Document 5gbq40x30KL1Nzmb5kGYxMd8

NO. 01-01021-B WANDA JOE MCREYNOLDS, ET AL., Plaintiffs, VS. U.S. GYPSUM COMPANY et al., Defendants. IN THE DISTRICT COURT DALLAS COUNTY, TEXAS 44th JUDICIAL DISTRICT ALCOA INC.'S RESPONSES TO PLAINTIFF'S REQUESTS FOR DISCLOSURE PURSUANT TO RULE 194 Defendant Alcoa Inc. ("Alcoa") now serves its Response to Plaintiffs Requests for Disclosure Pursuant to Rule 194. Rule 194.2(a) Request. The correct names of the parties to the lawsuit. RESPONSE: Effective January 1,1999, the proper name for this defendant is Alcoa Inc. Alcoa does not know the correct names of all of the other parties to this lawsuit. The other parties, including plaintiffs, are presumably knowledgeable regarding their proper names. Rule 194.2(b) Request. The name, address, and telephone number of any potential parties. RESPONSE: At this time, based upon the limited information available to Alcoa regarding the plaintiff or plaintiffs that have filed suit against it, Alcoa is not aware of any additional potential parties. Additional parties may include the manufacturers that produced products that were purchased by ALCOA for use in its plants. Further investigation will need to be done once Alcoa learns of the PT 50598.1 02402 72034 particular work location of the plaintiff. To the extent Alcoa learns that applicable indemnity agreements exist, Alcoa may join the employers and/or contractors that have agreements with Alcoa. Rule 194.2(c) Request. The legal theories and, in general, the factual bases of the responding party's claims or defenses (the responding party need not marshal all evidence that may be offered at trial). RESPONSE: With respect to plaintiff(s)' claims of negligence, negligence per se, gross negligence and/or intentional tortious conduct, Alcoa states that it at all relevant times has acted reasonably in investigating the potential dangers of exposure to asbestos and/or asbestos-containing products. Additionally, Alcoa reasonably provided adequate protection at its plants to prevent workers from being exposed to asbestos dust in excess of the then applicable exposure limits. With respect to plaintiff(s)' claims of conspiracy, Alcoa denies that it in any way conspired with the manufacturers of asbestos or asbestos-containing products or other defendants to suppress information relating to the potential hazards of asbestos and/or asbestos-containing products. In fact, Alcoa relied on the warnings or lack thereof from those manufacturers and any information that was withheld from the public at large was likewise withheld from Alcoa. Additionally, Alcoa's Medical, Safety and Industrial Hygiene Departments warned workers of the potential hazards of asbestos exposure. Furthermore, Alcoa monitored the health of its employees through yearly medical examinations and chest x -rays. With respect to plaintiffs)' alleged exposure to asbestos and/or asbestos-containing products, Alcoa denies that plaintiffs)' work at its plant resulted in sufficient exposure to asbestos to result in any asbestos-related disease. Plaintiffs) also allege(s) such exposure occurred at other premises owned, occupied or operated by third parties over which Alcoa PT 50598.1 02402 72034 6/21/01 10:15 am -2- exercised no control. As such, Alcoa asserts that its conduct is not a direct or proximate cause of any of plaintiffs' alleged injuries. Furthermore, Plaintiffwas in a similar position as Alcoa to know about asbestos exposure because Plaintiff knew or should have known about such exposure from information provided through his employers and union. By way of additional response, Alcoa has never engaged in the business of selling, manufacturing, producing, designing and/or otherwise placing into the stream of commerce asbestos, asbestos-containing products and/or machinery calling for the use of asbestos and/or asbestos-containing products. As such, many of the allegations contained in plaintiffs)' petition are inapplicable to this defendant. Furthermore, by way of additional response, see Alcoa's Answer filed in this action. If it is shown that the plaintiff was at any time an employee of Alcoa this defendant would show that at all pertinent times it was a subscriber to the applicable state's worker's compensation statute and therefore a direct action for negligence is barred. Rule 194.2(d) Request. The amount and any method of calculating economic damages. RESPONSE: Alcoa will calculate damages according to what is fair and reasonable by community standards, and applying mitigation theories. Rule 194.2(e) Request. 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. RESPONSE: See Supplemental Attachment "A" affixed hereto. PT 50598.1 02402 72034 6/21/01 10:15 am -3- Rule 194.2(f) Request. 