Document 2q6O85jzjN8K3QmG61pwVVdZr
NO. 97-1897-C
MARCELLA MONTAGNA, et al,, Plaintiffs,
v. OWENS CORNING (a/k/a OWENS CORNING CORPORATION), et al.
Defendants.
IN THE DISTRICT COURT NUECES COUNTY, TEXAS 94th JUDICIAL DISTRICT
DEFENDANT REYNOLDS METALS COMPANY'S SUPPLEMENTAL RESPONSES TO PLAINTIFF'S REQUEST FOR RULE 194 REQUEST FOR DISCLOSURE
Defendant Reynolds Metals Company ("Reynolds51), by counsel, pursuant to Rule 194 of
the Texas Rules of Civil Procedure, responds as follows to Plaintiffs Request for Disclosures:
A. The correct names of the parties to the lawsuit.
Reynolds states drat its correct name is Reynolds Metals Company; it is without
knowledge as to the correct names of the other parties to the lawsuit.
B. The name, address, and telephone number of any potential parties.
In discovery. Plaintiff has identified many facilities, premises, and work-sites where
exposure to harmful substances, including asbestos, may have occurred. Parties associated with
these sites are `"potential parties" for this action. Reynolds is not awrare of any other "potential
parties." Reynolds reserves the right to supplement its response to this request.
C. The legal theories and, in general, the factual bases of the responding party's claims.
Reynolds refers plaintiff to its Special Exceptions and Original .Answer to Plaintiffs First
Amended Asbestos Petition Subject to Motion to Dismiss or, in the Alternative, to Sever and
Transfer Venue to San Patricio County filed on July 7, 1998. At this time, Reynolds expects that
its defense will be based on documentary and testimonial evidence (including lay and expert
testimony) that: Joseph Montagna was not exposed to harmful levels of asbestos at a Reynolds premises; Joseph Montagna's disease was attributable to a cause other than exposure to asbestos; Reynolds did not breach any duty of care owed to Joseph Montagna; Reynolds was not negligent; Plaintiff voluntarily and knowingly assumed the risk of incurring any injuries or damages alleged; Joseph Montagna was contributorily negligent.
D. The amount and any method of calculating economic damages. At this time, plaintiff has not disclosed the amount of damages he seeks nor the method
of calculating such damages. Although Reynolds generally denies that grounds exist for damages, Reynolds cannot respond specifically to plaintiff s claimed damages and/or damage calculation. Reynolds therefore reserves the right to supplement its response to this Request until such time as plaintiff has provided this information. E. The name, address, and telephone number of persons having knowledge of relevant
facts, and a brief statement of each identified person's connection with the case. Investigation and discovery is ongoing in this matter, and, at this time, Reynolds does not know each and every individual who has knowledge of the relevant facts, nor does Reynolds know at this rime whom it may call to testify a: the trial of this matter. Reynolds therefore reserves the right to supplement its response to 'his Request in accordance with Rule 193 of the Texas Rules of Civil Procedure. At this time, Reynolds identifies the following individuals who may have knowledge of relevant facts and who Reynolds may call to testify at the trial cf this marten
1) Plaintiff/Family Members 2) Treating/Diagnosing Physicians, Reynolds may call Joseph. Montagna s
treating physicians as trial witnesses to offer testimony, including expert testimony, about their
care, treatment and diagnosis of Joseph Montagna. 3) Coworkers and Reynolds1 Personnel/Wifaesses. Reynolds may call some or ail
of the following individuals who were coworkers of Mr. Montagna or who were employed at
various times at the Sherwin Alumina Plant or San Patricio Reduction Plant to testify as to their
personal knowledge concerning plant operations and plant conditions; the use of asbestos-
containing products in plant operations; the elimination and abatement of asbestos; Reynolds1
safety procedures, both in general and as they relate to asbestos (including the use of respirators);
Joseph Montagna's potential for asbestos exposure; and, other matters relevant to plaintiffs
claims and/or Reynolds' defenses:
Dr. John Frandolig RR 1, Box 358 Lake Geneva, WI 53147
Dr. Frandolig was the Sherwin Alumina Plant Medical Director from 1989-91. He may be called to testify about his knowledge regarding the Respiratory Surveillance Program at the Sherwin Alumina Plant, Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about liis knowledge related to asbestos exposure procedures.
