Document 2jQXpY4ak63k03p5RdaZEX2ma

CAUSE NO. 98-748-A GEORGE JOSEPH DOLEZAL, et al. Plaintiffs, VS. OWENS CORNING, et al., Defendants. IN THE DISTRICT COURT NUECES COUNTY, TEXAS 28TH JUDICIAL DISTRICT DEFENDANT ALCOA INC.'S LIST OF EXPERT AND FACT WITNESSES I. EXPERT WITNESSES J. LeRoy Balzer, Ph.D 408 Horse Trail Court Alamo, CA 94507 Phone: 925-274-0826 Fax: 925-274-1413 Dr. Balzer was a Certified Industrial Hygienist from 1973 until 1987 when he became an Assistant Vice Chancellor at the University of California Health Sciences Campus in San Francisco. Dr. Balzer may testify regarding the state of scientific and medical knowledge concerning asbestos during the time periods relevant to this case. Dr. Balzer may give testimony regarding the level of asbestos fiber released in various activities. He may testify regarding threshold limit values and permissible exposure levels as promulgated by private organizations and government agencies. He may testify as to work practices in various types of occupations using products that contained asbestos. He may testify as to the applicability of the Environmental Protection Agency and OSHA guidelines as they relate to various types of occupations. Dr. Balzer's testimony will be based on his training, experience, education, review of the relevant medical and scientific literature, a site visit to Alcoa's Point Comfort Operations, and a review of the documents produced by the parties during discovery. Peter J, Barrett, MD 300 Boylston Street, Suite 714 Boston, MA 02116-3923 Phone: 617-426-2110 Fax: 617-426-6415 Dr. Barrett is a radiologist and certified B-Reader. Dr. Barrett may testify, in general, concerning the criteria for diagnosis of an asbestos related disease. Based on Plaintiffs medical records and radiographs. Dr. Barrett may also testify regarding the existence or non-existence of any asbestos-related disease in Plaintiff. Dr. Barrett may testify as to review and interpretation of x-ray films, and whether other diseases or conditions were present in Plaintiff. Dr. Barrett may also testify regarding the existence or non-existence of any asbestos-related disease in employees performing similar jobs at the Point Comfort plant. Dr. Barrett may testify that one cannot have an asbestos-induced mesothelioma in the absence of radiographic indicia of asbestos exposure. Dr. Barrett's testimony will be based on his training, experience, education, review of Plaintiff s medical records and radiographs, review of a series of x-rays of employees who have worked at the Point Comfort plant, and review of the medical literature concerning asbestos-related disease. William Burgin, M.D. 2601 Hospital Blvd. Corpus Christi, Texas 78405 Phone: 361-884-8209 Dr. Burgin is a Pulmonologist. Dr. Burgin may testify, in general, concerning asbestos related diseases and the effects of asbestos exposure upon persons in occupational settings, including the epidemiology of asbestos related diseases and the criteria for diagnosis of an asbestos related disease. Based on Plaintiffs medical records and radiographs, Dr. Burgin may also testify regarding the existence or non-existence of any asbestos related disease. Dr. Burgin may testify as to review and interpretation of x-ray films, review and interpretation of pulmonary function testing, and whether other diseases or conditions were present in Plaintiff. Dr. Burgin may testify on the health consequences of smoking. He may also testify on the existence of a dose response relationship between exposure to asbestos and asbestos related disease. Dr. Burgin may testify about general medical issues relating to smoking, asbestos, asbestosis, emphysema, bronchitis, COPD, cancer, the lungs, and the respiratory system. Dr. Burgin's testimony regarding the condition of the Plaintiff and the causes of his symptoms and disease will be based on his training, experience, education, review of medical records, and review of relevant medical literature concerning asbestos related disease. Lawrence W. Birkner McIntyre, Birkner & Associates, Inc. 2026 El Monte Drive Thousand Oaks, CA 91362-1822 Phone: 805-494-8173 Mr. Birkner is an experienced certified industrial hygienist with extensive background in the prevention of adverse health effects and injuries in the workplace by evaluating the workplace for potential hazards with regard to work practices and workplace design; measuring and evaluating various substances to assess exposure, exposure potential and health and safety risks; and controlling the occupational setting with engineering, work practice, administrative, and personal protective equipment methods. Mr. Birkner may testify as to the state of the art with respect to asbestos in the field of industrial hygiene, and in particular the evolution of knowledge regarding the effects of asbestos exposure and its control during the period relevant to this case. He may also testify as to the development and utility of methodologies identifying and measuring asbestos in air, dust and products, and the process of setting threshold limit values ("TLVS") and other levels for asbestos exposure. He may also testify regarding the evolution of various standards for exposure to asbestos, including Threshold Limit Values and OSHA Permissible Exposure Limits. 2 Mr. Birkner may discuss the relationship between scientific knowledge and the development of public policy and the standards relating to asbestos exposure, and all aspects of government regulation of asbestos exposure. Mr. Birkner may discuss historic literature regarding asbestos exposure and its health consequences, and recommended methods for controlling those consequences. Mr. Birkner may discuss the conditions and circumstances necessary to give rise to asbestos-related disease, as reflected in the historic literature, including the nature of the exposure, fiber type involved, duration of exposure, intensity of exposure and job categories. He may also testify industrial hygiene relating to asbestos, including, but not limited to asbestos containing products used in manufacturing facilities, construction sites, and assessment of risk of exposure under various circumstances. Mr. Birkner may also testify about the development of knowledge regarding the dose-response relationship between exposure to asbestos and disease, and other related matters including knowledge about asbestos- related disease among aluminum workers. Mr. Birkner may also testify about the development of the internal knowledge of ALCOA regarding exposure to asbestos, including but not limited to what was known and knowable regarding the health effects of exposure to asbestos, the knowledge available to the industry and the advice being given by industrial hygienists in the field, potential risks of exposure to asbestos, how to address those risks in various occupational settings, and finally the development of information regarding finished products and their application in field settings. Mr. Birkner may testify about the approaches generally and by ALCOA in particular for controlling the risks arising from exposure to asbestos and asbestos-containing products in occupational settings, including but not limited to work practices, engineering controls, warnings and labeling. Mr. Birkner may comment about testing done by or on behalf of the Plaintiff, including critique and analysis of the sampling methods and analysis, protocols and scientific basis for the tests, and accuracy of the testing in reproducing field conditions. Mr. Birkner's testimony will be based on his training, experience, education, review of the relevant medical and scientific literature, a review of various documents produced by the parties in discovery, a review of deposition transcripts, and a site inspection of the Alcoa facilities. Mr. Birkner may testify about matters referred to in the designations of Dr. First, Dr. Balzer and Dr. Weir. Philip Cagle Center for Pulmonary Pathology 1200 Moursund, Room 286A Baylor College of Medicine One Baylor Plaza Houston, TX 77030 Phone: 713-798-3671 713-790-2370 Dr. Cagle is a physician who is an expert in the field of pathology. Furthermore, he is an expert in the etiology and diagnosis of asbestos-related disease based upon review of tissue and tissue slides obtained as a result of biopsy or autopsy. His testimony will include a discussion of asbestos and its effect on human health generally and Plaintiff specifically, and the effect that other substances have on human health generally and Plaintiffs conditions specifically. Dr. Cagle is a pulmonary pathologist who may testify about asbestos related diseases, causes of cancer, and the effect of other substances, such as cigarette smoke, on the Plaintiff. Dr. 3 Cagle may also testify regarding the Plaintiffs medical condition based upon a review of medical records, x-rays, Plaintiffs experts' reports and supplemental reports, and Plaintiffs deposition. Morton Corn, Ph.D. Director, Division of Environmental Health Engineering The Johns Hopkins University 3208 Bennett Point Road Queenstown, Maryland 21658-1126 Phone: 410-827-7305 Dr. Com is expected to testify regarding the history and development of regulations and government documents concerning asbestos. He may testify about the dissemination and availability of information related to asbestos. Dr. Com is Professor Emeritus at the Johns Hopkins University Department of Environmental Health Sciences, Division of Environmental Health Engineering and holds a Ph.D. in Industrial Hygiene and Sanitary Engineering from Harvard University. Dr. Com will testify regarding exposure issues related to the handling of some asbestos-containing products as well as the relative risks, governmental regulations and feasibility of engineering controls. He may discuss and testify about levels of asbestos exposure experienced in various occupations and trades, fiber emitting propensities of products, factors affecting levels of exposure, and industrial hygiene practices. Dr. Com may base his opinions regarding use of such asbestos-containing products on various fiber release studies performed at industrial hygiene laboratories. Dr. Com may testify as to the state of the art with respect to asbestos in the field of medicine and in particular the evolution of knowledge regarding the effects of asbestos exposure on human health. Dr. Com may discuss historical literature regarding asbestos exposure and its health consequences. Dr. Com may discuss the conditions and circumstances necessary to give rise to asbestos-related disease as reflected in the historical literature, including the nature of the exposure, the type of fiber or asbestos involved, the duration of exposure, the intensity of the exposure and the job category or tasks involved in the exposure. Dr. Com may testify about the development of knowledge regarding the dose-response relationship between exposure to asbestos and disease and other related matters including current and historic knowledge about asbestos-related disease among aluminum workers. Dr. Com may testify that based on the medical and scientific literature available at the time, Alcoa could not have reasonably known that its particular use of asbestos could be injurious. Dr. Com may testify as to his review of the literature and the opinions and conclusions contained in that literature. Dr. Com may testify as to his experiences and developing knowledge as a doctor over the years. Dr. Com may testify regarding exposure levels to asbestos, at what levels asbestos may cause disease, and when this was known and reflected in the medical and scientific literature. Dr. Com is expected to testify regarding Alcoa Point Comfort's health and safety practices and safety statistics, as compared to industry generally during the time periods when Plaintiff may have worked at Alcoa. John E. Craighead, M.D. 1845 Four Winds Road 4 Ferrisburgh, VT 05406 Phone: 802-425-3480 Dr. Craighead is a pathologist. Upon review of Plaintiffs medical records and pathology materials. Dr. Craighead may testify about Plaintiffs medical condition and its causes. His testimony may include a discussion of asbestos and its effects on human health generally and on the Plaintiffs condition specifically and the effect of other substances on human health generally and on the Plaintiffs condition specifically. Dr. Craighead may testify regarding the increased risk of cancer faced by individuals who smoke cigarettes or other tobacco products and the link between smoking and cancer. Dr. Craighead may testify about the relationship between asbestos exposure and cancer and the methods by which it can be determined whether a particular cancer is related to asbestos exposure. Dr. Craighead may apply these principles to Plaintiffs case. Dr. Craighead may discuss asbestosis, bronchitis, bronchiolitis, emphysema, peribronchial fibrosis, smokers pigment and