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) all 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; RESPONSE: Alcoa may consult or retain any of the expert witness included in Supplemental Attachment "A". Alcoa will supplement this Response when Alcoa identifies additional experts or obtains additional information responsive to this disclosure request. Many of the persons listed as experts have experience and training in the business of Alcoa and the production of aluminum products generally and do not have a formal resume. Their description in Supplemental Attachment "A" contains a description of their experience in the field. Rule 194.2(g) Request. Any discoverable indemnity and insuring agreements. RESPONSE: Alcoa has indemnity agreements with many contractors. Once Plaintiff has supplied specific work history as to dates, employer and site, Alcoa will be able to provide PT 50598,1 02402 72034 6/21/01 10 : 15 am -4- Plaintiff with information relating to applicable indemnity agreements. As to insuring agreements, coverage has not been determined, and coverage information, if any, will be provided once determined. Rule 194.2(h) Request. Any discoverable settlement agreements. RESPONSE: At this time, Alcoa is unaware of any discoverable settlement agreements related to the current action. Rule 194.2(i) Request. Any discoverable witness statements. RESPONSE: At this time, Alcoa does not possess any discoverable witness statements related to the current action. Rule 194.2(j) Request. In a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills that are reasonably related to the injuries or damages asserted or, in lieu thereof, an authorization permitting the disclosure of such medical records and bills. RESPONSE: To the extent that Plaintiff (s) alleges an employment relationship with Alcoa, Alcoa will release such records upon the receipt of an authorization from Plaintiffs) authorizing such disclosure. Rule 194.2(k) Request. In a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills obtained by the responding party by virtue of an authorization furnished by the requesting party. RESPONSE: PT 50598.1 02402 72034 6/21/01 10:15 am -5 - Alcoa has obtained or may seek such documents with the appropriate authorizations provided by the plaintiffs. If Alcoa has obtained or obtains such documents, these documents will be made available for any party's inspection and/or copying at the offices of LeBoeuf, Lamb, Greene & MacRae, L.L.P., 601 Grant Street, Suite 700, Pittsburgh, Pennsylvania 15219 at a time to be mutually agreed upon by the parties or at 10:00 a.m. fourteen days after the date of the transmittal letter from the court reporter to the requesting p?-*" KENNETH D. MORRIS State Bar No. 00791303 FORMAN, PERRY, WATKINS, KRUTZ & TARDY, PLLC 1349 Empire Cental, Suite 400 Dallas, Texas 75247 Telephone: (214)905-2924 Facsimile: (214)905-3976 ATTORNEYS FOR DEFENDANT ALCOA INC. Of Counsel: Ronald B. Walker WALKER, KEELING & CARROLL, L.L.P. 210 E. Constitution Victoria, TX 77902 (361)576-6800 (361) 576-6196.(fax) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served by hand delivery, telephonic document transfer, certified mail, return receipt requested, or regular mail to all parties on this the 2<-<4 day of June, 2001. PT 50598.1 02402 72034 6/21/01 10:15 am KENNETH D. MORRIS -6- Wanda Joe McRevnolds, et al.. v. U.S. Gypsum Company, et al Cause No. 01-01021B ATTACHMENT A 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. H. P. Armintrout 1625 Orchard Wenatchee, WA 98801 Phone: 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 Plaintiff s medical records and radiographs, Dr. Barrett may also testify regarding the existence or non-existence of any asbestosrelated 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. 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. 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 2 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. 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 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. 3 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. William Burgin, M.D. 2601 Hospital Blvd. Corpus Christi, TX 78405 (361) 884-8209. Dr. Burgin is a practicing physician. 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. 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 4 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. 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. J. J. Congleton 130E Zachary College Station, TX 77843 Phone: 409-845-5574 (Office) 409-690-0737 (Home) 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. 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. 5 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 Ferrisburgh, VT 05406 Phone: 802-425-3480 Dr. Craighead is a pathologist. Upon review of Plaintiff s 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. 