Dr. Guy Racette 8122 Deck Street Corpus Christi, TX 78412
Dr, Racette was the Sherwin Alumina Plant Medical Director from 1991-93. He may be called to testify about his knowledge regarding the Respiratory Surveillance Program at the Sherwin Alumina Plant, Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about his knowledge related to asbestos exposure procedures.
j
Dr. Wendell Roberts 620 West Johnson Avenue Arkansas Pass, TX
Dr. Roberts is the current Sherwin Alumina Plant physician. He may be called to testify about his knowledge regarding the Respiratory Surveillance Program at the Sherwin Alumina Plant, Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses.
Deloris Ulke Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Ms. Ulke was the Head Nurse at Sherwin Alumina Plant/San Patricio Reduction Plant Medical Department. She is familiar with the Respiratory Surveillance Program that was instituted in approximately 1975 at the Sherwin Alumina Plant. She may be called to testify about her knowledge about Reynolds' attitude toward employee health in general, as well as general information regarding the Medical Department at the Sherwin Alumina Plant/San Patricio Reduction Plant. She may also be called to testify about her knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses.
C. Arlon Boatman Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Boatman is the Health & Safety Manager for the Sherwin Alumina Plant who may be called to testify about his knowledge of Reynolds' safety procedures and the use of asbestos-containing products at the Sherwin Alumina Plant, as well as other information. He may also be called to testify about the operation of the Sherwin Alumina Plant Medical Department, including the Respiratory Surveillance Program. He may also be called to testify- about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses.
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Terry N. Roubidoux Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Roubidoux was the Safety Coordinator for the Sherwin Alumina Plant from 1992-June 1997. He is currently die Area II Business Unit Superintendent at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures and the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. He may also be called to testify about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiff's claims and/or Reynolds' defenses.
A.S. "Stan" Miilsap 5541 Bear Lane, Ste. 236 Corpus Cbristi, TX 78405
Mr. Miilsap was the Safety Coordinator at the Sherwin Alumina Plant He may be called to testify about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding QSHA and MSHA requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be called to testify about bis knowledge regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training. He may further be called to testify about his knowledge of asbestos abatement at the Sherwin Alumina Plant.
Ray Rabalais 4214 Patronila Creek Corpus Christi, Texas 78410
Mr. Rabalais was a coworker of Mr. Montagna at Scott Electric. He is familiar with Mr. Montagna's job duties as an employee of Scott Electric and specifically, his potential for exposure to asbestos, and he may be called to testify about the same,
Darrell L. Lentz 2406 West Frank Street Apartment 114 Lufkin, Texas (409) 632-9345
,
Mr. Lentz was the Safety Director at the Sherwin Altunina Plant from 1977November 1982. He may be called to testify about his knowledge regarding respirator use at the Sherwin .Alumina Plant, regarding OSHA and MSHA requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be called to testify about his knowledge
regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training. He may further be called to testify about his knowledge of asbestos abatement at the Sherwin Alumina Plant.
Ernest L. Sweet 114 Glenwood Drive Liverpool, New York 13090 (315) 652-6543
Mr. Sweet was the Superintendent for Environmental Health and Safety from 1980- October 1985. He may be called to testify about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding OSHA and MSHA requirements and tire implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be-called to testify about his knowledge regarding die responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety' meetings that were conducted and employee training. He may further be called to testify about his knowledge of asbestos abatement at the Sherwin Alumina Plant.
William E. Hamblin Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Hamblin was a Senior Maintenance Engineer at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds1 safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Lou Suffredini Austin, Texas
Mr. Suffredini was the Plant Manager of the Sherwin Alumina Plant. He was employed at the Sherwin Alumina Plant from the early 1950s-l 977. He may be called to testify about his knowledge of Reynolds' safety' procedures, che use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Timothy D. Woods Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Woods is the Plant Controller at the Sherwin Alumina Plant. He may be called to testily about his knowledge of Reynolds' safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Frank Strickland Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Strickland is the Purchasing Manager for Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
D. T. Greeson Sherwin Alumina Plant P.O.Box 9911 Highway 361 Gregory, TX 78469
Mr. Greeson is a Purchasing Agent for Sherwin Alumina Plant. He may be called to testily about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
James C. Tiffany Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Tiffany was the Plant Engineer at the Sherwin Alumina Plant from approximately 1973-76 and was a General Engineer, Maintenance Superintendent, and Senior Engineer for various periods from 1964-73 and 1985 to the present. He may be called to testify about his knowledge of tire use of products that contained asbestos, the elimination of some asbestos-containing products, and asbestos abatement. He mav also be called to testify about his knowledge of Reynolds' safety procedures, and use of safety equipment at the Sherwin Alumina Plant, as well as other information.