Chronic Obstructive Pulmonary Disease, their interaction and their relationship to cancer. Dr. Craighead may testify as to the state of the art with respect to asbestos in the field of medicine and in particular the evolution of knowledge regarding the effects of asbestos exposure on human health. Dr. Craighead may discuss historical literature regarding asbestos exposure and its health consequences. Dr. Craighead may discuss the conditions and circumstances necessary to give rise to asbestos-related disease as reflected in the historical literature, including the nature of the exposure, the type of fiber or asbestos involved, the duration of exposure, the intensity of the exposure and the job category or classification involved in the exposure. Dr. Craighead may testify about the development of knowledge regarding the dose-response relationship between exposure to asbestos and disease and other related matters including current and historic knowledge about asbestos-related disease among aluminum workers. Dr. Craighead may testify regarding Plaintiffs diagnosis and symptoms and their relationship, if any, to his alleged exposure to asbestos and/or other substances, including cigarette smoke. Dr. Craighead may discuss the relationship between the time of Plaintiffs alleged exposure to asbestos and its relationship to the onset of disease. Dr. Craighead may discuss the concept of latency and its applicability to this case. Dr. Craighead may testify about cigarette smoking and the diseases caused by cigarette smoking generally. Dr. Craighead may testify based on epidemiology studies as to the cause of Plaintiffs alleged asbestos-related disease. Dr. Craighead may testify that based on the medical and scientific literature available at the time, Alcoa could not have reasonably known that its particular use of asbestos could be injurious. Dr. Craighead may testify as to his review of the literature and the opinions and conclusions contained in that literature. Dr. Craighead may testify as to his experiences and developing knowledge as a doctor over the years. Dr. Craighead may testify regarding exposure levels to asbestos, at what levels asbestos may cause disease, and when this was known and reflected in the medical and scientific literature. Dr. Craighead may also testify about the body's biological responses to exposure to asbestos, the pathogenic effects produced by various asbestos fiber types and the levels of exposure necessary for such effects, the levels and circumstances of exposure necessary to produce them and the mechanisms of asbestos induced diseases including fibrosis and carcinogenesis. He may further testify concerning asbestos deposition and elimination from the lungs and body. 5 Dr. Craighead may testify concerning the fiber types of asbestos generally and the asbestos-related diseases that can be potentially caused by those types and under what circumstances. Dr. Craighead may testify concerning the various alleged exposures to asbestos encountered by Plaintiff during his lifetime and the relative probability ofthose exposures being related to the development of the alleged asbestos-related disease. Dr. Craighead's testimony will be based on his training, experience, education, review of the relevant medical and scientific literature, a review of the various documents produced by the parties in discover}', their pertinent medical records and pathology specimens and records introduced by Plaintiff as evidence in this case. Dr. Craighead may testify further as to matters described in the designation of Dr. Cagle. I.A. Feingold, M.D., F.R.C.P.(C)., FCCP Chief, Division of Pulmonology Medicine South Miami Hospital 6200 Southwest 73rd Street Miami, FL 33143 Phone: 305-662-5352 Dr. Feingold is a pulmonologist and certified B-reader. Dr. Feingold may testify, in general, concerning asbestos related diseases and the effects of asbestos exposure upon persons in occupational settings, including the epidemiology of asbestos related diseases and the criteria for diagnosis of an asbestos related disease. Dr. Feingold may also testify regarding the existence or non-existence of any asbestos related disease in Plaintiff. Dr. Feingold may testify regarding review and interpretation of x-ray films, and whether other diseases or conditions were present in Plaintiff. Dr. Feingold may testify on the health consequences of smoking. He may also testify on the existence of a dose response relationship between exposure to asbestos and asbestos related disease. Dr. Feingold may testify about general medical issues relating to smoking, asbestos, asbestosis, lung cancer, the lungs, and the respiratory system. Dr. Feingold may testify about the anatomy and physiology of the lungs and other parts of the respiratory system. He may testify about PlaintifFs medical history. Dr. Feingold may testify about lung cancer and other cigarette related diseases. He may testify about the effects of cigarette smoking on the lungs and other parts of the respiratory system. He may discuss bronchitis, bronchiolitis, peribronchial fibrosis, emphysema. Chronic Obstructive Pulmonary Disease, smokers pigment and the relationship, if any, between these conditions and exposure to tobacco smoke. He may testify about the causal association between cigarette smoking and lung cancer, and the effect, if any, of cessation of smoking to that association. Dr. Feingold may testify that based on the medical and scientific literature available at the time, Alcoa could not have reasonably believed that its particular use of asbestos could be injurious. Dr. Feingold may testify as to his review of the literature and the opinions and conclusions contained in that literature. Dr. Feingold may testify about the nature of asbestos exposure and when it was known that particular types of exposure could cause disease, as reflected in the medical and scientific literature. This testimony may include a discussion of levels of exposure, fiber type, and job descriptions and categories. 6 Dr. Feingold's testimony will be based on his training, experience, education, review ofthe relevant medical and scientific literature, a review of various documents produced by the parties in discovery, medical records, pathology specimens, x-rays, and deposition transcripts. Melvin W. First Harvard School of Public Health Department of Environmental Health 665 Huntingdon Avenue Boston, MA 02115 Dr. First is an industrial hygienist. Dr. First may give testimony regarding the level of asbestos fibers released in various situations. He may testify regarding threshold limit values and permissible exposure levels as promulgated by private organizations and government agencies both currently and historically. He may testify as to work practices over the years. He may testify regarding what was known historically about the hazards of asbestos and the appropriate response to that hazard. Dr. First may testify concerning the prudence ofAlcoa's occupational health and safety practices, the likelihood that Plaintiff was exposed during his working career to a number of airborne asbestos fibers of hygienic significance in excess of then current standards or recommendations and the likelihood that these alleged exposures are related to Plaintiffs alleged disease. Dr. First is of the opinion that Alcoa's industrial hygiene practices were among the most advanced in their industry and that Alcoa was and is a responsible employer. Dr. First may discuss some environmental exposure measurements made over the years by Alcoa. Dr. First may discuss the mechanical air conduction exhaustion air systems in the various departments of the plant. Dr. First may discuss the hygienic significance of visible dust particles. Dr. First may discuss the periodic physical examination and x-ray program employed by the plant. Dr. First may discuss the government and industry regulations regarding asbestos exposure and their development and modification over the years. Dr. First's testimony will be based on his training experience, education, review of the relevant medical and scientific literature, a review of various documents produced by the parties in discovery, a review of deposition transcripts, and a site inspection of the Alcoa facility. Dr. First may testify further regarding the subjects described in the designations of Dr. Balzer, Dr. Weir and Mr. Birkner. Dr. Richard Lee RJ Lee Group, Inc. 350 Hochberg Road Monroeville, PA 15146 Phone: 724-325-1776 Dr. Lee is a microscopist, material scientist and physicist. Dr. Lee may testify about methods for testing and measuring airborne concentrations of asbestos fibers, the size of respirable fibers, and potential exposure of Plaintiff. He may comment on the work of Dr. Longo and others. Dr. Lee may also testify regarding potential exposure of Plaintiff to environmental tobacco smoke. 7 Dr. Lee will assess Plaintiffs exposure to asbestos. Dr. Lee may testify about any tests he has performed regarding potential to exposure to asbestos in the performance of various tasks. Dr. Lee may testify concerning experiments performed to determine release of asbestos from particular products. Dr. Lee may testify concerning the nature of such experiments and the results and determinations based upon those experiments. This witness may testify concerning the precise hazards caused by the levels of dust generated by the products in question. Dr. Lee may also testify concerning the use of such products, the handling of such products and the asbestos content of such products. He may testify concerning the specific exposure of an individual when handling or using such products or while in the vicinity of such products while being used or handled. Dr. Lee's testimony will be based on his training, experience, education, review of the relevant medical and scientific literature, a review of various documents produced by the parties in discovery, a review of deposition transcripts, and any inspection he has performed of Plaintiffs place of work. Dr, Robert Morgan Environmental Health Strategies 149 Commonwealth Place Menlo Park, CA 94205 Phone: 650-688-1750 Fax: 650-688-1799 Dr. Morgan may be offered as an expert in epidemiology and cancer epidemiology. Dr. Morgan may testify concerning his analysis of the data on asbestos exposure and the illnesses that may result, cigarette smoking and exposure to environmental tobacco smoke and the illnesses that may result, incidence of cancer in the general population including the effects of age on the incidence of cancer, incidence of cancer among aluminum workers, and heredity as a factor in the development of cancer. Dr. Morgan may testify about the development of this knowledge historically. Dr. Morgan may testify concerning the principles employed in determining the causes and contributing factors of individual cancers and other diseases. Dr. Morgan will apply these principles to Plaintiffs medical conditions. Dr. Morgan may testify concerning the science of epidemiology, the appropriate use of epidemiology in addressing causal issues, the types of studies used in epidemiology to address causal issues, biostatistical aspects of epidemiologic investigations and the criteria used to interpret epidemiological data. Dr. Morgan may testify in depth about the epidemiologic studies addressing the causal association between cigarette smoking, second-hand exposure to cigarette smoking, the increased risk of lung cancer, and the fact that asbestos exposure, in the absence of a confirmed diagnosis of asbestosis, is not causally associated with lung cancer or an increased risk of lung cancer. Dr. Morgan may testify about the relationship between smoking, asbestos and cancer. Dr. Morgan's testimony will be based on his training, experience, education, review of the relevant medical and scientific literature, a review of medical records and deposition transcripts. 