6 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 Plaintiff s 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 Plaintiff s 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. Dr. Craighead may testify concerning the fiber types of asbestos generally and the asbestosrelated 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 of those 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 discovery, 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. John Cummings Corporate and Investor Relations P.O. Box 5108 Denver, CO 80217-5108 Phone: 303-978-4914 Fax: 303-978-2041 Joseph Damiano 134 Laurel Wood Drive Pittsburgh, PA 15237 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 7 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 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. 8 LA. 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. Dr. Feingold'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, 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 9 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 of Alcoa'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. 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. 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 10 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. 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. 11 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. Kathryn Ann Hale, M.D. Baylor College of Medicine 6550 Fannin, Suite 1236 Houston, TX 77030 Phone: 713-790-2076 Dr. Hale is a Pulmonologist. Dr. Hale 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. Hale may also testify regarding the existence or non-existence of any asbestos related disease. Dr. Hale 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. Hale may testify on the health consequences of smoking. She may also testify on the existence of a dose response relationship between exposure to asbestos and asbestos related disease. Dr. Hale may testify about general medical issues relating to smoking, asbestos, asbestosis, emphysema, bronchitis, COPD, cancer, the lungs, and the respiratory system. Dr. Hale's testimony regarding the condition of the Plaintiff and the causes of his symptoms and disease will be based on her training, experience, education, review of medical records, and review of relevant medical literature concerning asbestos related disease. 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). 12 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 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. 13 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. Dr. E.B. Ilgren, MA, MD, D.Phil. Suite No. 503 830 Montgomery Avenue Bryn Mawr, PA 19010 Phone: 610/525-5960 Fax: 610/520-1156 Dr. Ilgren is a pathologist. Based on his review of Plaintiff s medical records and pathology specimens, he may testify about Plaintiffs medical condition and the cause of Plaintiff s death. His testimony may include a discussion of the diagnosis in this case, the cause of Plaintiff s death, methods of making a differential diagnosis, the causes or potential causes of Plaintiff s disease and the amount of exposure to carcinogens necessary for the development of cancer and/or Plaintiffs disease. Dr. Ilgren's testimony will be based on his training, experience, education, review of Plaintiffs medical records, review of Plaintiff s tissue specimens and review of the medical literature concerning asbestos-related diseases and other materials available. Tom Innes 113 Royale Drive Port Lavaca, TX 779779 Phone: 512-552-3172 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. 14 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 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 15 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 testily 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 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 MandevUle, 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 16 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. 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. 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. 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 17 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 Plaintiff s place of work. 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. 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 generally, in Point Comfort's Environmental Department, and at Alcoa plants with facilities similar to ones at which he has worked. 18 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. 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. 19 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. 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. 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. 20 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. 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 21 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 testily 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 testily 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 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. 22 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. A1 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. 