Jack C, Oates Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Oates was the Plant Engineer at the Sherwin Alumina Plant from 1980-84 and was Maintenance Engineer, Project Engineer, and Project Manager for various periods between 1967-74 and 1977-91. He is currently the Senior Engineering Supervisor at the Sherwin Alumina Plant. He may be called to testify about Ins knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin .Alumina Plant, as well as other information.
Paul Matula Sherwin Alumina Plant P.O.Box 9911 Highway 361 Gregory, TX 78469
Mr. Matula is a Designer in the Engineering Department of Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment the use of products which contained asbestos, and abatement of asbestos at die Sherwin Alumina Plant, as well as other information.
Mario Rivera Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Rivera was a maintenance supervisor in Area 50 of Sherwin Alumina Plant. He is currently in die Industrial Hygiene Department of the Sherwin Alumina Plant. He may be called to tesdfy about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Charles Chapman Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Chapman was a maintenance supervisor in Area 50 of Sherwin .Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety' equipment, die use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
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Jeffrey Downs Sherwin Alumina Plant P.O.Box 9911 Highway 361 Gregory, TX 78469
Mr. Downs is the current maintenance supervisor in Area 50 of Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Gary Cedotal Sherwin Alumina Plant P.O.Box 9911 Highway 361 Gregory, TX 78469
Mr. Cedotal was the maintenance supervisor for Areas TV and V of the Sherwin Alumina Plant from 1989-93. He is currently the Shift Maintenance Supervisor. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Ernest Coulter Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Coulter was the Maintenance Supervisor and General Foreman in the Maintenance Department at the Sherwin Alumina Plant from 1963-90. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Ludwig Jahn Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Mm has been the Maintenance Supervisor in the Maintenance Department at the Sherwin Alumina Plant since 1989. Prior to this position, Mr. Jahn held numerous jobs in the Maintenance Department in die 1970s. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Hector De La Garza Sherwin Alumina Plant P.O.Box 9911 Highway 361 Gregory, TX 78469
Mr. De La Garza is in the Environmental Department of the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Adan J. Villarreal Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Villarreal is a Cost Accountant at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds1 safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at tire Sherwin Alumina Plant, as well as other information.
Lester Charles Homan Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Homan is a Senior Accountant at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Ernest Boulware 215 Seco Portland, TX 78374
Mr. Boulware is a retired carpenter, laborer and maintenance mechanic from the Sherwin Altunina Plant. He may be called to testify concerning his knowledge of die work environment, Reynolds' safety procedures, the use of products which contained asbestos, and die abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
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Frank Hal], Jr, 401 Rabbit Run Road Arkansas Pass, TX 78336
Mr. Hall is a building and trade mechanic, employed with the Sherwin Alumina Plant since the late 1950s. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products winch contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Weldon Hesseltine Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Hesseltine is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1955. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and die abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Leroy Rhoads Sherwin Alumina Plant P.O.Box 9911 Highway 361 Gregory, TX 78469
Mr. Rhoads is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1969. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, tire use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, the involvement of the Union in safety matters at the Sherwin Alumina Plant, as well as other information.
Howard Cave Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Cave is a member of the Maintenance Department at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, surety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Ronald Hesseltinc Sherwin Alumina Plant P.O.Box 9911 Highway 361 Gregory, TX 78469
Mr. Hesseltine is a supervisor, employed with the Sherwin Alumina Plant. He worked as an hourly equipment cleaner &om 1965-88. He was promoted to supervisor in 1988 and worked as a supervisor in. Areas IV and V from 1994-96. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Jimmie Lehman Sherwin Alumina Plant P.O.Box 9911 Highway 361 Gregory, TX 7S469
Mr. Lehman is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Howard Bittel Sherwin Alumina Plant P.O.Box 9911 Highway 36l Gregory, TX 78469
Mr. Bittel is a building and trade mechanic, employed with the Sherwin Alumina Plant smce 1987. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Chuck Coulter Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Coulter is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and tire abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
!2
Mr. E. W. Dressen 221 Blanco Portland, Texas 78374 (512)643-2104
Mr. Dressen was an Engineer and Reduction Superintendent at the San Patricio Reduction Plant. He also was the acting plant manager of the San Patricio Reduction Plant from 1974-79 and from 1981 until the plant closed. He may have knowledge regarding plant operations; various applications of asbestos-containmg products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; and Reynolds' attitude toward safety and employee health in general.
