Moore v. Owens-Corning Fiberglas Corp., et ai 343ra Judicial District Court of Nueces County ; No. S-98o033CV*C Dear Alicia Enclosed please find Defendant Reynolds Metals Company's Responses To Plaintiff's Request For Rule 194 Request For Disclosure. By copy of this letter, we are giving notice to ail counsel of record. Copies of this pleading are available upon request by contacting my office at the telephone number listed above. Sincerely Mary Lou Robertson Enclosure cc: All Known Counsel of Record (via regular mail) (w/o end )