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 23 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 of this 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 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 24 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 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 25 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 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 26 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. 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 27 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 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 28 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). 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 29 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 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 30 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. 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 31 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. 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. Robert Trevino 201 Woodchase Drive 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. 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 32 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 of the relevant scientific literature, a review of various documents produced by the parties in discovery, and review of deposition transcripts. John Vasquez 306 Bloomingdale 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 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. 33 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. 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 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 of the 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 Plaintiff s place of employment. 34 Dr. Weir may testify concerning matters referenced in the designations of Dr. First, Dr. Balzer and Mr. Birkner. 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. 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. 35 AH 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 NO. 01-01021-B WANDA JOE MCREYNOLDS, ET AL., Plaintiffs, VS. U.S. GYPSUM COMPANY et al.. Defendants. IN THE DISTRICT COURT DALLAS COUNTY, TEXAS 44th JUDICIAL DISTRICT ALCOA INC.'S EXHIBIT LIST TO: Plaintiff, Wanda Joe McReynolds, et al, by and through their attorney of record, Elizabeth Schick, Baron & Budd, 3102 Oak Lawn Avenue, Suite 1100, Dallas, TX 75219. COMES NOW, Defendant, Alcoa Inc. (Alcoa) and makes and files this Exhibit List in the above-entitled and numbered cause, pursuant to the Texas Rules of Civil Procedure. Respectfully submitted. State Bar No. 00791303 FORMAN, PERRY, WATKINS, KRUTZ & TARDY, PLLC 1349 Empire Cental, Suite 400 Dallas, Texas 75247 Telephone: (214)905-2924 Facsimile: (214)905-3976 ATTORNEYS FOR DEFENDANT ALCOA INC. Of Counsel: Ronald B. Walker WALKER, KEELING & CARROLL, L.L.P. 210 E. Constitution Victoria, TX 77902 (361)576-6800 (361)576-6196 (fax) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served by hand delivery, telephonic document transfer, certified mail, return receipt requested, or regular mail to all parties on this the Z-Y~~ day of June, 2001. Q < CD O Q El LoL W anda Joe McReynolds et al. V. U.S. Gypsum Com pany, et al Cause No. 0101021B D efendant's Exhibit List CO Q LhcOo- o ZX HI O X < ChD- Oo O) oC<hLyOO-> CO <a r*CCMO o o X OOH < ooh>CohM>- o CO CM CL O) M1 CO CO oo oo 00 CO CD CD o> o> oO -M- M" O) z CO o o LU CO X o oh < oLO o CO CIiso-D CaO 00 co CM o o Xo OH < <hhOD-oChooMM>>-* CCMO CO CM OCL < cIs*o- CO oo ooGCoOO> o 0CCoT0ODf O la--. cc o co LU Q Z o CO acc>oo gg in O CD LU oDXC C<IO 3P O<in H>> d<o oz O 1CCTO> > X a.Xl ODC I-- ^F >P X CO x Lii O X DC 8: < CO LIOU- z X LU O cc z LIU- H; DC Q5 Z < co X< < > UJ z zo CD ^ co o^ d 53 LU 3 LU O >r x O co CL X >5 <x < CO LU DC oI-- cLUo UJ CO CC co 3< XH O3 OO DC CO CO < coo ICO LmU co < LU X I- >CO- CO o I-- CO UJ CO CO < z o CO Io < LU DC LU 2^ LU a: ? CO lii UJ X CO Q<>X0. C_OJ < DC LU cd co 3 < DC UJ I< aui > o DC s8 Ul 0. 33 a co x5 X CO < On; O LU LU z UJ UJ UJ cHo- <_ co = C3LUO 2< U". CO CO CD O Z HC? CO CD >X 3 < DC f-- CD V X < DC C<O co 3 Q Z co 3 a UJ co 3 ax z? lii DC I- oLU DC Z < 3 CL co > 3 UJ Q DC oz uj o 2o UJ ui DC O LL o UJ o o Ho < oI O Q o o CSJ OCD <5 D o 111 o 11 j ! co 11 11 ! j oo 11 CM J1 co o 11 o i :9 ! i 99 1t in 1) LO o o o o 11 o 1 11111 o o o ! Jo : :9 i !o \ 1o ! j o *} 1 9 CM ! S o oo *oo 1 11 111 * CD CM CM o 1 t111111 in o 4 o CM CO M* in CD N- z Q < CO O Q W anda Joe McReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List O % CO o CO T" Z o o LLI O CL < CM O O O ULl CO O CL < r-~ in 05 bO LL co LU z o >o 1i- o O 2: q_ _ii <, IQ--. 31 CC O 99 xx O co x LLI LLJ CO *LL LU Q oz ?< o< UJ < o o CM O CaM> o X o DC < 05 5.