Kenneth E. Murphree 458 Caroline Acres Point Hot Springs, Arkansas 71913 (501) 525-3726
Mr. Murphree was the plant manager of the San Patricio Reduction Plant from 1979-81. He may have knowledge regarding plant operations; various applications of asbestos-containing products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information.
William E. Campbell 7746 East Laguna Azul Apartment #272 Mesa, Arizona 85208 (602) 357-9978
Mr. Campbell was the plant manager of the San Patricio Reduction Plant from 1972-77. He may have knowledge regarding plant operations; various applications of asbestos-containing products throughout the plant; tire use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information.
Mr. Harry V, Helton 509 Kilmarnock Drive Richmond, Virginia 23229 (804) 740-7705
Mr. Helton was employed at the San Patricio Reduction Plant from 1966-72 and held positions as potroom supervisor, general plant supervisor and, from 1971-72, plant manager. He may have knowledge regarding plant operations; various applications of asbestos-containing products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information.
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Mr. Clyde Doyce Hester 546 Evergreen Drive Corpus Christi, Texas 78412
Mr. Hester was the chief chemist at the San Patricio Reduction Plant from 1953S9. He may have general knowledge about the plant processes, environmental issues (including asbestos abatement issues) and other information.
Mr. Allen G. Hill 418 Fetick Avenue Taft, Texas 78390-2808 (512) 528-2749
Mr. Hill was a chemist at the San Patricio Reduction Plant from 1967-85. He may have general knowledge about the plant processes, environmental issues (including asbestos abatement issues) and other information.
Mr. William D. Pipes P.O. Box 148 Crozier, Virginia 23039 (804) 784-1250
Mr. Pipes held the following titles at the San Patricio Reduction Plant from 196677: process engineer, power plant supervisor; and maintenance superintendent. He also was the plant engineer from 1979-82. He may have knowledge about the use and application of asbestos-containing products, elimination and/or substitution of asbestoscontaining products, general health and safety issues and other relevant information.
Mr. Kenneth W. Younger 12604 Hardings Trace Court Richmond, Virginia 23233 (804)281-4111
Mr. Younger was a project engineer at the San Patricio Reduction plant from 1970-77 and 1980-85. He may have knowledge about the use and application of asbestos-containing products, elimination and/or substitution of asbestos-containing products, general health and safety issues and other relevant information.
Mr. Brice G. Nelson 1045 Wilshire Corpus Christi, Texas 78411 (512) 852-4535
Mr. Nelson was involved in the original construction and operation of the carbon plant at the San Patricio Reduction Plant, and he worked at the San Patricio Reduction Plant from approximately 1951-69, and from 1974-76. Ide may have knowledge regarding the construction and processes of the San Patricio Reduction Plant in general,
the availability and use of personal protective equipment, general heal* and safety issues and applications of asbestos products in the pLant.
Mr. Raymond L. Bennett 414 Reynolds Avenue Taft, Texas 78390 (512) 528-3284
Mr. Bennett was the power plant supervisor at the San Patricio Reduction Plant from approximately 1953-84. He may have knowledge regarding plant operations in general and the operation of the power plant in particular. He also may have knowledge regarding applications of asbestos products in the power plant.
Mr, John L- Massey P.O. Box 73 Bayside, Texas 78340 (512) 529-6692
Mr. Massey was a foreman in the San Patricio Reduction Plant maintenance department from approximately 1952-88. He may have general knowledge regarding plant operations, tire use and application of asbestos-containing products, the availability and use of personal protective equipment, general health and safety issues and other relevant information.