8 Gail Stockman, M.D. 701 East Marshall, #502 Longview, TX 75601 Phone: 903-753-0787 Dr. Stockman is a specialist in the area of respiratory diseases. Dr. Stockman will testify as to all matters pertaining to her examination of the plaintiffs' medical records; review of x-rays of the plaintiffs; the diagnostic criteria for asbestos-related disease and the basis of such opinion; the plaintiffs' current medical conditions; her prognosis in regard to the plaintiffs' medical conditions. Dr. Stockman will also testify about the general medical issues with emphasis on the respiratory system and the effect that asbestos and other substances have on human health generally and with respect to plaintiff specifically. Dr. Stockman will also testify concerning those areas described for Drs. Craighead and Ilgren. Dr. Stockman will also provide testimony on state of the art issues concerning the evaluation of medical and scientific knowledge related to asbestos and disease and various work groups. Drew Van Orden R.J. Lee Group, Inc. 350 Hochberg Road Monroeville, PA 15146 Phone: 724-325-1776 Mr. Van Orden is a mineral engineer, materials scientist/microscopist and statistician. He may testify about methods for testing and measuring airborne concentrations of asbestos fibers, the size of respirable fibers, and potential exposure of Alcoa employees to asbestos fibers. He may comment on the work of Dr. Longo. Mr. Van Orden may testify about matters referred to in the designation of Dr. Richard Lee. Mr. Van Orden's testimony will be based on his training, experience, education, review ofthe relevant scientific literature, a review of various documents produced by the parties in discovery, and review of deposition transcripts. Francis W. Weir, Ph.D. 8131 Wycomb Drive Houston, TX 77070 Phone: 281-893-4003 Dr. Weir is an Industrial Hygienist and Toxicologist. Dr. Weir may testify regarding the state of scientific and medical knowledge concerning asbestos during the time periods relevant to this case. His testimony may include, but is not limited to, discussions regarding the respiratory system, asbestos-related diseases and the effect of other substances on the respiratory system. Dr. Weir may give testimony regarding the level of asbestos fibers released at Defendant's facility. He may testify regarding threshold limit values and permissible exposure levels as promulgated by private organizations and government agencies. He may testify as to work practices regarding various types of occupations using products that contained asbestos. He may testify as to the applicability of the Environmental Protection Agency and OSHA guidelines as they relate to various types of occupations. Dr. Weir may assess the potential for Plaintiff to have received a physiologically significant exposure to asbestos fibers released from his alleged interaction with asbestos-containing materials 9 resulting from his work activities at the Alcoa facility in question. Dr. Weir may testify concerning the appreciation, knowledge and understanding by various industries in the United States including aluminum, manufacturing industries regarding the toxicity of and the hazards to their workers from the use of the various asbestos-containing materials utilized in these industries at various times. Dr. Weir may testify concerning the use of asbestos-containing insulation within industry in the twentieth century. Dr. Weir may testify about the early appreciation and understanding of the health and safety issues pertaining to asbestos. Dr. Weir may testify about the differences between the various types of asbestos fibers including serpetines and amphiboles and the different propensity for these fiber types to cause disease. Dr. Weir may testify concerning the relative use of the fiber types both in the United States and abroad. Dr. Weir may discuss the relationship of the various fiber types and their relationship to asbestosis, lung cancer, mesothelioma and other alleged asbestos-related diseases and the understanding of those diseases historically and as reflected in the medical and scientific literature. Dr. Weir may discuss case reports regarding asbestos-related diseases both currently and historically and the medical and scientific significance of such reports. Dr. Weir may discuss the contemporary literature regarding aluminum workers. Dr. Weir's testimony will be based on his training, experience, education, review ofthe relevant medical and scientific literature, a review of the documents produced by the parties during discovery, including Plaintiffs medical records, as well as any inspections of Plaintiffs place of employment. Dr. Weir may testify concerning matters referenced in the designations of Dr. First, Dr. Balzer and Mr. Birkner. II. FACT WITNESSES Jim Archibald 13712 West Robertson Drive Sun City West, AZ 85375 Phone: 913-345-1500 Mr. Archibald began employment with Alcoa in 1952, and retired in 1991. During that time, Mr. Archibald was involved with developing Alcoa's safety programs, policies and procedures. Mr. Archibald may testify about safety programs implemented at Alcoa's Point Comfort facility and throughout the nation. He may testify about the safety statistics of the Point Comfort facility as compared to other Alcoa facilities and as compared to industry generally. In addition to offering factual testimony, Mr. Archibald may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Thomas Bonney 2816 Herron Lane Glenshaw, PA 15116 Phone: 412-487-4877 Mr. Bonney is a retired Alcoa employee. Mr. Bonney began working at Alcoa in 1948 and retired in 1987. Mr. Bonney worked in the Industrial Hygiene department in Pittsburgh. Mr. Bonney is a certified Industrial Hygienist and practiced such profession while an employee of Alcoa. He will express opinions 10 concerning what was known about asbestos related disease in the 1950's, 1960's, 1970's and 1980's and the assumptions made concerning the type of fibers that caused or did not cause disease. Furthermore, he may testify concerning the safety awards and general hygiene practices at Alcoa generally. He will express opinions concerning the implementation of the ACGIH Threshold Limit Value standards and the various governmental regulations. In addition to offering factual testimony, Mr. Bonney may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Boyd Braniff 114 Cedar Ridge Drive Rockport, TX 78382-6825 Phone: 512-987-6180 Mr. Braniff is currently employed at Alcoa's Point Comfort, Texas plant as a Remediation Construction Manager. While Mr. Braniff did not begin his employment at Point Comfort until 1997, he began his tenure with Alcoa in 1968. He has worked at several Alcoa facilities in the United States and abroad. He has worked in construction, engineering, procurement, and was involved in smelter expansion efforts abroad. Mr. Braniff may offer testimony relating to any of his Alcoa positions. Mr. Braniff may offer testimony relating to Alcoa's general polices regarding asbestos removal and Alcoa's efforts to identify substitutes for asbestos-containing materials. Additionally, Mr. Braniff may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Jay Bruggeman 336 Raymaley Rd. Harrison City, PA 15636 Phone: 724-744-0821 Mr. Bruggeman may testify regarding the design of "pots" or "cells" used in Alcoa's smelting operations. In addition to offering factual testimony, Mr. Bruggeman may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. J. J. Congleton 130E Zachary College Station, TX 77843 Phone: 409-845-5574 (Office) 409-690-0737 (Home) 11 Mr. Congleton is a former employee of Alcoa Rockdale. He is educated as an engineer. Mr. Congleton may testify to his knowledge of industrial hygiene and his knowledge of Alcoa's procedure and processes in the potrooms. He may testify concerning the aluminum smelting process generally. He may testify concerning the processes and procedures of other industries in the United States during the relevant times. He may discuss the asbestos abatement program at Alcoa Rockdale and similar facilities owned by Alcoa. He may discuss the medical surveillance program at Alcoa Rockdale and similar facilities owned by Alcoa. During Mr. Congleton's tenure at Alcoa he handled safety discussions and may testify concerning the safety awards received by Alcoa Rockdale, Alcoa corporation generally and Alcoa plants throughout the world. He may testify concerning the communication with the union for employees concerning safety issues. Mr. Congleton may testify concerning the safety statistics and record of Alcoa Rockdale as it is compared to other industries both similar and dissimilar in the United States. He will also testify concerning Alcoa's safety program and its influence on the safety environment in Alcoa facilities. In addition to offering factual testimony, Mr. Congleton may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Joseph Damiano 134 Laurel Wood Drive Pittsburgh, PA 1S237 Phone: 412-364-0394 Mr. Damiano has served in a number of industrial hygiene positions at Alcoa's Corporate Offices in Pittsburgh since 1979. Mr. Damiano may testify about any of his job positions at Alcoa, Alcoa's use or non-use of asbestos containing materials, and safety precautions advised by Alcoa. In addition to offering factual testimony, Mr. Damiano may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Christine C. Dixon-Ernst 1202 Macon Avenue Pittsburgh, PA 15218 Phone: 412-553-3612 Ms. Dixon-Ernst is a current Alcoa employee. She began as an Industrial Hygienist in 1979 and has held the position of Senior Consultant in the area of industrial hygiene since 1984. Ms. Dixon-Ernst may testify based on her experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Alcoa plants generally, by Alcoa's industrial hygienists, and in Alcoa's Safety and Medical Departments. In addition to offering factual testimony, Ms. Dixon-Ernst may offer specialized or expert testimony. It is anticipated that her testimony may include "expert testimony," based on her experience, background and training in the field. Wayne Dunlap Rt. 4, Box 56 Port Lavaca, Texas 77979 Phone: 512-552-9526 12 Mr. Dunlap is a former Alcoa employee. While employed at Alcoa's Point Comfort, Texas facility, he worked as a foreman in the utility area. Mr. Dunlap may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Dunlap may testify regarding Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's pot rooms, in Point Comfort's calcination area, and at Alcoa plants with facilities similar to the ones at which he has worked. He may testify about Alcoa's use and substitution of asbestos containing materials, and safety precautions advised by Alcoa. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background, and training in the field. George Farrah 460 Riverview Drive New Kensington, PA 15068 Phone: 412-337-8700 Mr. Farrah began his employment with Alcoa in 1940 and retired in approximately 1979. Mr. Farrah held several positions including Chairman of the Environmental Health Lab. Mr. Farrah may testify regarding any of his job positions at Alcoa, and safety precautions advised by Alcoa. In addition to offering factual testimony, Mr. Farrah may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Tim Fitzpatrick 1900 Yokley Drive Rockdale, TX 76567 Phone: 412-833-6839 Mr. Fitzpatrick is a current employee at Alcoa Rockdale and is an industrial hygienist. Mr. Fitzpatrick may testify concerning the safety statistics and record of Alcoa Rockdale as it is compared to other industries both similar and dissimilar in the United States. He will also testify concerning their influence on the safety environment in Alcoa facilities. He may testify further regarding the audit standards employed by Alcoa in the self audits found in the various documents produced by Alcoa. He may testify concerning the communication with the union for employees concerning safety issues. Furthermore, he may testify concerning present and past management-union contracts and the labor relations policies and procedures. In addition to offering factual testimony, Mr. Fitzpatrick may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Tom Flores P.O. Box 3022 Port Lavaca, TX 77979 Phone: 512-552-3080 Mr. Flores is a former Alcoa employee. Mr. Flores was employed at Alcoa's Point Comfort, Texas facility from 1955 until his retirement in 1993. During his tenure, he was employed as a chemical engineering technician, an environmental control technician, an environmental control supervisor, a senior technician-RM&A, and a process model technician. 13 Mr. Flores may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Flores may testify concerning the location of asbestos-containing materials at the Point Comfort plant, the handling of asbestos-containing materials, and dust sampling. Mr. Flores also may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, by the Environmental Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Ron Flournoy 215 Willowbend Port Lavaca, Texas 77979 Phone: 512-553-7040 Anna Garrett 885 Evans Road Yoakum, TX 77995-6766 Phone: 512-293-2782 Ms. Garrett is currently employed at Alcoa's Point Comfort, Texas plant as a secretary in the Maintenance Department. Ms. Garrett began her employment at Alcoa in 1970 at Point Comfort. During her tenure at Point Comfort she has worked in various clerical positions as well as unit supervisors in the Chloralkalai and Natural Gas plants and as a maintenance control specialist. Ms. Garrett may offer testimony relating to any of her Alcoa positions. Ms. Garrett may testify based on her experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's Chloralkalai and Natural Gas plants, and at Alcoa plants with facilities similar to Point Comfort. In addition to offering factual testimony, Ms. Garrett may offer specialized or expert testimony. It is anticipated that her testimony may include "expert testimony," based on her experience, background and training in the field. Clois Green 1800 Yokley Rockdale, TX 76567 Phone: 512-446-5472 Mr. Green was an environmental manager for Alcoa Rockdale and is fully knowledgeable of the policies and procedures at Rockdale and Point Comfort. Mr. Green may testify regarding any of his positions at Alcoa, as well as Alcoa's policies and procedures and safety precautions recommended by Alcoa. In addition to offering factual testimony, Mr. Green may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. 