-- o X oo < II cc. < CL LU Q CO I-- CC o CL UJ OC <w UJ LU I Zy O CL Z LU CC J LU ^ > CO H OQ i x I- < X 7n ^ LU -- Q I, >LO t LUqH < Z CO o> o> 0 X 0 oc < 05 CO T" CD 0 X 0 DC < z o r LLJ -- Q. Q- b LU O CO Q0X XX LU < LU LL LL X o|5 lit 111 1|11 11 1111111111 1 11 11111|11111 ^ u, i oo co s_ m to~ =3 =3 CL X >- W LL Z LU KUJ ^iht Pluq. LU CC _1 CL -- CO 0 CM o> 0 X 0cc < CM 00 o> 0 1 0cc < >UJ >- UJ Ul LU li^ S< b ox- ztX > b LU < O u. CO Z ll ;ui O H- 0 o QC < O LU _l > CL co o CM 05 o X o DC < oo 5 o X o CC < CC LO > tg <co> uj b Ul ui o tZ Ul 1 o 0X <S i= it* < O ui > LLQj 1 CL O H O Uol s Ul X _ x 05 li z Z X H >uj ozeoe lli i o z b o K>b o > 50 < zo 2 Ul co H x X sico 2fom co`> t o 2 o2 w cl iE LL LH<QLI - - o i :g og 0^-0 i ! o.-- conn lo in to tt cm o o iii CO "I- co 1 ; CM co j ; CM 11 I I f- CM CO Tf CM T" O 11 1 11111 t111 CM CM CM CM CM T- T_ CM CO CO CO CO CO CO CO CO CO CO CO d> '<* rL CO CO i" 0 CM CM CM CM J" CM CM CM CM CM T" OO O O 0 T" 0 11 1111111 )111 CM CM CM CM CM CM CO CO CO CO CO CO CO co 06 d> CM T- 0 CM CM CM CM CM CM r- OOO O OO to o 05 ofS 00 O) CM o < om Q Q_ MEMO RE: INDUSTRIAL HYGIENE NEWSLETTER. MARINITE; ARCH018211 ARCH018234 SAWING OF MARINITE; DERMATITIS POTENTIAL OF MARINITE IS MINIMAL AND THE POSSIBILITY OF W anda Joe M cReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List 4QfcZ HI CO LO o <* o CM 0in5tf CM O O O a. < CO CO CD CM O' o Q X < co o o co 't o Q DC < CM o o X O X < %zo aHI CD CD o CM o o 't CM O' O 05 LO CM O O Q- < cCCCMoDD 'f O a: < CM O COO o a a: < CM O o X O X < oQ pco X x o 5 Q z < 0 z >- "o uj cn a: ox ^ LU X CO o oUJ _l _J co _ ^UJ UJ I- uo oxc co o Ul U ^ UJ Ul oc oUl CO Oz _i oo co Ul zUl O_l O < Ul o o co CO oco < 3I-- CO CO z o Qb I" 2 IKO! X ox X X 1x= _i CO 5 X z X X >I-- UJ if zo UJ X H- DC < <o z X : Q_ 0<oQ/:) a a=3 0Q>1 x cOo o 3* O 2 i3=HI ZO yo o 0c > Ol X UJ -J z < UJ Z CO UJ LU >- 3 Xo d Ul Izt a: uj co CO x a Ul UJ z<1t111111 1111 uife x oo oZ i | 11 H ui a: O O _l CL UJ DC F CO < QC => a UJ CL D Z UJ o - OC 2 CL 3 OO? Z^2 UJ LLJ 3 U-J-o < EzZ Qoa 2 oc LU uj < co Sox z o < Ul co X a z < co X Ox ui X X UJ z Ul Si x <u co xS Ul _J Ul <x xh- oCD- CO o> QZ iCoM .. X XX X CO XX LU LU -J CO 1 I<Q-o v-- CN CO O OTo Q HJ t-- CM CO CO CO ^ to to CM CM t- CM CM tL t- r- O i ' ! \ ! J itiii CO CO CO CO d) co OO ^-- r* OO i J ! 1 i J1111 to tjo in o <Oi or-I o 1 to 1 to tL CM CO o 11111111 in CM d> o iifiiiiii co T~ J ! co 09-25-64 09-15-64 08-27-64 0O ARCH018743 ARCH018743 MEMO RE: P 0 T R 0 0 M CRUCIBLE REPAIRS (BONNEY PLAINTIFF EXHIBIT) Q < CD O TO 0 >* c CD QL E o O E 3 CO co CD CM O CO => ^ X o LU 6 ^2 (D c 0 0 0 0 CO c CO 32 0 0 0 O c O 0 o > 0 tr o 0 o --) 0 0 c 0 O Q_ Tt Q Z LLI 4t Z CD LLI CD 0 Si *5 0 H -i 0 eg x 0X 00 0 LL H Z oo <^ _j eg O. oo' a> I-- CM CM 0. 00 00 XX aa o a: 0 CO < < LLI 08 ofl Q in h- CM CM oo oo II CO CD eg 5 co oo r~ r* XX oo vc a: << LLI 1- O' O O O O O O O O 0 O' O CD1 v~ CD CO CD CM CD CD CO CD CD CD r^- CD O CD O CD t! CD r^ CD CD < CM *-- O - CM CM *- O CO t- O o Q 00 CO CO 00 CO N* N* 1^- in CO CO CO O O 0O 0OO O 0 0 00 CM CO O ai ro o Q CM in o in o oo CD O O' o in o in o oo oo> o* >- i* is Q 0 Jr 0 0o 03 o 0' Z0 z a 0_ Q_ 0 0 cIYa oM z d* Z0 <0 o3 - X o X < 0 2 1L a: 0 o a >- z 1 0 0 < m CL 0 z O CL 0 14 o 0 CL wf O 0_ 0 0 < o a: 0 LL a: lu Oo sp 5 0 o l00 0 0 < 0 CL 2<Po CD r^ oo o X o CC < hN- CO O X o VC < o0 05 z< 0o 0 Si < CL I0- 3 X00 O 0 0 o_j 0 h LL) 0 t LL lit ?oo 200 o in o o oo o N* in CO O o in o o 0o0 LO CO O < 0 CL < < O O0 z 0 00 0 3 >- X 0 0L 0 aO z CL <a 0a 0z 3< 0z Ho ZH CL < < CL O 00 CL Og 0 0 < 0 O' O O' CD CD CD CD O O T-- CO OO T-- T" j in i !9 ! ' CD * :9 I ! o! !0 11 CD 11>111111 CD CO T- CO 0 CD O CM CM CM CM 01-12-68 Q < CD O Q ARCH18741 ARCH18741 LETTER RESPONDING TO LETTER RE: DANGERS OF WORKING WITH ASBESTOS IN UNVENTED SHOP W anda Joe McReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List O CM Tfc M" Q CO Z 0 1 LU O OH < CM co 0 o1 111 CD O OH < in go _ O ll < si -fc LU o Cj Q HI I-- b V) Q_ z o: a: < CL o in LU LU CO OH oh-- OH LU Q CO LU oo oCO X < LU 3 oc Si o I- go 2Q x LU X < LU 't in co o Xo oc < r-~ co cco- o X o oc < Q CO z O< I-- h* CO o LU V LU X 3 co m L- co O o QC Q. _i * < O-2ofot a3 o z x QC < co cOho- co ooQ o LU zo 3LU CO co co -> LU > LU % Z < OC oh- LU ^ OH j= LOL LgUc S >tn? 4b KCO 3 Q- HI CO LU 2| X2 CD z < a w ill" HI CO CH Z Oci--o" nO 2 a. 2 co LU LU 2 QC CO LU m co < Hi LU 8 D UD LLUU n * CO ; lu ; hi =2 co o CO -Mh~ NCO CO OO XX OO QC QC << CO o co -s- 00 h00- oo XX OO 0C QC << LU W CO 0C " QC 3 QC Hi CO LU X t OC o LU a CO LU HI o oc X O o CO 2 < Hl 5LU CP fClO) 2< < o hCO X o o M" L~00 X o QC < X I- a HI o o co co < co co oz bco <-- HI ca co 3 X < o oLUc CO o UJ z l-- < HJ O Q<C oll > HI lijO QC X ^3 tO HI f- 00 COI CO <I QO CO 00 CO oo CO CO CO h- CO CO CO CO CO CO CO CO CO CO CO CD CO CO h- h-. h- h- h- hCM a> CO CO CM CM CO CD T-- CM LO co CD O O CM CM T-- r-- CM CM T-- CO V~ T- o T-- CO CM CM CM o CM CO CO oOOO ooO T-- T- o o o o 1 11l<111111 00 00 CO CO d> o CM CO CM oo 11 00 11t111111 CO d> CM CM o CM CD o jU ro o CO O CM CM LO CD CM CM CM 02-26-68 Q < CO O TELEGRAM RE: DOCUMENTATION FOR HEAT TREATMENT C35794 2945 C35794 2945 FOR MARINITE, WHICH