Mr. James C. Black 224 Bafanridge Drive Hot Springs, AR 71901 (501) 624-7244
Mr. Black was employed at the San Patricio Reduction Plant as a potroom foreman from 1960-63. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues, and other relevant information.
Mr. Clyde A. Krueger 131 Granby Portland, Texas 78374 (512) 643-2421
Mr. Krueger was a general foreman at the San Patricio Reduction. Plant from 1952-84. He may have general knowledge about the plant processes, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues.
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Mr. William E. Shepp 244 Ross Road Kelso, Washington 98626 (360) 578-2429
Mr. Shepp to a potroom engineer and casthouse supervisor at the San Patricio Reduction Plant. He may have knowledge about the use and application of asbestoscontaining products, elimination and/or substitution of asbestos-containing products, general health and safety issues and other relevant information.
Mr. Harold L. Bern, Jr. 2341 East Lynnwood Drive Longview, Washington 98632 (206) 425-8082
Mr. Bern was the Personnel Manager at the San Patricio Reduction Plant from 1979-82 and may have knowledge about information relevant to this lawsuit.
Mr. Joel W. Whitlock 6837 SE Cottrell Road Gresham Oregon 97080-8911 (503) 663-2096
Mr. Whitlock was employed at the San Patricio Reduction Plant from 1958-71 and, during that time, held the following titles and positions: potroom general clerk; potroom foreman; anode foreman; pot relining supervisor; maintenance supervisor and plant safety engineer. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues, and other relevant information.
Mr. Jack H. Norris, Jr. 4318 St. George Corpus Christi, Texas 78413 (512) 853-1021
Mr. Norris was a purchasing agent at the San Patricio Reduction Plant from 197686 and plant purchasing manager from 1986-88. He may have knowledge about the purchase, use and application of asbestos-containing products and/or substitutes for asbestos-containing products, the purchase and use of safety equipment (including respirators), asbestos abatement and other relevant information.
17
Richard C. Easterline IS Serra Lane Massena, New York 13662 (315) 769-1996
Mr. Easterline was employed at the San Patricio Reduction Plant from 1968-82 and held positions as an engineer and carbon services supervisor. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues, and other relevant information.
John W. Ford c/o Reynolds International P.O. Box 27002 Richmond, Virginia 23261 (503) 666-0203
Mr. Ford was the plant maintenance supervisor at the San Patricio Reduction Plant from 1979-83. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues, and other relevant information.
(a) Reynolds Corporate Personnel. Reynolds may call some or all of the
following individuals to testify regarding their personal knowledge on matters of safety, medical
and industrial hygiene issues on the corporate level and/or at tire Sherwin Alumina Plant/San
Patricio Reduction Plant specifically; plant operations and conditions; the use, elimination and/or
substitution of asbestos-containing products; and, on other matters relevant to plaintiffs claims
and/or Reynolds' defenses:
Dr. Woobon W. Doane 14 Runswick Drive Richmond, Virginia 23233-5413
Dr. Doane was Reynolds' Corporate Medical Director from 1993-June 1997. He may be called to testify about his knowledge concerning corporate medical issues.
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David Warren, M.D. 8705 Tarytown Drive Richmond, Virginia 23229
Dr. Warren was the acting Corporate Medical Director from 1992-93. He may be called to testify about his knowledge concerning corporate medical issues.
E. Claiborne Irby, M.D. 11-1/2 Tapoan Road Richmond, Virginia 23226
Dr. Irby was an Associate Corporate Medical Director from 1959-77, and Corporate Medical Director for Reynolds from 1977 until his retirement in 1992. He may be called as a factual witness, but because he also qualifies as an expert, he may offer expert, he may offer expert testimony in tire fields of occupational medicine, stateof-the-art, governmental regulations, and medical issues in general as they may relate to occupational asbestos exposures.
James MacMillan, M.D. 306 Gunby Drive Richmond, Virginia 23229
Dr. MacMillan was the Corporate Medical Director of Reynolds from 1956-77. He may be called to testify about his knowledge concerning corporate medical issues.