14 Dr. Griffin Brookhollow Drive Port Lavaca, TX 77979 Phone: 512-552-5417 Dr. Griffin worked at Alcoa's Point Comfort, Texas plant as a plant physician from approximately the late 1950's until 1960's and for approximately one year in or around 1996. Dr. Griffin may offer testimony relating to his work for Alcoa. Dr. Griffin may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed by Alcoa's Medical Department. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Dwain Holmes 515 Travis Port Lavaca, TX 77979 Phone: 361-552-9097 Mr. Holmes is currently employed at Alcoa's Point Comfort, Texas plant in the Procurement Department. Mr. Holmes has been employed with Alcoa for approximately 30 years. Mr. Holmes has been employed with Alcoa in various capacities within the Engineering, Environmental, Safety, and Calcination Departments. Mr. Holmes may offer testimony relating to any of his Alcoa positions. Mr. Holmes may testify that based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Alcoa's Point Comfort plant generally, by Point Comfort's Industrial Hygiene, Safety, Procurement, Medical, Environmental and Engineering Departments and Alcoa plants Procurement facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field(s). Joe H. Hutchins 701 N. Washington Victoria, Texas 77901 Phone: 512-573-4196 Mr. Hutchins is a former Alcoa employee who was employed at Alcoa's Point Comfort, Texas plant. During his tenure at Point Comfort, which began in the 1960s and ended in the 1990s, he worked in various locations as an engineer including the smelting plant. Mr. Hutchins may offer testimony relating to any of his Alcoa positions. He may offer testimony relating to the location and the potential for exposure to asbestos-containing materials at the smelting plant. He may also testify as to Alcoa's efforts to locate asbestos substitutes and the ventilation system at Point 15 Comfort. Additionally, Mr. Hutchins may testify regarding Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's pot room, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Carl Hudson 2100 Sager Rockdale, TX 76567 Phone: 512-446-5495 Mr. Hudson is currently the Director of Personnel at the Alcoa Rockdale facility. He has had various previous assignments throughout Alcoa. He may testify that Alcoa employees were covered under the appropriate Worker's Compensation statute during the relevant time periods. During Mr. Hudson's tenure at Alcoa he has handled safety discussions and may testify concerning the safety awards received by Alcoa Rockdale, Alcoa corporation generally and Alcoa plants throughout the world. Mr. Hudson may testify concerning the safety statistics and the safety record of Alcoa Rockdale as it is compared to other industries both similar and dissimilar in the United States. He will also testify concerning Alcoa's safety program and its influence on the safety environment in Alcoa facilities. Mr. Hudson may testify concerning Alcoa communications with the union regarding safety issues. Furthermore, he may testify concerning present and past management-union contracts and the labor relations policies and procedures. He may testify further regarding the audit standards employed by Alcoa in the self audits found in the various documents produced by Alcoa. He will also testify concerning the aluminum smelting process generally. Mr. Hudson is involved with Alcoa management discussions concerning the economic viability of any smelter or other Alcoa facility and the comparison of profitability between that plant and others that exist anywhere in the world. Mr. Hudson may testify as to the economic issues admissible in the punitive damages phase (if any) of the trial. He will discuss expenditures on health and safety yearly at the Alcoa Rockdale plant and similar facilities owned by Alcoa. Mr. Hudson will further testify to the involvement of Alcoa Rockdale in the community and Alcoa's contribution to charities and other non profit organizations that benefit the citizens in the area. In addition to offering factual testimony, Mr. Hudson may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Tom Innes 113 Royale Drive Port Lavaca, TX 779779 Phone: 512-552-3172 16 Mr. Innes is a former Alcoa employee. Mr. Innes began his employment with Alcoa in 1968 and retired in 1993. He worked at Point Comfort for two years in Smelter Renovation and worked the balance of his years at Point Comfort as a Procurement Manager. Mr. Innes may offer testimony relating to any of his Alcoa positions. Mr. Innes may testify regarding Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's smelter, in Point Comfort's Procurement Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Robert M. James 1220 Airedale Dr. Bethel Park, PA 15102 Phone: 412-831-0961 Mr. James has served in a number of managerial positions in Health, Safety and Industrial Hygiene at Alcoa's corporate offices in Pittsburgh since 1979. These positions include Staff Industrial Hygienist, Manager, Health Regulatory Affairs, Manager, Health and Safety, CMPLC and Services; and, currently, Manager, Industrial Hygiene and Toxicology. Mr. James may testify regarding any of his positions at Alcoa. In addition to offering factual testimony, Mr. James may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Katie Johnson 222 Suncrest Port Lavaca, TX 77979 Phone: (512)552-2867 Ms. Johnson is a former Alcoa employee. Ms. Johnson was employed at Alcoa's Point Comfort, Texas facility from 1954 until her retirement in 1994. During her tenure, she was employed as a typist, secretary, and stores buyer. Ms. Johnson may offer testimony relating to any of her Alcoa positions. Ms. Johnson may testify based on her experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, by the Stores and Purchasing Departments, and at Alcoa plants with facilities similar to ones at which she has worked. Mrs. Johnson may testify regarding Alcoa's efforts to locate substitutes for asbestos containing materials. In addition to offering factual testimony, she may offer specialized or expert testimony. It is anticipated that her testimony may include "expert testimony," based on her experience, background and training in the field. Norman Jones Box 212 Ganado, TX 77962 17 Phone: 512-771-2627 Mr. Jones is a current Alcoa employee. Mr. Jones has been employed at Alcoa's Point Comfort, Texas facility since 1968. He has been employed in the security department since 1969 and also worked in casting, potrooms, civil maintenance, and utilities. Mr. Jones may offer testimony relating to any of his Alcoa positions. Mr. Jones may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Jerry Karl P.O. 603 Edan, TX 77957 Phone: 512-782-6418 Mr. Karl is a retired Alcoa employee and began his Alcoa career in 1964. He held a variety of positions including Potroom Line Foreman from 1969-1975, Potroom Technician from 1975-1979 and Potroom Supervisor from 1979-1981. Mr. Karl also worked as a Supervisor in the Paste and Carbon Plans prior to his retirement in 1997. Mr. Karl may offer testimony relating to any of his Alcoa positions. Mr. Karl may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's pot room, in Point Comfort's Carbon plant, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Kerry Keller 1920 Jackson Port Lavaca, TX 77979 Phone: 512-552-2351 Mr. Keller is a former Alcoa employee. He began his employment at Alcoa's Point Comfort, Texas plant in 1959 and retired in 1998. During his tenure with Alcoa he was employed as a maintenance supervisor, a general mechanic, a supervisor in safety and clarification, and worked in the Safety & Industrial Hygiene Department. Mr. Keller may offer testimony relating to any of his Alcoa positions. Mr. Keller may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's Maintenance Department, in Point Comfort's Clarification Department, in Point Comfort's Safety and 18 Industrial Hygiene Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. William Kimpel 47 Kramer Place Mandeville, LA 70471 Phone: 504-727-4675 Mr. Kimpel is a former employee at Alcoa's Point Comfort, Texas plant. Mr. Kimpel began his employment with Alcoa in 1977 at Alcoa's Bauxite, Arkansas plant. During his employment with Alcoa, Mr. Kimpel has also worked in the Calcination and Clarification Departments, worked as an Engineering Supervisor, and as a Procurement Manager. Mr. Kimpel may offer testimony relating to any of his Alcoa positions. Mr. Kimpel may testify based on his experience and training concerning Alcoa's general policies and procedures and concerning policies and procedures followed at Point Comfort generally, in Point Comfort's Procurement Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Gus Klekar Route 1 Box 489C Rockdale, TX 76567 Phone: 512-446-3092 Mr. Klekar began his employment with Alcoa in 1966 as a production helper. He served in various positions including potlining foreman and supervisor of the potroom. Mr. Klekar retired in 1997. Mr. Klekar may testify regarding any of his positions at Alcoa, Alcoa's policies and procedures and safety precautions recommended by Alcoa. In addition to offering factual testimony, Mr. Klekar may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Richard Klimatchek Ezzel Road Hallettsville, TX 77964 Phone: 512-798-2448 Mr. Klimatcheck is a former Alcoa employee. Mr. Klimatcheck began his employment at Alcoa's Point Comfort, Texas facility in 1953 and retired in 1983. During his tenure at Point Comfort Mr. Klimatcheck worked as a pot tender in the pot room, a line supervisor in the pot room, a foreman in the utility department, and also worked with temperature control and in the refinery. 19 Mr. Klimatcheck may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Klimatcheck may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's pot room, smelter, or refinery, in Point Comfort's Utility Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Norman V. Lubbers 17 Argomaniz Way Hot Springs Village, AR 71909 Phone: 512-578-6678 Mr. Lubbers is a former Alcoa employee. Mr. Lubbers began his employment at Alcoa in 1953 and retired in 1996. He first worked as a Chemical Engineer at Alcoa's East St. Louis plant in 1953. In 1960 he began work at Alcoa's Point Comfort, Texas plant and has served as a Staff Chemical Engineer, a Production Engineer (Fluoride Plant), Production Superintendent (Fluoride Plant), and a Technical Superintendent at this facility. From 1970 until 1974, he also worked at Alcoa's Fort Meade plant as Production Superintendent in the Aluminum Fluoride Plant. Mr. Lubbers may offer testimony relating to any of his Alcoa positions. More specifically, Mr. Lubbers may offer testimony regarding the infrequent handling of asbestos-containing materials in the Fluoride plant at the Point Comfort facility. Mr. Lubbers may testify regarding Alcoa's safety meetings generally. Mr. Lubbers may also testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's Fluoride plant, in Point Comfort's Production Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Frank Mabry 95 Houston Street Port Lavaca, TX 77979 Phone: 512-552-9047 Mr. Mabry is a former Alcoa employee. Mr. Mabry began his employment at Alcoa in 1943 and retired in 1983. He first worked at Alcoa's East St. Louis plant in 1943. In 1961 he began work at Alcoa's Point Comfort, Texas plant and has served as an Assistant Superintendent Electrolyte (Fluoride) Plant, Superintendent (Alumina Plant), Product Manager (Alumina), Product Superintendent (Alumina), and worked in the Environmental Department. From 1969 until 1972 he also worked at Alcoa's Jamaica plant as a Manager (Chemicals). Mr. Mabry may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Mabry may testify regarding Alcoa's safety program and policies regarding the use of respirators. Mr. 20 Mabry may also testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant general!