CONTAINS 50% ASBESTOS, TO REDUCE TOXICITY SIGNIFICANTLY W anda Joe M cReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B D efendant's Exhibit List UL O Tfc Q Z HI CM O CCMO CO CD OO CM CinO CO 0h0- o OX x < in CD h- in % CD o zo o> o o c- co o 00CM CM o LU CO CO in in X o tx < hCO in M- o oo X < o CO m o- o o Ox < o Q SSo O I- <2Q_ OH O CO LU 52 HI x <(0 o z< X I_l < LU X <_l z o : OI-- < XI- < LU X o < t LU LU < CO _l < z o H < 2X uj < _l oo cop C0 UJ UJ Ul in in r- ao I- < O Ul ,, 00 LU Q _l UJ O in X 3_l X CO o < Ul X Ul N- CO in c- X oo H o Q Z=> O LU co UJ a=3 o_ Z -- X I-- CO o x z o Io-- z D z < cx o u Q oX Ul X XX St < < CO 5 > Ul LU X o X3 o x cOo x X co I-- z g CO 3a xQ OF OX x O o p a co CO X oc H < x co Q CO a =J x 1:5 <a "? is 2^ mm co < o 3Z g8 -X O co ox od x < > ul O zz X XXX If IsQ CL 3 oo o uj IX o 2' CL OO3 o LU LU (IX- LU z LX g O co 2o X _j X CL uo iii 0 *< oa X CO < Ul UJ _J _l o< co _l o X Ujx H z "1 ffi5! 2 LU O Z 0 u_- o x 3 X X0 X < -7 < W X . co CO co O z X-- UJ X 0 b! 2 8" 2 Q O 7 o o SEuj ! LU UJ 2Q Xo xa X2c<o X 2 111 co UJ al o CM LU h< O iti iii i h- h- i r^ i itii$ii c6 CO oo cr> d> oo iitii CD o o T~ 11 11 ! ! r* o O o> a> O) O) i i^ h- CD CD CD CD i i cm CD d> 00 CD CO CO : i ^ CM o O CM CM O I j o CM T~ d> CO CM CO 11 11 OooO O iii iiiiiiii ii T__ T-- h- r^- co CM o CM CM T- o Oaj co Q 0C0N C7> CM O CO 00 CM CO 01-27-72 MEMO RE: ASBESTOS CONTAINING REFRACTORY AND ARCH002259 ARCH002260 INSULATING MATERIALS USED IN FURNACE AND CASTING EQUIPMENT CONSTRUCTION W anda Joe McReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List Q < GO O Q U_ LL O ft 00 Q ccsmi Z LU o o O Dl < Tfc -- CM T-- o o o UJ co O Q- < a z aLU < i_rco' LU u. c3o a UJ ' Q QCOO QL LU i=UX CO ^ oI-- oP LU _I CO CO L-- UJ uj co > CO LU co co r; LU < co z -- n' O O lu5 Q lL LOL ^co l0--. ns 0 w 2 Q != (XL O CO LU Q > 1 < a: co 3 a z .. 3 co o ax. LU ci-o 3 a co < UJ Q2 Z LU <H %3. CO CO -< UJ uj 8s O LU a. oc a UJ co < Ul 0 LU Z* CO 5: uj 50 LU H CO < 2 LU 2? o < CO ^ CO |Uco 0 Ul CL Ul X CO CD 3 2 < a: a: O CO CD CO o CO a> LO CO o CO oID> OChO- CO LU CD <: Q LU oX o o z < CO D3 LU Q XO ocr O a. t! 0 LU z *z a: < ^8 CM O oO CL < ho CM o o O CL < < O3 UJ ,, Q rr u=5 LU co X Ul UJ OC Ul CD CO DC -J < 22 UJ r 9 Cl LU lu a: < U. 3 iie .<50. CO >X -LU < I Oco co 3 a or O u. co Q ouj a: xk< q CO Q 2 LU Z ^ CD < W co P 2 < CO CD o r*o o Qa<: LO o h*o o Q a: < CO > a: o g. Eol! a. CO : co uj ; uj tr. DC., ~3 l-- <r co S -i cc com uj co S=i o Ul X > CD .. Q Q UJ I- Ul an: oiu o> zOd wkqI 5i< CM CD N- CO o o CD 00 o 2 g* 3 u. co .. ^LU O I-- IT O LL- z co z O ui w P CO LLJ F cc CWD L>5>L $LU < 0 <? U. Z CL O < CO Z^Z oy cuoi u>i H<3a O Z 3 LU ioo --Z< -I -- CO Ul CO X O c<o OoS Cugfi 2 CL 0 08-21-72 LU CM CM h- i^. I- < o Q oo CM CO O ro o CO Q CO ChMp Cf-Mp CO 4 CM LO CO oo CM CM II c- r- oo II h- CO oo CM N- O 4CM o CM Ni. NOi CO o 00O' LO CO CO CO CO r-. CO co W anda Joe M cReynolds et al. V. U.S. Gypsum Com pany, et al Cause No. 0101021B Defendant's Exhibit List Q < CQ O Q LL LL O m Q in Zo o LD O CL < o 't o o X Otr < CT> CD CM o Q a: < 4fc CO in CD o o LU O CD CL < CD O M" o o X Otn < CM CO O CM O" aO CL < o *- dc o in UJ LU CD in T"* DC H 3 CO CD CO o X O LU O o 111 _COl LU Z UJ O DoC <jZ < --I CL DC X Ul DC O UJ oU_ CO Ul U_ Q oo co 2 LU O h-- Q_ a: o UJ 3 CO w <? oI X O' 3 Q. LU DC UJ CL 0I- < LU X _l 3O 1 LU CO DC a XO CO 9 <h LU S CD ID Q 3 CO LU <5< co I- 3 LU CO O Ul O < Xo o <z >z si 3 LU o a: co co aIdc O O UJ tD Xz iii Q 1 wo o co UJ co UJ CO CD 2UJ c<o c<o O -J S3 1^. a> o h- o o Q DC < o> o I*- o ao DC < a DC < t as X XUl ULL- UJ DC O o I-- DC CO H UJ Z LU 3 O oo 1^ co o L- CM co CT> h- CO o cc- CM CD ^-- CD CO c>o _l < z < a z < o < CO DUCl go LL CO o I-- cUol CD C<O ui DC UJ L5QDo CM DI- o o CO CM h1- Is- CM 00 CMi o o 1 t 11 111111 CO co CM CM CM CM CM CM CM h- r- h- N- N- N- N- N- f"- in d) co N- CM N. O T-- o CM CM t-- O O CM CM O CM o Ti- o CM s-- O T" o 1^o CD O NO 00 O oT" 1 L1111tt111 CO hd) CM to o ii CO iiiiiiiii h- CM CM CD O CM CD O oai co O 0o0> o CM CO Q < CO O Q LL LL O W anda Joe McReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List in % NooO Q r^ ZULi tho- 05 o CO o 'fr 05 CM MO Q CL 05 rC-D CM < Oco) CinM o Q CL < in o o O 0. < oo o o o O CL < 3*: hCO O N- o oULI CD 05 CD O CM r^ o M- 05 o CM M" O 0co5 O CL r~ CM < 00 CD CinM o Q CL < co o in o o O 0. < 00 o o o CL < co r- 05 M- 05 CO mco oo o0 oX 1 O CL DC << h- 05 05 05 CO O O CmO co o o Xo oX CL a: << CO CohO- CO < O CohO- *b z 59 x => CD UJ XUl ULI & UJ CO CO < Q CO UJ O CD 25 CD CO < Ul CO ul co ui u. 3 Q l= 7- X Q ,X a! co uj <OlL Q I-- U- UJ CO L >-z z Ul < CL co o O oO _i I-- u CO >CO oyjS 0. UJ CD CL X O UJ CO O o| mI-- X UJ o o o|Q_ h o >- co oCC U<l UJ Q O oX Z *>CO Q o ocUJ CO U08J I-- D z UJ X _l < CL H CO < CL u. CO _l Ul < z UJ CC I-- co Ul co O Ul 0 CO z <UJ ui CL 3 X CL CO Ul co 2 < o *UJ O(X) CO K 3 Q Z UJ I-- O CL >Pz DC O < co 2 co - ouj co ui S 3 u O 6? F2 << LL >- UJ > P CL UJ O w <Z uCOi