Mr. Homer Mac Cole Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 (804) 2S1-3506
Mr. Cole is the Corporate Director of Industrial Hygiene and Toxicology at Reynolds. He has been an industrial hygienist at Reynolds since 1972. Mr. Cole performed industrial hygiene surveys at the Sherwin Alumina PlanfrSan Patricio Reduction Plant and may testify regarding such surveys as well as other factual matters based on his personal experience and knowledge, including, but not limited to, plant conditions, various uses of asbestos-containing products in plant applications, the elimination and substitution of asbestos-containing products, and general issues related to industrial hygiene and safety. Although Mr. Cole will testify as a factual witness, he qualifies as an expert and may offer expert testimony in the fields of industrial hygiene, occupational health and safety, state-of-the-art, governmental regulations of workplace exposures, threshold limit values, the measurement of occupational asbestos exposures as well as other potential occupational hazards, respiratory protection, and pxoper work practices.
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Mr. Ronald E. Benton Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230
Mr. Benton is Manager of Industrial Hygiene and Safety Services at Reynolds. He has been at Reynolds since 1974. He performed industrial hygiene surveys at the Sherwin Alumina Plant/San Patricio Reduction Plant and may testify regarding such surveys as well as other factual matters based on his personal experience and knowledge. Mr. Benton may testify as a factual witness, but because he qualifies as an expert, he may offer expert testimony in the fields of industrial hygiene, occupational and environmental health and safety, state-of-the-art, governmental regulations of workplace exposures, threshold limit values, the measurement of occupational asbestos exposures as well as other potential occupational hazards, respiratory protection, and proper wrork practices.
Ms. Linda Maillet Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230
Ms. Maillet wras the Regional Industrial Hygienist at the Corporate Headquarters of Reynolds for the Eastern Region. She is currently the Principal Health, Safety and Regulatory Affairs Scientist at the Corporate Headquarters.
Ms. Laurie Shelby Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230
Ms. Shelby was the Manager of Industrial Hygiene Programs at the Corporate Headquarters of Reynolds. She is currently the Manager of Health and Safety Programs.
Mr. Richard Mansur 1416 Coronet Drive Richmond, Virginia 23229-4806 (804) 282-4438
Mr. Mansur was the Manager of the Industrial Hygiene Department at the Corporate Headquarters of Reynolds from 1969-75.
Mr. James D. Davidson
Mr. Davidson was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1976-82.
:o
Ms. Stacey Hansen 12701 Mirror Pond Way Midlothian, Virginia 23113 (804) 794-1736
Ms. Hansen was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1990-93.
Mr. Hale Prokopchak 2704 Empress Court Richmond, Virginia 23233 (804) 360-3301
Mr. Prokopchak was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1988-89.
Ms. Deborah R, Hudgins
Ms. Hudgins was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1984-88.
Mr. Harry L. Skalsky 6910 West Grace Street Richmond, Virginia 23261
Mr. Skalsky was a Medical Corporate Toxicologist at the Corporate Headquarters of Reynolds 1979-85.
Ms. Karen Kestle 1336 Merrymeade Avenue Glen Allen, Virginia 23060 (806)264-1789
Ms. Kestle was the Senior Insurance Administrator at the Corporate Headquarters of Reynolds,
Mr. Bobby J. Sasser
Mr. Sasser was the Corporate Safety Director for Reynolds from 1973-95.
Mr. Joseph Nichols 2300 Cedarfield Parkway Apartment 161 Richmond, Virginia 23233 (304) 282-8245
Mr. Nichols was the Corporate Safety' Director for Reynolds from 1945-73.
(b) Other Reynolds' Witnesses
Service Environmental Co. P.O. Box 2355 Beaumont, XX 77704
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Service Environmental Co. may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at tire Sherwin Alumina Plant, as well as other information.
Industrial Specialist Inc, P.O. Box 1630 Lake Jackson, TX 77569
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Industrial Specialist Inc. may be called to testify concerning Reynolds1 safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Estes Refractory & Insulation 6300 Highway 70 N. P.O. Box 600 Belle Rose, LA 70544
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Estes may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
TGI Stephens 777 N, Eldrige, Suite 315 Houston, TX 77079
Performed insulation and/or asbestos abatement wnrk at the Sherwin Alumina Plant. Accordingly, certain agents or employees of TGI Stephens may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Thermo Tech Inc. P.O. Box 3109 Orange, TX 77631
Performed insulation and/or asbestos abatement work at tire Sherwin Alumina Plant. Accordingly, certain agents or employees of Thermo Tech may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Gilman Insulation Co. P.O.Box 4074 Corpus Christi, TX 78469
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Gilman Insulation may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Falcon Associates P.O. Box 7777 Philadelphia, PA 19175
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Falcon Associates may be called to testify concerning Reynolds' safety procedures/ safety' equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Brand Remediation Services, Inc, 1914 Austin Street Orange, TX 77630
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Brand Remediation may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant as well as other information.