}', in Point Comfort's Environmental Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Manville Trust P.O. Box 426 Marrifield, VA 22116-0426 Phone: 703-204-2300 John Mayfield 117 Bloomingdale Circle Victoria, TX 77904 Phone: 512-574-9955 Mr. Mayfield is currently employed at Alcoa's Point Comfort, Texas plant as the Director of the Environmental Group. Mr. Mayfield began his tenure at Point Comfort in 1971 as a staff chemist. As a staff chemist he worked throughout the Point Comfort plant. As of 1978, Mr. Mayfield became the Operations Environmental Control Superintendent and held similar positions until 1995. Mr. Mayfield is currently the Environmental Manager for Point Comfort Operations. Mr. Mayfield may offer testimony relating to any of his Alcoa positions. Mr. Mayfield may offer testimony relating to Alcoa's general polices regarding asbestos removal and the handling of asbestos-containing materials, the location of asbestos-containing materials at Point Comfort, and Alcoa's efforts to identify substitutes for asbestos-containing materials. Additionally, Mr. Mayfield may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Point Comfort, in Point Comfort's Environmental Department, Safety Department, or Medical Department, and at Alcoa plants with facilities similar to Point Comfort. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Daniel Nelsen 15 Jade Drive Victoria, TX 77904 Phone: 512-576-5413 Mr. Nelsen is a former Alcoa employee. Mr. Nelsen began his employment with Alcoa in 1949 and retired in 1985. He began his employment at Alcoa's Point Comfort, Texas facility as a technical apprentice in the metallurgical department and later became a pot repair room superintendent. Mr. Nelsen worked at Point Comfort until 1963. During his tenure at Point Comfort Mr. Nelsen also worked in Point Comfort's casting department, pot rooms, and production department. 21 Mr. Nelsen may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Nelsen may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Point Comfort generally, in Point Comfort's pot rooms, in Point Comfort's casting and production departments, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Larry Onken 202 W. Larkspur Victoria, TX 77904 Phone: 512-576-0126 Mr. Onken is a former Alcoa employee. Mr. Onken was employed at Alcoa's Point Comfort, Texas plant from 1965 through his retirement in 1996. During his tenure at Point Comfort, Mr. Onken was employed as a lab assistant, an engineering technician (in both the engineering and environmental departments), and worked in the Environmental Department. Mr. Onken may offer testimony relating to any of his Alcoa positions. Mr. Onken may offer testimony relating to asbestos abatement and dust sampling at Point Comfort. Additionally, Mr. Onken may also testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's Environmental Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Jon N. Peace 122 Chris Drive RD #11 Irwin, PA 15642-9119 Phone: 724-744-4691 Mr. Peace is currently employed at Alcoa's headquarters in Pittsburgh, Pennsylvania as a Senior Staff-Industrial Hygiene. He has been employed by Alcoa since 1981 and has worked also as a chemist and a technical supervisor-industrial hygiene. Mr. Peace may offer testimony relating to any of his Alcoa positions. Mr. Peace may testify based on his experience and training concerning Alcoa's general policies and procedures and Alcoa's industrial hygiene policies and procedures. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. 22 Nancy Peikert 601 Sunnydale Port Lavaca, TX 77979 Phone: 512-987-6209 Ms. Peikert is currently employed at Alcoa's Point Comfort, Texas plant as a registered industrial nurse. She has been so employed since 1975. Ms. Peikert may offer testimony relating to any of her Alcoa positions. Ms. Peikert may testify based on her experience and training concerning Alcoa's medical surveillance program, Alcoa's general policies and procedures and the policies and procedures followed at Point Comfort generally, in Point Comfort's Medical Department, and at Alcoa plants with facilities similar to Point Comfort. In addition to offering factual testimony, she may offer specialized or expert testimony. It is anticipated that her testimony may include "expert testimony," based on her experience, background and training in the field. Ken Peterson HC2 Box 380 Palacios, TX 77465 Phone: 512-972-2906 Mr. Peterson is a former Alcoa employee. Mr. Peterson began his employment at Alcoa's Point Comfort, Texas facility in 1949 and retired in 1983. During his tenure at Point Comfort Mr. Peterson worked as a paste plant technician, a paste plant foreman, a pot repair foreman, and a line supervisor. Mr. Peterson may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Peterson may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's pot room, in Point Comfort's paste plant, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Leslie A. Pfeil 11 Pecan Drive Port Lavaca, TX 77979-5614 Phone: 512-552-3839 Mr. Pfeil is a former Alcoa employee. Mr. Pfeil began his employment at Alcoa in 1956 and retired in 1988. During his tenure with Alcoa, Mr. Pfeil was employed as a buyer stores administrator. Mr. Pfeil may offer testimony relating to any of his Alcoa positions. Mr. Pfeil may testify regarding Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in the Purchasing/Stores Department, and at Alcoa plants with facilities 23 similar to ones at which he has worked. Mr. Pfeil may testify regarding Alcoa's efforts to locate substitutes for asbestos containing materials. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Raleigh Prince 101 Tern Court Victoria, TX 77901 Phone: 361-572-8541 Mr. Prince is a current Alcoa employee. Mr. Prince has been employed at Alcoa's Point Comfort, Texas facility since 1974. During his tenure, he has held many job titles including drafting, smelting process technician, plant messenger, laboratory assistant, and environmental technician. He is the current Senior Environmental Technician at Point Comfort. Mr. Prince may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Prince may testify concerning the location of asbestos-containing materials at the Point Comfort plant and the handling of asbestos-containing materials. Mr. Prince also may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, by the Environmental Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Al Rambikur P.O. Box 507 Point Comfort, TX 77978 Phone: 512-987-2821 Mr. Rambikur is a former Alcoa employee. Mr. Rambikur began his employment at Alcoa in 1942 and worked at Alcoa's Point Comfort, Texas facility from 1963 until his retirement in 1978. While at Point Comfort, Mr. Rambikur worked in the smelting and metallurgical divisions and later oversaw the Environmental Department. Mr. Rambikur may offer testimony relating to any of his Alcoa positions. Mr. Rambikur may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Point Comfort, in Point Comfort's pot room, in Point Comfort's smelting and metallurgical divisions, in Point Comfort's Environmental Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. 24 John Ramos 105 Oak Colony Victoria, TX 77904 Phone: 361-578-0948 Mr. Ramos is currently employed at Alcoa's Point Comfort, Texas plant as the Refining Manager. Mr. Ramos has been employed with Alcoa in various capacities within the refining and engineering departments at the Point Comfort plant. Mr. Ramos may offer testimony relating to any of his Alcoa positions. Mr. Ramos may testify that based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Alcoa's Point Comfort plant generally, by Point Comfort's Industrial Hygiene, Safety, Medical, Environmental and Engineering Departments and Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field(s). Records Custodian Alcoa Wenatchee Works 6200 Malaga Highway Malaga, WA 98828-9728 Phone: 509-663-9227 This individual may testify as to Alcoa's document retention policy at this plant and authenticate any documents Alcoa offers at the trial of this matter. Records Custodian Alcoa Warrick Operations Highway 66 Newburgh, IN 47629 Phone: 812-853-6111 This individual may testify as to Alcoa's document retention policy at this plant and authenticate any documents Alcoa offers at the trial ofthis matter. Records Custodian Alcoa Badin Works Highway 740 Badin, NC 28009 Phone: 704-422-3621 This individual may testify as to Alcoa's document retention policy at this plant and authenticate any documents Alcoa offers at the trial of this matter. Records Custodian Alcoa Corporate Offices 201 Isabella Street 25 Pittsburgh, PA 15212 Phone: 412-553-4545 This individual may testify as to Alcoa's document retention policy at this plant and authenticate any documents Alcoa offers at the trial of this matter. Records Custodian Alcoa Point Comfort Operations State Highway 35 Point Comfort, TX 77978 Phone: 512-987-6180 This individual may testify as to Alcoa's document retention policy at this plant and authenticate any documents Alcoa offers at the trial of this matter. Records Custodian Alcoa Rockdale Operations Five Miles South of Intersection on State Highway 79 and Farm to Market Road Rockdale, TX 76567 Phone: 512-446-8423 This individual may testify as to Alcoa's document retention policy at this plant and authenticate any documents Alcoa offers at the trial of this matter. Records Custodian Alcoa Technical Center 7th Street Road Route 780 Alcoa Center, PA 15069 Phone: 412-339-6651 This individual may testify as to Alcoa's document retention policy at this plant and authenticate any documents Alcoa offers at the trial of this matter. Records Custodian Alcoa Tennessee Operations 1100 East Hunt Road Alcoa, TN 37701 Phone: 423-977-2011 This individual may testify as to Alcoa's document retention policy at this plant and authenticate any documents Alcoa offers at the trial of this matter. Records Custodian Massena Operations Park Avenue East Massena, NY 13662 26 Phone: 315-764-4011 This individual may testify as to Alcoa's document retention policy at this plant and authenticate any documents Alcoa offers at the trial of this matter. Hilda G. Rendon 535 W. Main Port Lavaca, TX 77979 Phone: 512-552-7376 Ms. Rendon was employed as a nurse at Alcoa's Point Comfort, Texas plant from 1967 until 1973. Ms. Rendon may offer testimony relating to any of her Alcoa positions. Ms. Rendon may testify based on her experience and training concerning Alcoa's medical surveillance program, Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's Medical Department, and at Alcoa plants with facilities similar to Point Comfort. In addition to offering factual testimony, she may offer specialized or expert testimony. It is anticipated that her testimony may include "expert testimony," based on her experience, background and training in the field. Denise Richardson 2004 Justice Drive Port Lavaca, TX 77979 Phone: 512-552-5168 Ms. Richardson is a former Alcoa employee and was employed as a Staff Industrial Hygienist at Point Comfort Operations from 1992 until 1999. Ms. Richardson may offer testimony relating to any of her Alcoa positions. Ms. Richardson may offer testimony relating to the location of asbestos-containing materials at Point Comfort and dust level count sampling conducted at Point Comfort. Additionally, Ms. Richardson may testify based on her experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Point Comfort generally, by Point Comfort's industrial hygienists, in Point Comfort's Safety and Medical Departments, and at Alcoa plants with facilities similar to Point Comfort. In addition to offering factual testimony, she may offer specialized or expert testimony. It is anticipated that her testimony may include "expert testimony," based on her experience, background and training in the field. Richard Ripley 109 Chantilly Port Lavaca, TX 77979 Phone: 512-552-1775 27 Mr. Ripley is currently employed at Alcoa's Point Comfort, Texas plant as a Construction Superintendent. Mr. Ripley began his employment at Point Comfort in 1967 as an engineer in Smelting, from 1980 until 1981 he was employed as a Safety Manager, and since 1981 has worked as an engineer. From 1969 through 1978, Mr. Ripley was employed at Alcoa's Massena plant. Mr. Ripley may offer testimony relating to any of his Alcoa positions. Mr. Ripley may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's smelter, in Point Comfort's Safety Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, Mr. Ripley may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Jerry Roddy 11904 Longstreet Place Knoxville, TN 37922 Phone: 423-675-4472 Mr. Roddy is a technical manager for Alcoa Primary Metals at the Knoxville Headquarters. He served as a potroom superintendent at Alcoa Rockdale and was assigned at the Pittsburgh Headquarters to develop and implement CORE safety training. He may testify concerning the aluminum smelting process generally. He is trained and educated as an engineer and may testify concerning engineering issues at the Alcoa facilities. In his tenure at Alcoa Rockdale he handled safety discussions and may testify concerning the safety awards received by Alcoa Rockdale, Alcoa corporation generally, and Alcoa plants throughout the world. He may testify concerning the communication with the union for employees concerning safety issues. Mr. Roddy may testify concerning the safety statistics and record of Alcoa Rockdale as it is compared to other industries both similar and dissimilar in the United States. Furthermore, he may testify concerning present and past management-union contracts and the labor relations policies and procedures. He will also testify concerning the CORE program and its influence on the safety environment in Alcoa facilities. He may testify further regarding the audit standards employed by Alcoa in the self audits found in the various documents produced by Alcoa. He will discuss the capital expenditure on health and safety yearly at the Alcoa Rockdale plant and similar facilities owned by Alcoa. In addition to offering factual testimony, Mr. Roddy may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Lee Ross, Jr. 609 Mallette Drive Victoria, Texas 77904 Phone: 512-575-7369 Mr. Ross is a current Alcoa employee. Mr. Ross began his employment at Alcoa's Point Comfort, Texas facility in 1967. Mr. Ross has been employed at Point Comfort in the pot rooms in various positions, as well as in the laboratory, the maintenance department, and in stores. 