Lb_ H CD 5 0 /r Q- CuU_zLJi 6^ zo 02" w a! [2 cOho- CO co' ui 0 Q cl 0 Ic-oiL_ O Ul UJ < CL CO CD nr Q. CO < <00 < ui [2 a: CC 5 cl r ui CO CO -2 t ^ h h --DZ ui CL DUCJ uXj 2^ y uj 2 zQ. < Ui W Poo: x O 2 LU S z: LU O SO QLi 2< Ul Ul 2X 1 ss x LU 0^ --Li- 1 1 1 1 O C/) CD ^ LU LU ^ CO CD m (0 CO 2<< o9h ui 2<O 11 1 H<Q 00 00o CM CD O jroj 6O Lll CO h*I . o I CM -M"M" ID 11 h- 1 CD O 111 00 O 111111 ID 1t1111111 CD 1"O CO CO 0 CD 00 1 h1 CD CM O 1 1 1111 11t1 N- CD 00 1 00 1 1t111111 11111i111 hp hp 0 r^00 CO CM 00 co 111t111111111111i11111111 h06 CM 0 CT> CM CM ooooI II O CD CM1 CM1 CM o o o ion to < FSOA0824 FSOA0838 00-00-91 CHANGING ATTITUDES AND OPINIONS REGARDING W anda Joe M cReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List o < CoD Q u_ LoL % a>'t in Q t1o^- o o in z o o LU a o <O O dc co co < ll 00 CO 1111 rh- in 1 in o < O co LL I111111111 o < O C/) Li. % O05' Z o LU CO cNOo- o a dc < 0O5' o 5O CO o om O co co CM CM f- in m O o <O co CO LL oI-- 0. o: o co LU Q co z o--X> < 0. in cci-mo- LQU 3 _l O z Io- z OW -o z S- W CO C\T mod UJOZ O rf Oom < dc o hi a. ct MqjO Ox t? 1OX1 ccaz 3<< w^il ^ =i O o>> 5ZO. LU < O 220 o CO cd icnOo ' CO CO o Q>3- CL CL I-- CO S O Own cd*8 --I z LU Q5Z 2 CO ^ mo. Ol-I Eco- m m co _ < to m l2 < mm DC co 3R O z in CO ^ m _j IO |g O > Z < u- .- O Q. Ow 5 mO m CD m m x O co O mz E!z SJ o^ -IL1- <oE QCOQ. DOC CL moc OC c/3 ^ 2m w< ?d < CO . t-a w co .. z co Oco mx czo 27 o < >- i-- CO wo* m co m co < oc CL o ^ < O CL X CL CL in a! COmD CD coo> CM co z <O > *m Pb cmo` <o' DC LL < X O3 m yQ co oz o _i t_<- o m o co O > m co m Q < o co o co oc ol-- >2 t3w < o*c o>- O' CO CO co < O z < m z CMi in r-- CM < ol--c o CO 3 H<- Q Z in cm 53 CO CM z CL m x COoDc CL O h05 CL o t- zm >m DC CL ooXc m< cmo oc m DC CL < O' o z ODC zm 05 CO LL a. O> o x co X > dc LLJ m CO g aDC < CL 3 D Z m i CO i LIQU-<o 00 00 d> o iiiiiiiii in o o CD O iiiiiiiiii CD O O V~ o CM CD O ro o CM CO Q m in m cmoI o hI- oo 6o oI oo in CD Nin in in zS si 0 SOA0065 SOA0044 CHEST, VOL. 30, JULY - DECEMBER 1956; PP. 141-159 OTHER THAN TOBACCO SMOKE; FROM: DISEASES OF THE ENVIRONMENTAL CAUSES OF CANCER OF THE LUNG Q < CoQ Q 0. LL O W anda Joe McReynolds et al. V. U.S. Gypsum Com pany, et al Cause No. 0101021B Defendant's Exhibit List Tfc Q Z HI % O HI CQ Cd o 3o o f-- ionot o< CD CL Cd Q. LU 2 <J> < o> in CD CM O 2? QI--_ SO OC a: z o So CO HJ Q <o Q ID a z< < Oco H C1--d C3O mCLUO O co < o CM CM o< CO in co CM <O co t< 0 ffii CQ LL go Hi < e! 1 5 CD "og o Cd o -- y O) X2O Z<TM >.. <2 oTM ao^ ^ -J t LU LU rnE2 ioo 2 co Q O LU LU 022 M" O ID o co U. o ID O co LU CO LU CD < 0. In O N* Cd > < g O CQ CCQO CtuL < CO LU K ID CM CoO LU 2 < OU. O _ < LU W CD X oz Z O C o* % > J <Za OUJr CO CD oSf co CD CM CD CO LU 3^ 3| LU LU LU X CO I-- 1 Oz (- < < V, o< CO c < u. n I ooL>U c2a< CO H 5U vLL- lu cc X CC co o't 03 03 CO CO LU CD < CL co" M" LU 3 O_l > o CM O O o< CO CD O O o CO o CD 03 CD z CM LU 5Z f- < LU o JE I- OJ 'Ok ^< CO LU ZX O H- co CM QC CL < oo>c- |_ U. OO LU LU CO CD LU OC LU > Cd LU H CO oLU LU LU X CD X LU o OO LU 0- CO < Z H h- oCL Cd LU o _ O o Si 2 CD 0C0*D CO h- O >X LU qJ LU CO O X CL LU I- < Oa 04 5 o a> o"5 o OO oo o o o o 1 CM 1 N- 11111i1I o o d> o T~ iiiiiiiiii CD O O O o 0in0 a> in o (D o CD CO cm o CD CM CD 00-00-56 SOA0406 PROCEEDINGS OF THE EIGHTH ANNUAL MEETING OF THE SOA0403 AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL HYGIENISTS, APRIL 7-13, 1946; PAGES 54-56 W anda Joe M cReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List Q < oCD Q Q_ UL O % Q CO 00 Z 0 0 LU < 0 <0 4fc Z CD CO o O O lii CQ < O (O 1 co 1 i0 !< SO !11 CO 1t ! !1 T^" i! 0< !O i CO 1 r* CO ! CO 1O :< s0 11l1 co 11 ! h} lO i C0 !0 !< !O : co i 10 !! C<sO!Q 1< !O t111! CO S co ! Is- co {Q *< :O : co 1 1T3 ! co :0 !^ !O 11!11>1 CO I M11 C2O2 !0 :< :O : co co Q tn CL CL < CO O x QC < X j= < Z o h- O 0. o^ nQ. ll.O cd o CO O- LU >" LU O tao- OO <^ O -- Oo gx 9o o o 5? X o ic I- CO z o 3 0O. LL - OQ 2 CO Oo L-- 0- <x 3 LU DC LU W CitO! LU LL- X Jt HO 2 <C co < LU Q bo 28 id 03 O 2 COI O UJ h- in Q CO aX 0- a! h- LU D ... 0^ co 01 JoTG>- X --- <710a o< 8 OC UJ o < o o z LU <_ pc O LL >- UJ O f-- _1E1--. O LO 9ZJSn CL < CO UJ O uj LU CL O X LL < I- < 0. Xoc z* o>- o? z2 co LU 3 UJ co < 1-- UJ X I-- co o co h~ < ? . - ID o Q co L2U UJ Q CO C9^O wO< co < X CL 3o o mF WLU = oQ co CO 2 Z LL < 3 UJ o ox z < LL LU O P2 oo oy 1o11 S 5S 2Z LU UJ QQX< CL > u O LU UJ < < LU o Ul iHt QLUC b uj < LL LU O m I- O H PrZCO al -a: o T_ LU >- O) LL CC LU < O oc LL I- |_ So" 3^z >in< Li uj r-- I2S 93 DC Si Ul CO LLj < Q O> o X co I-- CM 04-00-46 LU o o o oi O' lOI O Ot 5o o o o o o o oI Qo o o o oooo <N co o 3ro o CO to CO O CO CO CO CO o ol Tf O 00 CO CO o < --5 CD O Q LL. LL O W anda Joe M cReynolds et al. V. U.S. Gypsum Com pany, et al Cause No. 0101021B Defendant's Exhibit List =tt Q LU 111 Z o z 3fc O LU CD LU z o z o CD o O 1 CD ; cm J CO rO 00 CsJ S' cho! CM CD ! CD o> i1 5> Oin) i cm ! CM o o S| coo Y-- > co 00 CM 1r ^CM