Northwinds Abatement, Inc. 903 Port Houston Street Houston, TX 77029
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Northwincs Abatement may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products
which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Casanova Industrial Insulation P.O. Box 4761 Corpus Christi, TX 78408
Performed insulation and/or asbestos abatement work at tire Sherwin Alumina Plant. Accordingly, certain agents or employees of Cassanova Industrial may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Northwest Envirocon, Inc. 16811 El Camino Real Suite 119 Houston, XX 77058
Performed asbestos audits and abatement work at the Sherwin Alumina Plant Accordingly, certain agents or employees of Northwest Envirocon may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant* as well as other information.
Alex Baca Baca Safety Consulting 6214 Battery Lane San Antonio, Texas 78233 (210) 657-0705
Mr. Baca is a retired inspector for the United States Department of Labor Mine Safety Health Administration. He was a Federal Mine Safety and Health Inspector from 197 until January, 1998 with duties to enforce the Safety and Health Regulations on Mining Operations and to gain compliance with such regulations. Pursuant to this position, Mr. Baca inspected the Sherwin Alumina Plant. Mr. Baca may testify' regarding such inspections as well as to other factual matters based on his personal experience and knowledge.
Robert E. Ruckstuhl Proactive Safety' Consultants Company, Inc. Post Office box 260955 Corpus Christi, Texas 78426-0955 (512) 767-1663
Mr. Ruckstuhl is a consultant who specializes in the area of asbestos safety and training. He has performed consulting functions and training seminars related to asbestos safety and asbestos abatement issues at the Sherwin Alumina Plant and nay testify
regarding such consulting sendees and training seminars as well as other factual matters based on his personal experience and knowledge. 4) Records Custodians. Reynolds may call individuals, live or by deposition or
affidavit, to authenticate relevant records.
5) Other Parties' Witnesses.
Reynolds reserves the right to call and/or elicit testimony from any witnesses identified
by plaintiff or any other party to this lawsuit, and, accordingly, will supplement its response to
this request when those individuals have been identified.
6) Rebuttal/Impeachment Witnesses. Reynolds reserves the right to call rebuttal
and/or impeachment witnesses and will supplement its response to this request if and when it has
sufficient information to determine the need for such testimony.
F. For any testifying expert:
(1) The expert's name, address, and telephone number;
(2) The subject matter on which the expert will testify;
(3) The general substance of the expert's mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information;
(4) if the expert is retained by, employed by, or otherwise subject to the control of the responding party.
(A) AH documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and
(B) The expert's current resume and bibliography. Reynolds reserves the right to supplement its response to this Request until 60 days
before the end of discovery in this matter.
REYNOLDS METALS COMPANY
David Craig Landin (Texas Bar No. 11863720} John D. Epps (Texas Bar. No. 00796079) Eric G. Reeves (Texas Bar No, 24026170) Lori Elliott Guzman (Texas Bar No. 24011471) HUNTON & WILLIAMS 951 East Byrd Street Riverfront Plaza, East Tower Richmond, Virginia 23219 (804) 788-8200 (804) 788-8218 (facsimile)
R. Clay Hoblit (Texas Bar No. 09743100) Adam Cortez (Texas Bar No. 04844650) CHAVES, GONZALES & HOBLIT, L.L.P. 2000 Frost Bank P]a2a 802 North Carancahua Corpus Christi, TX 78470 (361) 888-9392 (361) 888-9187 (facsimile)
CERTIFICATE OF SERVICE I hereby certify that on September 5, 2001, a true and correct copy of the above and foregoing instrument is being served by facsimile and certified mail, return receipt requested, on the following Plaintiff $ counsel: Russell W. Budd, Esq. Baron & Budd, P.C. The Centrum Suite 1100 3102 Oak Lawn Avenue Dallas, "DC 75219 All other known counsel of record are being served by regular United States Mail.
R. Clay Hoblit
2S