28 Mr. Ross may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Ross may testify regarding Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, Point Comfort's pot rooms. Point Comfort's calcination area, by the Maintenance Department, and at Alcoa plants with facilities similar to the ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background, and training in the field. Haig Sakoian 1061 Regent Circle Maryville, Tennessee 37803 Phone: 615-977-4244 Mr. Sakoian is currently employed at Alcoa's headquarters in Pittsburgh, Pennsylvania. During his tenure with Alcoa, he has been employed as an industrial hygienist, a manager-safety and environmental health, and a director-EHS Audit. Mr. Sakoian may offer testimony relating to any of his Alcoa positions. Mr. Sakoian may testify based on his experience and training concerning Alcoa's general policies and procedures, Alcoa's industrial hygiene policies and procedures, and Alcoa's safety and environmental policies and procedures. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Gene Sampson 209 Sunnydale Port Lavaca, Texas 77979 Phone: 512-552-3608 Mr. Sampson is a former Alcoa employee. Mr. Sampson was employed Alcoa's Point Comfort, Texas facility. His last job at Point Comfort was a supervisor in calcination. Mr. Sampson may offer testimony relating to any of his positions at Alcoa. Mr. Sampson may offer testimony relating to substitutes for asbestos containing materials and the use of respirators. Additionally, he may testify regarding Alcoa's general policies and procedures and policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's calcination area, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background, and training in the field. Ray W. Sauer, Jr. 1520 Sequoia Drive Pittsburgh, PA 15241-3224 29 Phone: 412-221-2925 Mr. Sauer is a retired Alcoa employee who began working for Alcoa in August 1958. He was formerly employed as Manager, Product Safety and Reliability. Mr. Sauer may testify regarding Alcoa's sales of various aluminum products, including what products were sold and how they were used. In addition to offering factual testimony, Mr. Sauer may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Laird F. Schaller, M.D. 1553 Tree Farm Drive Plano, TX 75093 Phone: 972-248-4810 Dr. Schaller was employed at Alcoa's Point Comfort, Texas plant as a plant physician from approximately the late 1970's until the early 1980's. Dr. Schaller may offer testimony relating to his work for Alcoa. Dr. Schaller may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed by Alcoa's Medical Department. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Irene Scheffler 2030 Emerald Ridge Drive Lakeland, FL 33813 Phone: 863-285-8101 Ms. Scheffler is currently employed at Alcoa's Ft. Meade, Florida plant as Plant Manager. Ms. Scheffler has been employed with Alcoa since 1978 in various capacities within the Safety, Industrial Hygiene, and Production Departments. Ms. Scheffler was the safety engineer at the Point Comfort Plant from 1978 until March 1984. She then worked at the Alcoa Bauxite, Arkansas plant in the safety and industrial hygiene departments. At her current location at the Alcoa plant in Ft. Meade, Florida, she served as the production manager and is the current plant manager. Ms. Scheffler may offer testimony relating to any of her Alcoa positions. Ms. Scheffler may testify that based on her experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Alcoa's Point Comfort plant generally, by Point Comfort's Industrial Hygiene, Safety, Medical, Environmental and Engineering Departments and Alcoa plants with facilities similar to ones at which she has worked. In addition to offering factual testimony, she may offer specialized or expert testimony. It is anticipated that her testimony may include "expert testimony," based on her experience, background and training in the field(s). 30 Claude Scott 515 Rattan Drive Victoria, TX 77901 Phone: 512-575-8520 Mr. Scott is a former Alcoa employee. Mr. Scott began his employment at Alcoa in 1952 and retired in 1984. He first worked as an Industrial Engineer at Alcoa's Mobile plant. In 1955 he became a Superintendent of Labor Relations at the Mobile plant. In 1961 he became employed as the Personnel Manager at Alcoa's Bauxite, Arkansas plant. In 1968, he became the Personnel Superintendent at Alcoa's Point Comfort, Texas plant. Mr. Scott remained at the Point Comfort plant until his retirement in 1984. While at Point Comfort he also worked in the Safety Department and was employed as an Industrial Engineer. Mr. Scott may offer testimony relating to any of his Alcoa positions. Mr. Scott may offer further testimony as to the location of asbestos-containing materials at Alcoa's Point Comfort plant and Point Comfort's efforts to monitor dust levels. Additionally, Mr. Scott may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Point Comfort, in Point Comfort's potroom, in Point Comfort's Safety Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. D. Ray Scott 105 Willowbend Drive Port Lavaca, TX 77979 Phone: 361-552-6069 Mr. Scott is the current Safety & Industrial Hygiene Manager at Alcoa's Point Comfort, Texas facility. He has been employed at Alcoa since 1980. He began his employment at Alcoa's Anderson County Works plant and also worked at Alcoa's Rockdale, Texas plant, Massena, New York plant, and the Alcoa Technical Center in Pittsburgh, Pennsylvania. Mr. Scott may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Scott may testify concerning the location of asbestos-containing materials at the Point Comfort plant and the handling of asbestos-containing materials. Mr. Scott also may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, by the Safety and Industrial Hygiene Departments, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Janie Sendejo P.O. Box 1303 Port Lavaca, TX 77979 Phone: 512-552-4661 31 Ms. Sendejo is currently employed as a nurse at Alcoa's Point Comfort, Texas plant. She has previously held the positions of First Aid Attendant and Medical Technician. Ms. Sendejo may offer testimony relating to any of her Alcoa positions. Ms. Sendejo may testify based on her experience and training concerning Alcoa's medical surveillance program, Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's Medical Department, and at Alcoa plants with facilities similar to ones at which she has worked. In addition to offering factual testimony, she may offer specialized or expert testimony. It is anticipated that her testimony may include "expert testimony," based on her experience, background and training in the field. Robert Sharkey 123 Heather Drive Pittsburgh, PA 15209 Phone: 412-821-1241 Mr. Sharkey was employed as Senior Corporate Safety Engineer at Alcoa from November 1973 to December 1993. During that time, Mr. Sharkey was involved with developing Alcoa's safety programs, policies and procedures. Mr. Sharkey may testify about safety programs implemented at Alcoa's Point Comfort facility and throughout the nation. He may testify about the safety statistics of the Point Comfort facility as compared to other Alcoa facilities and as compared to industry generally. In addition to offering factual testimony, Mr. Sharkey may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Bobby Sheppard 725 Gilbert Road Edna, TX 77957 Phone: 512-987-2719 Mr. Sheppard is a former Alcoa employee. Mr. Sheppard began his employment at Alcoa in 1950 and retired in 1990, although he actually stopped working in 1988. In 1950, he began his tenure at Alcoa's Point Comfort, Texas plant in the Medical Department. From 1951 until 1955, he served in the United States Navy. In 1957, after receiving training as an X-ray technician, he returned to Point Comfort as a Technician in the Medical Department and later worked at Point Comfort in Security (Fire protection). Mr. Sheppard may offer testimony relating to any of his Alcoa positions. Mr. Sheppard may testify regarding Alcoa's medical department including the completion of annual employee physical examinations. Additionally, Mr. Sheppard may testify regarding Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's medical department, in Point Comfort's safety department, and at Alcoa plants with facilities similar to ones at which he has worked. 32 In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Jeff Shockey AFL/Dixiewire 5901 California Ave. P.O. Box 90208 Nashville, TN 37209-0208 Phone: 615-376-9892 Mr. Shockey is a current Alcoa employee. Mr. Shockey was employed at Alcoa's Point Comfort, Texas facility from 1980 until 1988. In 1988, Mr. Shockey transferred to Alcoa's headquarters in Pittsburgh, Pennsylvania. During his tenure at Point Comfort, he was employed as a safety engineer and a manager in Safety & Hygiene. Mr. Shockey may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Shockey may testify concerning the location of asbestos-containing materials at the Point Comfort plant and the handling of asbestos-containing materials. He also may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, by the Safety Department, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Harvey Skow Box 119 Point Comfort, TX 77978 Phone: 512-987-2792 Mr. Skow is currently employed at Alcoa's Point Comfort, Texas plant as an Unit Supervisor of painters and insulators. He has worked at the Point Comfort facility since 1960. During this time he has also been employed as a painter apprentice and a painter. Mr. Skow may offer testimony relating to any of his Alcoa positions. Mr. Skow may further testify as to the location of asbestos-containing materials and the use of respirators. Additionally, Mr. Skow may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Alcoa's Point Comfort plant generally and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Robert Trevino 201 Woodchase Drive 33 Victoria, Texas 77904 Phone: 512-573-0464 Mr. Trevino is a current Alcoa employee. Mr. Trevino began his employment at Alcoa's Point Comfort, Texas facility in 1966. He has been employed at Point Comfort in the pot room, Safety Department, and in calcination. Mr. Trevino may offer testimony relating to any of his Alcoa positions. Additionally, Mr. Trevino may testify regarding Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally, in Point Comfort's pot rooms, in Point Comfort's calcination area, by Point Comfort's Safety Department, and at Alcoa plants with facilities similar to the ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background, and training in the field. John Vasquez 306 Bioomingdale Circle Victoria, TX 77904 Phone: 512-575-8147 Mr. Vasquez is currently employed at Alcoa's Point Comfort, Texas plant as the Personnel and Public Relations Manager. Mr. Vasquez has been employed with Alcoa since 1973 and has been employed as a mechanical engineer, a personnel administrator, and an industrial relations supervisors. Mr. Vasquez may offer testimony relating to any of his Alcoa positions. Mr. Vasquez may testify that Alcoa employees were covered under the appropriate Worker's Compensation statute during the relevant time periods. Additionally, Mr. Vasquez may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Alcoa's Point Comfort plant generally, by Point Comfort's Industrial Hygiene Department, in Alcoa's Safety and Medical Departments, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Leroy Wagner P.O. Box 96 Westhoff, TX 77994 Phone: 830-236-5882 Mr. Wagner is currently employed at Alcoa's Point Comfort, Texas plant as an industrial hygienist. In 1969 he joined the Industrial Hygiene Department at Point Comfort. Mr. Wagner may offer testimony relating to any of his Alcoa positions. Mr. Wagner may further testify as to the location of asbestos-containing materials at Point Comfort, dust sampling 34 conducted at Point Comfort, training sessions and safety meetings conducted at Point Comfort, and Alcoa's regulations relating to the handling of asbestos-containing materials. Additionally, Mr. Wagner may testify based on his experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed at Alcoa's Point Comfort plant generally, by Point Comfort's Industrial Hygiene Department, in by Alcoa's Safety Department and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Thomas Washam, M.D. P.O. Box 69 Vinton, OH 45686 Phone: 740-388-8248 Dr. Washam served as the Texas area medical director for Alcoa beginning in 1981. Dr. Washam retired in 1996. In addition to offering factual testimony. Dr. Washam may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Doris Welch 518 Willowwick Port Lavaca, TX 77979 Phone: 512-987-6206 Ms. Welch is currently employed as an administrative assistant at Alcoa's Point Comfort, Texas plant where she has been employed since 1949. Ms. Welch may offer testimony relating to any of her Alcoa positions. Ms. Welch may testify based on her experience and training concerning Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort plant generally and at Alcoa plants with facilities similar to ones at which she has worked. In addition to offering factual testimony, she may offer specialized or expert testimony. It is anticipated that her testimony may include "expert testimony," based on her experience, background and training in the field. Curtis Wofford 315 Robinson Street Lolita, Texas 77971 Phone: 512-874-4277 Mr. Wofford is a former Alcoa employee. Mr. Wofford began working at Alcoa's Point Comfort, Texas facility in 1949. He initially worked in the utility department and then shortly after that began his career in the pot room. 35 Mr. Wofford may offer testimony relating to any of his Alcoa positions. Mr. Wofford may offer testimony concerning the process and the various jobs performed in the pot room. He may offer testimony relating to substitutes for asbestos containing materials and the use of respirators. Additionally, Mr. Wofford may testify regarding Alcoa's general policies and procedures and the policies and procedures followed in Alcoa's Point Comfort pot room, at the plant generally, and at Alcoa plants with facilities similar to ones at which he has worked. In addition to offering factual testimony, he may offer specialized or expert testimony. It is anticipated that his testimony may include "expert testimony," based on his experience, background, and training in the field. All witnesses named by any other party in this action, even if the plaintiff or defendant naming that witness is no longer a party to this lawsuit at the time of trial. All witnesses deposed or to be deposed by any party in this action, even if the plaintiff or defendant deposing that witness is no longer a party to this lawsuit at the time of trial. All doctors and other health care professionals who have treated or examined plaintiff or Plaintiff. Records Custodians as may be necessary to authenticate documents to be used by Alcoa at trial. 36 Exhibit # Date George Joseph Dolezal, et al. v. Owens Corning, et al. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates Ending Bates 1 00-00-00 BROCHURE RE: WHAT EVERY EMPLOYEE SHOULD KNOW C35793 0750 C35793 0761 ABOUT ASBESTOS AND WHAT YOU SHOULD TELL OTHERS 2 00-00-00 REPORT RE: FACTS ON ASBESTOS BY THE ASBESTOS ARCH002348 ARCH002371 INSTITUTE 3 00-00-63 DUSTS, FUMES, AND MISTS IN INDUSTRY; DATA SHEET 409972 0776 409972 0790 131 REVISION A (TABLES II, III AND BIBLIOGRAPHY) 4 00-00-00 MECHANICAL PACKINGS AND GASKETING MATERIALS APC2 31432 APC2 31447 08-21-80 CONTAINING ASBESTOS FIBER 5 02-26-52 MEMO RE: INDUSTRIAL HYGIENE 409680 0137 409680 0139 6 04-05-56 MEMO RE: INDUSTRIAL HYGIENE; APPROVED MATERIALS 409680 0134 409680 0134 FOR PLANT USE / 01-09-63 IOC RE: INDUSTRIAL HYGIENE TRAINING AND WORKS 412594 0006 412594 0013 01-08-63 INDUSTRIAL HYGIENE PROGRAM 8 07-07-64 MEMO RE: ENCLOSED ARE ARTICLES ON EFFECT OF ARD042663 ARD042663 CARCINOGENIC PROPERTIES OF ELECTRODE MATERIAL USED IN ALUMINUM INDUSTRY; NO ENCLOSURES 9 09-25-64 LETTER RE: INDUSTRIAL HYGIENE NEWSLETTER FOR ARCH002115 ARCH002117 SEPTEMBER 25, 1964 RE: MARINITE 10 02-29-68 LETTER RE: VARIETIES OF ASBESTOS ASSOCIATED WITH ARCH18740 ARCH18740 OCCURENCE OF CANCER IN HUMANS 11 09-08-71 MEMO RE: OCCUPATIONAL HEALTH AND SAFETY ACT OF 411582 0099 411582 0102 09-03-71 1970 12 10-06-71 MEMO RE: OCCUPATIONAL SAFETY AND HEALTH ACT - 411582 0097 411582 0098 DECISION TREE Exhibit # Date 13 12-23-71 12-07-71 George Joseph Doiezal, et al. v. Owens Corning, et al. Cause No. 98-748-A Description Exhibit List of Alcoa Inc. Beginning Bates Ending Bates MEMO RE: EMERGENCY STANDARD FOR EXPOSURE TO ASBESTOS DUST; ENCLOSES INSULATION HYGIENE PROGRESS REPORTS RE: RECOMMENDATIONS FOR MINIMIZING AND PREVENTING ASBESTOS DUST FROM BECOMING AIRBORNE; ALSO INCLUDES FEDERAL REGISTER REGULATIONS FOR CONSTRUCTION APC004530 APC004537 14 01-27-72 TELEGRAM RE: DOCUMENTATION FOR HEAT C35794 2945 C35794 2945 TREATMENT FOR MARINITE, WHICH CONTAINS 50% ASBESTOS, TO REDUCE TOXICITY SIGNIFICANTLY 15 04-17-72 MEMO RE: INDUSTRIAL HYGIENE NEWSLETTER - APC001215 APC001228 01-12-72 ASBESTOS DUST EXPOSURES, WITH ATTACHED FEDERAL REGISTER CODE, STANDARD FOR ASBESTOS DUST, REPORT RE: MEASUREMENT OF ASBESTOS FIBERS, AND OSHA SAMPLING DATA SHEETS FOR FIVE TOXIC SUBSTANCES RELEASED 16 05-16-72 LETTER RE: LOCKED IN AND NON-LOCKED IN ASBESTOS 411596 0311 411596 0316 03-24-72 CONTAINING PRODUCTS 17 07-01-72 MEMO RE: OSHA STANDARD FOR EXPOSURE TO APC001207 APC001214 06-07-72 ASBESTOS DUST, WITH FEDERAL REGISTER OSHA STANDARD FOR EXPOSURE TO ASBESTOS DUST 18 07-20-72 MEMO RE: APPROVED ASBESTOS RESPIRATORY PROTECTION; INCLUDES A LIST OF RESPIRATORS APPROVED BY THE U.S. BUREAU OF MINES ARD007015 ARD007016 19 08-07-72 MEMO RE: ELIMINATION OF ASBESTOS FROM 411084 1790 411084 1792 INSULATION PRODUCTS; INCLUDES HANDWRITTEN NOTE RE: FIBER GLASS AS USAGE OVEN SPACERS 20 08-21-72 MEMO RE: ASBESTOS CONTAINING REFRACTORY AND ARCH002259 ARCH002260 INSULATING MATERIALS USED IN FURNACE AND CASTING EQUIPMENT CONSTRUCTION 21 10-04-72 MEMO RE: NATIONAL PURCHASE AGREEMENT P-615951, APC001543 APC001545 JOHNS-MANVILLE SUPEREX INSULATION BLOCK 22 01-22-73 MEMO RE: RULES AND REGULATIONS FOR EXPOSURE TO ARCH004406 ARCH004410 10-18-72 ASBESTOS DUST, WITH ATTACHED FEDERAL REGISTER ASBESTOS REGULATIONS Exhibit # Date 23 02-05-73 01-29-73 12-23-71 04-17-72 01-12-72 07-01-72 06-07-72 07-20-72 08-21-72 10-04-72 George Joseph Dolezal, et al. v. Owens Coming, et at. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates Ending Bates MEMO RE: REPLACEMENT OF ASBESTOS - CONTAINING ARD042962 ARD042994 INSULATION BLOCK; WITH ATTACHMENTS 24 05-29-73 MEMO RE: OSHA ASBESTOS COMPLIANCE QUESTIONNAIRE; REPORT DETAILING ASBESTOS HAZARD CONTROL ARD007091 ARD007097 25 06-22-73 MEMO RE: ASBESTOS FIBER SAMPLING AND ANALYSIS 916277 0371 916277 0371 26 12-10-73 ARTICLE: ASBESTOS HEALTH QUESTION PERPLEXES 409677 0374 409677 0375 EXPERTS; FROM C&EN DECEMBER 10, 1973 ISSUE 77 08-06-75 MEMO RE: INDUSTRIAL HYGIENE POLICY ARD042947 ARD042947 28 03-30-76 MEMO RE: ALTERNATES FOR ASBESTOS AND ASBESTOS 412769 0102 412769 0103 - CONTAINING MATERIALS 29 01-26-78 MEMO RE: ALCOA'S RESPONSIBILITY FOR MAINTAINING A ARD015268 ARD015269 HEALTHY WORK ENVIRONMENT 30 03-00-76 JOHNS-MANVILLE BROCHURE: CHRYSOTILE ASBESTOS APC001503 APC001514 02-07-78 FIBERS 31 02-18-81 MEMO RE: ASBESTOS ARCH003997 ARCH003998 32 09-18-81 MEMO RE: PURCHASE AGREEMENT IN017695PA JOHNS- ARD007394 ARD007394 MANVILLE MARINITE PRODUCTS; (DOES NOT INCLUDE COPY OF CHANGE ORDER NO. 2) 33 06-00-53 AN EPIDEMIOLOGICAL STUDY OF LUNG CANCER IN FSOA0049 FSOA0071 ASBESTOS MINERS; A.M.A. ARCHIVES OF INDUSTRIAL HEALTH, JUNE 1963: VOL. 17, PP. 634-653 Exhibit # Date George Joseph Dolezal, et al. v. Owens Coming, et al. Cause No. 98-748-A Description Exhibit List of Alcoa Inc. Beginning Bates Ending Bates 34 01-00-64 ASBESTOSIS REPORT OF THE SECTION ON NATURE AND FSOA0500 FSOA0505 PREVALENCE COMMITTEE ON OCCUPATIONAL DISEASES OF THE CHEST AMERICAN COLLEGE OF CHEST PHYSICIANS; DISEASES OF THE CHEST, VOL. 45, NO. 1 JANUARY-JUNE, 1964; PP. 107-111 35 00-00-65 ASBESTOSIS IN SOUTH AFRICA - CERTAIN FSOA0528 FSOA0538 GEOGRAPHICAL AND ENVIRONMENTAL CONSIDERATIONS; ANNALS OF NEW YORK ACADEMY OF SCIENCES, VOL. 132, 1965; PP. 215-234 36 04-00-70 PARTNERSHIP FOR PREVENTION - THE INSULATION FSOA0572 FSOA0577 INDUSTRY HYGIENE RESEARCH PROGRAM; INDUSTRIAL MEDICINE, VOL. 39, NO. 4, APRIL 1970; PP. 21-25 37 00-00-91 CHANGING ATTITUDES AND OPINIONS REGARDING FSOA0824 FSOA0838 ASBESTOS AND CANCER 1934-1965; AMERICAN JOURNAL OF INDUSTRIAL MEDICINE, VOL. 20, 1991; PP. 685-700 38 00-00-88 COMMENTARY: LINKING CHRYSOTILE ASBESTOS WITH FSOA1216 FSOA1220 MESOTHELIOMA; AMERICAN JOURNAL OF INDUSTRIAL MEDICINE 14: 205-209 (1988) 39 09-00-72 CARCINOGENICITY OF AMOSITE ASBESTOS; ARCH FSOA2501 FSOA2504 ENVIRON HEALTH - VOLUME 25, SEPTEMBER 1972; PAGES 183-186 40 00-00-91 THE DISCOVERY OF THE ASSOCIATION BETWEEN BLUE FSOA2626 FSOA2634 ASBESTOS AND MESOTHELIOMAS AND THE AFTERMATH; BRITISH JOURNAL OF INDUSTRIAL MEDICINE, 1991; VOLUME 48; PAGES 399-403 41 04-23-60 EXCERPTS OF THE TRANSACTIONS OF THE TWENTY- SOA0009 SOA0020 SECOND ANNUAL MEETING OF THE AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL HYGIENISTS, ROCHESTER, NEW YORK APRIL 23 - 26, 1960; PP. 76-86 42 00-00-56 ENVIRONMENTAL CAUSES OF CANCER OF THE LUNG SOA0044 SOA0065 OTHER THAN TOBACCO SMOKE; FROM: DISEASES OF THE CHEST, VOL. 30, JULY - DECEMBER 1956; PP. 141-159 43 00-00-00 TOXICOLOGIC ASPECTS OF OCCUPATIONAL HAZARDS; SOA0066 SOA0083 FROM: TOXICOLOGY IN OCCUPATIONAL HAZARDS; PP. 177-194 Exhibit # Date 44 00-00-00 George Joseph Dolezal, et al. v. Owens Coming, et al. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates THE COMPLEXITIES IN THE EVALUATION OF EPIDEMIOLOGIC DATA OF FIBER-EXPOSED POPULATIONS; PP. 37-39 SOA0141 Ending Bates SOA0143 45 00-00-54 THE EPIDEMIOLOGY OF CANCER IN AFRICA; THE SOUTH SOA0357 SOA0361 AFRICAN INSTITUTE FOR MEDICAL RESEARCH, 1954; PAGES 753-757 46 00-00-00 EPIDEMIOLOGY OF DIFFUSE MESOTHELIAL TUMORS: SOA0373 SOA0375 EVIDENCE OF AN ASSOCIATION FROM STUDIES IN SOUTH AFRICA AND THE UNITED KINGDOM; ANNALS NEW YORK ACADEMY OF SCIENCES; PAGES 575-578 47 04-00-61 THRESHOLD LIMIT VALUES FOR 1961; ADOPTED AT THE SOA0384 SOA0385 23RD ANNUAL MEETING OF THE AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL HYGIENISTS 48 04-00-46 PROCEEDINGS OF THE EIGHTH ANNUAL MEETING OF THE SOA0403 SOA0406 AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL HYGIENISTS, APRIL 7-13, 1946; PAGES 54-56 49 06-07-78 HISTORICAL BACKGROUND TO THE ASBESTOS PROBLEM NONE NONE 50 08-13-47 MEMOS RE: NUISANCE DUST SURVEY 08-06-47 916281 0059 916281 0060 51 04-23-48 MEMOS RE: ROTOCLONE SYSTEMS; PARTICLE SIZE 916278 0322 9162780326 04-12-48 DISTRIBUTION OF DUST FROM GRINDING MAGNESIUM 04-08-48 CASTINGS; LETTER AND CHART RE: INDUSTRIAL HYGIENE DUST SAMPLING PROGRAM 52 08-09-48 LETTER RE: T.A.C. SUB-COMMITTEE 916277 0017 916277 0017 53 08-23-48 AIR CLEANING DEVICES TESTING METHOD (DRAFT) 916277 0018 916277 0023 54 12-27-48 MEMO RE: EXPOSURE TO BAUXITE DUST 916281 0053 916281 0055 55 02-25-49 MEMO RE: MINUTES OF INDUSTRIAL HYGIENE COMMITTEE MEETING OF FEBRUARY 16, 1949 916281 0040 916281 0049 56 02-09-55 MEMO RE: SMELTING POT EFFLUENTS 916277 0383 916277 0388 Exhibit # Date 57 04-09-73 George Joseph Dolezal, et al. v. Owens Corning, et al. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates Ending Bates MEMO RE: SUBSTITUTES FOR ASBESTOS BDN016617 BDN016618 58 04-16-73 MEMO RE: POTLINING INSULATION CONTAINING ASBESTOS BDN016260 BDN016260 59 04-17-73 MEMO RE: LIST OF ASBESTOS-BEARING MATERIALS; BDN016262 BDN016264 INCLUDES HANDWRITTEN NOTES ON MARINITE; ALSO INCLUDES IOC: "ALL THE ACTIVE POTLINING CARDS HAVE BEEN MARKED TO SHOW ASBESTOS IN HI TEMP" 60 05-29-73 MEMO RE: OSHA ASBESTOS COMPLIANCE QUESTIONAIRE BDN016323 BDN016329 61 09-12-77 MEMO RE: ASBESTOS DUST - CONSTRUCTION MARINITE BDN033383 BDN033384 ROOM 62 06-15-78 MEMO RE: PROCEDURE FOR CLEANING OUT THE MARINITE DUST COLLECTOS BDN033387 BDN033387 63 07-28-81 MEMO RE: ASBESTOS EXPOSURE BDN033416 BDN033417 o> 1 1 1 1 1 1 1 i 05-20-82 MEMO RE: ASBESTOS HANDLING PROCEDURES BDN033418 BDN033418 65 06-15-83 MEMO RE: ASBESTOS EXPOSURE AND POTENTIAL BDN027067 BDN027073 HEALTH HAZARD; INCLUDES ATTACHED INDUSTRIAL HYGIENE TECHNICAL BULLETIN NO. 83-3 66 00-00-0000 EMPLOYEE HANDBOOK FOR ALCOA POINT COMFORT APC004954 APC004981 OPERATIONS 67 00-00-0000 POINT COMFORT OPERATIONS EMPLOYEE HANDBOOK APC004982 APC005002 o> 1 oo | it 1 i 00-00-0000 SAFETY TOOLS POINT COMFORT SPECIFICATIONS APC241706 APC241740 69 00-00-0000 ASBESTOS FILE: HISTORICAL BACKGROUND ON APC003376 APC003380 ASBESTOS GROUPED TOXICITY, LIMITS, EVALUATION, OSHA REGULATIONS AND 1 H NEWSLETTERS 70 00-00-0000 DEMOLITION/REMOVAL OF ASBESTOS-CONTAINING APC003530 APC003531 MATERIALS Exhibit # Date George Joseph Dolezal, et al. v. Owens Corning, et al. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates Ending Bates 71 00-00-1948 POINT COMFORT WORKS VOLUME 57-1 1948 - 1955, COPY APC000001 APC000416 3, PLANT HISTORY 72 00-00-1956 HISTORY POINT COMFORT OPERATIONS VOLUME 57-B APC000417 APC000676 COPY NO. 3 73 00-00-1956 POINT COMFORT SMELTING VOLUME 57-C 1956 ON COPY APC000677 APC000865 NO. 3 74 06-30-1960 INDUSTRIAL HYGIENE HANDBOOK; 2 COPIES OF ALCOA'S APC001261 APC001261 INDUSTRIAL HYGIENE HANDBOOK COMPILED BY THE PITTSBURGH OFFICE 75 08-28-1963 DRAWING #A-6435-PC ALCOA SMELTING POTROOMS APC213381 APC213331 BUILDING 4-18: PLAN OF LOT LINES 1 & 2 SHOWING POT NUMBERS 76 05-04-1964 INDUSTRIAL HYGIENE NEWSLETTER SAWING MARINITE APC004272 APC004275 77 10-26-1964 INDUSTRIAL HYGIENE COMMITTEE MEETING MINUTES APC003984 APC003985 FOR QUARTERLY MEETING ON SEPTEMBER 24, 1964 78 04-07-1965 PURCHASE DEPARTMENT REQUISITION NO. 12743 FOR APC205401 APC205402 POINT COMFORT MDG SAW NO. 2 79 05-25-1966 PURCHASING DEPARTMENT REQUISITION NO. 475511 APC216624 APC216624 REGARDING HAYLETT O'NEILL & SON FOR USE ON BUILDING 13E MARINITE WORK AREA DEPARTMENT 21 80 02-15-1967 PURCHASING DEPARTMENT REQUISITION #476325 FOR APC215339 APC215339 POTROOM SWEEPER NO. 771 DEPARTMENT 19 81 07-21-1967 SAFETY INDOCTRINATION FOR CONSTRUCTION EMPLOYEES; ENCLOSING REGULATIONS APC005318 APC005323 82 11-10-1967 PURCHASING DEPARTMENT REQUISITION NO. 099797 APC215529 APC215529 FOR USE IN BUILDING 54E BANDSAW DUST COLLECTOR DEPARTMENT 21 83 03-29-1968 INDUSTRIAL HYGIENE COMMITTEE MEETING - MARCH 14, APC003981 APC003983 1968 Exhibit # Date George Joseph Dolezal, et al. v. Owens Corning, et al. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates Ending Bates 84 10-25-1968 INDUSTRIAL HYGIENE COMMITTEE MEETING - OCTOBER APC003976 APC003978 10, 1968 85 12-10-1968 DISTRIBUTION OF INDUSTRIAL HYGIENE MANUALS - APC200848 APC201007 ELECTRICAL DEPARTMENT 86 05-23-1969 INDUSTRIAL HYGIENE COMMITTEE MEETING - MAY 8, 1969 APC003979 APC003980 87 07-15-1969 INDUSTRIAL HYGIENE COMMITTEE MEETING - JULY 10, APC003974 APC003975 1969 88 12-01-1969 INDUSTRIAL HYGIENE COMMITTEE MEETING - NOVEMBER APC003972 APC003973 18, 1969 89 02-20-1970 INDUSTRIAL HYGIENE COMMITTEE MEETING - FEBRUARY APC003969 APC003971 12, 1970 90 04-30-1970 INDUSTRIAL HYGIENE COMMITTEE MEETING - APRIL 22, APC003967 APC003968 1970 91 11-01-1971 PURCHASE ORDER #PR39232-905133-01; FOR USE IN APC215731 APC215731 BUILDING 54, REPAIRS TO HUMMER SCREENS IN DEPARTMENT 21 92 12-23-1971 EMERGENCY STANDARD FOR EXPOSURE TO ASBESTOS APC001229 APC001238 DUST; FEDERAL REGISTER OF DECEMBER 7, 1971, VOLUME 36, NO. 234 FOR SAFETY AND HEALTH REGULATIONS FOR CONSTRUCTION; RESPIRATORS APPROVED BY US BUREAU OF MINES UNDER SCHEDULE 21B, & 19B; INSULATION HYGIENE PROGRESS REPORTS VOLUME 3, NO. 4, WINTER 1971 93 04-17-1972 INDUSTRIAL HYGIENE NEWSLETTER - ASBESTOS DUST APC004255 APC004269 EXPOSURES; FEDERAL REGISTER VOLUME 37, NO. 7 OF JANUARY 12, 1972 FOR STANDARD FOR EXPOSURE TO ASBESTOS DUST; REPORT REGARDING MEASUREMENT OF ASBESTOS FIBERS; OSHA SAMPLING DATA SHEETS FOR FIVE TOXIC SUBSTANCES RELEASED; CORRECTED LIST OF RESPIRATORS APPROVED BY US BUREAU OF MINES UNDER SCHEDULE 21 B & 19B 94 06-23-1972 EXPOSURE TO ASBESTOS; LIST OF AREAS WHERE APC005214 APC005216 MAINTENANCE PEOPLE ARE EXPOSED TO ASBESTOS DUST Exhibit # Date George Joseph Dolezal, et al. v. Owens Corning, et al. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates Ending Bates 95 07-20-1972 APPROVED ASBESTOS RESPIRATORY PROTECTION; JULY APC001205 APC001206 18, 1972 REVISED REPRESENTATIVE GROUP OF RESPIRATORS APPROVED BY US BUREAU OF MINES UNDER SCHEDULE 21B & 19B 96 08-21-1972 ASBESTOS CONTAINING REFRACTORY AND INSULATING APC001203 APC001204 MATERIALS USED IN FURNACE AND CASTING EQUIPMENT CONSTRUCTION (WITH REFERENCES TO LETTERS OF DECEMBER 23, 1971 AND APRIL 17, 1972) 97 10-04-1972 NATIONAL PURCHASE AGREEMENT P-615951 JOHNS- APC005588 APC005589 MANVILLE SUPEREX INSULATION BLOCK WITH BREAKDOWN OF PRELIMINARY PROPERTIES AS OF SEPTEMBER 11, 1972 98 11-29-1972 ASBESTOS DUST TESTS AT MARINITE SHOP; BUILDING APC005217 APC005237 54E; ASBESTOS AIR SAMPLES; MONTHLY REPORT; TEST ON FLAMEMASTIC FLAME RETARDANT 99 01-02-1973 ASBESTOS DUST TESTS; BUILDING 54E; MARINITE SHOP APC004197 APC004199 100 02-01-1973 ASBESTOS DUST TEST AT MARINITE SHOP DURING JANUARY APC004196 APC004196 101 02-05-1973 REPLACEMENT OF ASBESTOS - CONTAINING INSULATION APC001168 APC001202 BLOCK WITH REFERENCE TO THE ATTACHED LIST OF OTHER MEMORANDUM, FEDERAL REGISTERS AND REPORTS; EXTENSIVE COPYEE LISTS 102 03-02-1973 ASBESTOS DUST TEST DURING FEBRUARY APC004193 APC004193 103 03-22-1973 PROTECTION AGAINST ASBESTOS EXPOSURE APC004194 APC004194 104 04-03-1973 ASBESTOS DUST TESTS DURING MARCH APC004200 APC004200 105 04-24-1973 ATTACHING OSHA ASBESTOS COMPLIANCE APC003726 APC003741 QUESTIONNAIRE WITH TEST RESULTS FOR DECEMBER THROUGH MARCH, BUILDING 54E, AND MARINITE SHOP 106 05-29-1973 OSHA ASBESTOS COMPLIANCE QUESTIONNAIRE; REPLIES APC004233 APC004239 Exhibit # Date George Joseph Dolezal, et al. v. Owens Corning, et ai. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates Ending Bates 107 11-06-1973 ASBESTOS DUST TESTS FOR THE MONTH OF OCTOBER APC004201 APC004201 108 02-20-1974 ASBESTOS DUST CLEAN-UP BY VACUUM CLEANER WITH APC220837 APC220841 REPORTS 109 08-27-1974 ASBESTOS FIBERS ON FLOOR OF MARINITE SHOP ON APC004337 APC004337 AUGUST 21, 1974 110 11-27-1974 POT REPAIR INSULATION MATERIALS; PROCEDURE ON APC241964 APC241983 BUILDING 54E; ELIMINATION OF UNNECESSARY USE OF ASBESTOS CONTAINING MATERIALS - ASBESTOS CONTROL PROGRAM POINT COMFORT OPERATIONS; PROJECTED USE OF ASBESTOS CONTAINING MOLTEN METAL MARINITE; INSULATION REMOVAL & DISPOSAL 111 12-18-1974 CALL FROM MR. RAY SKINNER OF OSHA CORPUS CHRISTI APC004328 APC004328 ON DECEMBER 16, 1974 AT 2:45 P.M. 112 12-27-1974 ALLEGED CITATIONS #4 & #5 DATED DECEMBER 23, 1974 APC004327 APC004327 113 12-30-1974 INSPECTION BY MR. RAY SKINNER OF OSHA CORPUS APC004325 APC004326 CHRISTI ON DECEMBER 27, 1974 114 08-22-1975 TESTING OF POTROOM ENVIRONMENTAL DUST WITH APC223064 APC223093 EXPERIMENTAL RECORD PROCESS ENGINEERING DEPARTMENT POINT COMFORT OPERATIONS TO DETERMINE EXPOSURE LEVELS OF POTMAN TO AIRBORNE PARTICULATE MATERIAL WHILE USING NONDUSTY ALUMINA FROM KILNS 115 11-19-1975 INDUSTRIAL HYGIENE NEWSLETTER PROPOSED APC001124 APC001130 REVISION TO OSHA WORKER EXPOSURE TO ASBESTOS 116 01-01-1976- POINT COMFORT OPERATIONS INJURY FREQUENCY APC241654 APC241655 E RATES DETERMINED BY TIME IN MONTHS FOR 1976 THROUGH 1979; AND POINT COMFORT OPERATIONS INJURY HISTORY FOR 1976 - 1978 117 01-01-1976 POTROOM DUST SAMPLING APC222909 APC223022 118 03-30-1976 ALTERNATIVES FOR ASBESTOS AND ASBESTOSCONTAINING MATERIALS APC003090 APC003091 Exhibit # Date George Joseph Doiezal, et al. v. Owens Corning, et al. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates Ending Bates 119 08-03-1976 ENCLOSED IS PRELIMINARY STATISTICAL ANALYSES OF APC213385 APC213389 THE PULMONARY FUNCTION DATA AND SOME REFERENCE MATERIAL 120 09-15-1976 POTROOM DEPARTMENT SAFE PRACTICES APC000906 APC000907 121 11-11-1977 PROCEDURE FOR HANDLING ASBESTOS TYPE INSULATION MATERIAL APC241946 APC241947 122 09-08-1978 POINT COMFORT ROUNDUP NEWSLETTER FOR SEPTEMBER 8,1978 APC005183 APC005184 123 10-04-1978 POINT COMFORT OPERATIONS INDUSTRIAL HYGIENE APC219881 APC219982 PROGRAM GUIDE 124 08-06-1979 ASBESTOS SUBSTITUTION - POTROOM CRUCIBLE - LID APC002864 APC002876 GASKET; REF: ATTACHED JULY 30, 1979 REPORT FROM HAIG G. SAKOIAN, PITTSBURGH INDUSTRIAL HYGIENE DEPARTMENT 125 08-27-1979 ASBESTOS; STATUS OF ALCOA'S ASBESTOS REPLACEMENT PROGRAM APC003132 APC003144 126 05-27-1980 ASBESTOS AIR SAMPLING RESULTS APC241152 APC241175 127 02-18-1981 ASBESTOS; REFERENCES PROVIDING A APC003130 APC003131 CHRONOLOGICAL OVERVIEW OF WHAT HAS BEEN SAID TO PLANTS ON ASBESTOS 128 12-02-1981 JUSTIFICATION FOR EMPLOYEE WORK CLOTHING LAUNDERING AND DRYING EQUIPMENT - CIVIL MAINTENANCE DEPARTMENT APC213995 APC213996 129 01-01-1982- BULK SAMPLE ANALYSIS FOR ASBESTOS E APC239654 APC239671 130 01-31-1983 POINT COMFORT OPERATIONS RESPIRATORY PROTECTION PROGRAM APC228653 APC228659 131 03-08-1983 ASBESTOS MATERIALS LISTING OF ITEMS THAT APPEAR APC241902 APC241920 IN THE STORES CATALOG AND SPARE PARTS CATALOG Exhibit # Date George Joseph Dolezal, et al. v. Owens Corning, et al. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates Ending Bates 132 11-00-1983 POINT COMFORT OPERATIONS INDUSTRIAL HYGIENE APC241262 APC241293 MANUAL NOVEMBER 1983 133 11-00-1983 POINT COMFORT OPERATIONS INDUSTRIAL HYGIENE APC232592 APC232668 MANUAL NOVEMBER 1983; REVISED AUGUST 1988 AND OCTOBER 1996 134 POINT COMFORT DUST COUNTS, 1970-1979 APC 004201 APC 004201 APC 234264 APC 234281 APC 234260 APC 234263 APC 234252 APC 234259 916287 0086 916287 0091 916287 0092 916287 0117 916287 0040 916287 0043 APC 222909 APC 222931 APC 222949 APC 222950 APC 222990 APC 222990 APC 222932 APC 222948 APC 222951 APC 222970 APC 222971 APC 222989 916287 0099 916287 0103 916287 0104 916287 0107 916287 0108 916287 0111 916287 0046 916287 0049 916287 0064 916287 0068 916287 0055 916287 0058 Exhibit # Date 135 George Joseph Dolezal, et al. v. Owens Corning, et al. Cause No. 98-748-A Description Exhibit List of Alcoa Inc. Beginning Bates Ending Bates POINT COMFORT DUST COUNTS, 1980-1989 APC 223040 APC 241152 APC 241188 APC 239653 APC 004464 APC 241191 APC 241899 APC 241898 APC 228694 916287 0002 916286 0798 APC 241178 APC 234829 APC 202952 916286 0771 916286 0767 916286 0762 APC 241852 APC 241848 916286 0756 APC 234816 APC 241846 APC 241842 916286 0791 APC 202829 APC 202831 APC 229299 916286 0900 APC 234793 APC 202938 APC 229198 APC 229200 APC 202897 APC 229310 APC 229273 APC 229192 APC229189 APC229187 APC229292 APC229184 916286 0633 APC202943 APC202950 APC202948 APC231683 APC231653 APC241844 APC202936 APC229214 APC229207 916286 0652 916286 0662 916286 0681 APC241176 APC229202 APC229205 916286 0648 APC234771 916286 0643 APC223042 APC241153 APC241151 APC239675 APC004478 APC241192 APC241900 APC241898 APC228701 916287 0002 9162860805 APC241182 APC234832 APC202955 916286 0790 916286 0770 9162860766 APC241853 APC241851 916286 0761 APC234817 APC241847 APC241843 916286 0794 APC202830 APC202833 APC229305 916286 1113 APC234794 APC202939 APC229199 APC229201 APC202828 APC229314 APC229276 APC229193 APC229191 APC229188 APC229298 APC229186 916286 0642 APC202944 APC202951 APC202949 APC231718 APC231682 APC241845 APC202937 APC229215 APC229211 916286 0661 916286 0683 916286 0687 APC241177 APC229203 APC229206 916286 0651 APC234776 916286 0647 Exhibit # Date George Joseph Dolezal, et al. v. Owens Corning, et al. Description Cause No. 98-748-A Exhibit List of Alcoa Inc. Beginning Bates APC202956 APC229212 916286 0746 APC229216 916286 0740 916286 0733 APC239580 APC234761 APC234765 916286 0749 Ending Bates APC202957 APC229213 916286 0748 APC229218 916286 0745 916286 0739 APC239652 APC234766 APC234766 916286 0755 136 MEDICAL RECORDS OF ALBERTO R. RIVERA RIV 0001 RIV 0344 137 REPORTS FROM PETER A. PETROFF, M.D. PET 0001 PET 0022 FOR ALBERTO R. RIVERA 138 CURRICULUM VITAE OF MORTON CORN, PH.D. 139 CURRICULUM VITAE OF DREW ROBERT VAN ORDEN 140 CURRICULUM VITAE OF JOHN CRAIGHEAD, M.D. 141 CURRICULUM VITAE OF J. LEROY BALZER, PH.D. 142 CURRICULUM VITAE OF LAWRENCE R. BIRKNER 143 CURRICULUM VITAE OF I.A. FEINGOLD, M.D. 144 CURRICULUM VITAE OF MELVIN W. FIRST 145 CURRICULUM VITAE OF KATHYRN ANN HALE, M.D. 146 CURRICULUM VITAE OF E.B. ILGREN, M.D. 147 CURRICULUM VITAE OF RICHARD J. LEE 148 CURRICULUM VITAE OF ROBERT W. MORGAN, M.D. 149 CURRICULUM VITAE OF GAIL DIANE STOCKMAN Exhibit # Date 150 George Joseph Dolezal, et al. v. Owens Corning, et al. Cause No. 98-748-A Description Exhibit List of Alcoa Inc. Beginning Bates Ending Bates CURRICULUM VITAE OF PHILIP CAGLE, M.D. 151 CIRRICULUM VITAE OF FRANCIS W. WEIR, PH.D. 152 CIRRICULUM VITAE OF WILLIAM BURGIN, M.D. 153A 02-28-98 VIDEOTAPE AND TRANSCRIPT TO THE DEPOSITION OF NONE THOMAS BONNEY IN THE MATTER OF LARRY C. WHATLEY ET AL. V. ALCOA POWER MARKETING ET AL., CAUSE NO. 25, 093, IN THE 20TH JUDICIAL DISTRICT, MILAM COUNTY, TEXAS NONE 153B 04-01-98 VIDEOTAPE AND TRANSCRIPT TO THE DEPOSITION OF NONE THOMAS BONNEY IN THE MATTER OF LARRY C. WHATLEY ET AL. V. ALCOA POWER MARKETING ET AL., CAUSE NO. 25, 093, IN THE 20TH JUDICIAL DISTRICT, MILAM COUNTY, TEXAS NONE CERTIFICATE OF SERVICE 1 hereby certify that a true and correct copy of Alcoa Inc.'s List of Expert and Fact Witnesses and Alcoa Inc.'s Exhibit List was served upon all counsel of record via regular U.S. mail or certified mail this 12th day of April, 2000. Lisa L. Steele