CT--D ! CD O) i5 1 i CO m 05 io CM O in o o |o O o o ! Is- N- T-- Y-- I IsCM CM 00 CM 00 CM } CD CYD~ CO CY"D !1 o> 05 O) o 1 1 Isio CY--O o CO in o o 'M* O !o o o O I J Ihs-- Nh-. Y-- 00 Y-- 00 CM CM CM CM i CD CY"O CYTO-- CY"D' i 05 O) 0> 05 O 00 CM CM 't Tf O CO O CM OO XX << <- sf O CD COM' COM' O CO O CM oo XX << LU LU z UJ LU _i CO o LU o> DC N X CL _l o o <W UJ Oh- aco H CO a z LU o> F2 OLU SO 3 i-- CD o> CQ i-- >co < ftLU X O 5: h~ i= H 3;I-- Q. 3 m O<Z Q 3 CO 1-- CO <2Q Q- O 00 -- UJ 2 DC O' LU CD H- ^ 2o O<' co a: x CO i 3X UJ Q <LU LU UJ o r^o> o CD z I- CO UJ X 3 < X ai co 2 3 "r" Q to co I- Z 3 QooQ: o a S^|O z|E1go d0< ooi- Ox P ooaCD O aj Ofo z:a CD 111 HI < 3 o X -X o < CD a: o CO X i 00 Is- i i N- i O CD ii O iiii C<O CD iitiiiiii a LU z < CO 3 Z LU CO o 2 UJ Is- IsCO CD V 00 00 oo 0C5D i i i i iiii itiiiiiii iiiiiitii LU lJ_ d q <o 15 8 O ll Hr O O^ ^ .X co; ~O< (/) ? 2 W OgpH I> J~ co co 5QOQ 00 00 00 ?^ CO CM 00 CM y-- O 444 ooo o Is- 1 1 t 111 111111 I1111I111 co1 C0 UJ 3 CO > LU a LU a: X LU t UJ -J 00 05 o 00 11 --i. 1 UJ tt11111111111111it11111 _J O DC < 00 CO CM CO 1 1 1 r i iiii iiiii o N- 111111 o 111111111 > 1 CM Is- iiiiiiiiiiiiiii UJ O < CO 3 3 LU X CO l- CO 3 UJ CL Z Ll X UJ 3 U,,o LU VC iii UJ xz i i o UJ iiiiii 2 *2 LU UJ LU > i 00 IsCM CM <iiiiiiiittiiiiiii 52 i 05 in CM CM ii CO h- iiitiiiiiiiiiiii iii iiiiiiii O Is- <iiiiiiiiiiiiiii I-- CO 3 l-- x o IL o I- z o X ID N- W anda Joe McReynolds et al. V. U.S. Gypsum Com pany, et al Cause No. 0101021B D efendant's Exhibit List Q < GO O Q [l LL O Q z LU % z CD LU GO in oo LO CM Tt in CO o CO CO CM Tf ay in CM o> o o 00 o> O o h- o CO Tf o o CO ay CM O in CD CM a> CD CM 00 O' CD CM O hCD CM o> 00 CD CM CO O O h- o o o CD o o CO CD o o OO in o o Tf CO CO CO h- h- h- h- CM CM CM CM CM CM N. s. i^. N- h- h- CM CM CO CM CM 00 00 00 00 CM CM CM CM CM CM 00 00 00 00 00 00 <O CL < o CL < CM CO 03 O 0. < o Q_ < CM CD 5) CM CD T-- o> CM CD ay CM CD o> O CL < O CL < O CL < o CL O CL < O < CM CD a> CM CD CD CM CD CD CM CD ay CM CD CD CM CD CD O to CM CO co O in CM in CO o o CM in CM CD 00 O O CM ay o o NT" o O Tf o o ay o CD CM CD tJCD CM o o> a> CM CM CO CD CM in CD CM NCD CM CD CD o o O' O O CO O O CD O o O' CD O o in in o o CO CO h- CO N- N. h- r- CM CM CM CM CM CM h- h- h- N. CM CM CM co CM 00 00 CO 00 CM CM CM CM CM CM 00 00 00 00 00 00 o o oO < sQ. CL < CL < CM CD O CL < CM CD 5) CM CD ay CM CD ay CM CD 03 O CL < CL < O a < O CL < O CL < O CL < CM CD ay CM CO ay CM CD a> CM CD T-- ay CM CO CD CM CO 03 CM o CO CM CM o CO in CM O in -- MCM O in hCD 03 CO CM O 00 r- o o O CM 03 T-- T" CM o O o 03 T-- CM o CD 0003 T-- CM O o N00- CM CM O CM O o o 0h0- CM CD m o oo o 0C0D CM CD CM OO T- MCM O CM CO 00 co CM O CL L a. CL CL a. CL CL CL Q. CL < < < < < < < < < 03 CD < < 00O 00 00o CO CM in T*"* oo oo T-- CO in CD 03 CO 03 03 03 T-- CD 03 T-- 03 CO 00 CM O O o 03 r^ o 00 N* T-- 03 CM OO ^ CM M* CO O CM h- CD Tf CO CM CM CM CM o CM CM CM CM oo OO CM CM O CL o 0. o CL O CL O CL O CL O CL a a. O CL CM CD CM CD o CL o CL < < < < < < < < < 03 03 < < oZ I-- Q. o: o CO LU Q LU H < oQ fSI CO o 03 CO o Q 00o33o I ooo 03 CI-O z 3 o o h~ CO 3 Q oaI--: LL o o Io CL CO I'- W anda Joe McReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List Q < CD O Q El ll O =tfc Q Z LU lO in O) CM O CM O 0. < O 05 o CO 00 CM CO o> o N. r^. o CO 00 CM CO o> CO CO N o CO 00 CM CT"O 0) CO in CO T-- CM o L < in 00 CM O CL < CO ho CO CO CM CO 03 ^-- 00 Tj* CO CM o CL < h- 00 Tf CM O CL < CO 00 CM o a. < o> s o CO 00 CM CO o> o CO oo CM o CM O Ql < CO CO 00 CM o CM O CL < in o CO O) CM CM o 0. < CO T" CO CO CM CO o> O) N- CO CM O CL < o> CO o> CM O CM O CL < oCT>) 0CCMM5 OCL < oCCoCMMM> OCL < 0CCCCOMMM0O 0O. < -O' CC0CMMO5 OCL < ChC0CCMOMM-) OCL < CoT0CC--MOM>5 OCL < OC0TCMM")) COL < CCCT0CMM--OO) COL < 00C0CCMMM0>5 OCL < C0T0CC--MOM0) OCL < CM CoO GCCCT0"MOO>O C0COMM> oCL < ioCC0nMM5 CaL < 0CM0COMM55* CoL < 01--0 r^ cCMo aCL < CCC0CTM"MOO0* OCL < in oT"o CM OCL < hCC0COMMO5CoL < itC0CCn--MMM5 OCL < T0CCTC--"MMM5" oCL < CCoOO CCoCMOOo 05 % z o LU CD CM in o CM O CM O CL < TN N O CO CO CM CO o> hco h-* o CO 00 CM CO o> CM CO hO CO 00 CM CO 05 CM in CO CM o CL < 00 Tj* oo 'O' CM a 0. < CO m ho CO 00 CM CO 03 CO 00 M* CO CM O CL < CTOj* oo CM O CL < CM tJ* 00 5 CM O CL < To> ho CO 00 CM CO a> O) CM OO CM O CM O CL < v CO oo CM O CM O CL < 0) o> CM o> CM CM o Ql < o o 05 O CO 00 CM CO a) CO o> h- CO CM O CL < 00 CO o> CM O CM O 0. < oCOOC1M[M>O) oCL < O COCCNNM)II OCL < CrCCO0MMM-0 CoL < o 0CCCNNO)II oCL < CCCCN0MMMO5 oCL < C0M) CCOMM) ao. < 0O>O 0CCMM) aCL < OO CoCMM> COL < CCoCCoMMMM>> COL < G^--O C0CNM3I OCL < C0CoO0D CCC0MOO0 0) CO C0oCMM) oL < CoCOi0nMM5 aQ. < o0COCMMMo5* OCL < C0COO0 CCMO oCL < CiCnOO CCMO OCL < 00 CMM' CaL < 0CCOCCMMO5O OCL < TjCC0CMMM) OCL < CCCNO0MMM5. OCL < CiConMO CCCoMOOo 05 O I-- Q_ o: o CO LU Q LU I< Q CNI OCD Q LL W anda Joe M cReynolds et al. V. U.S. G ypsum Company, et al Cause No. 0101021B Defendant's Exhibit List o>3fc Q Z ill CO CD COD CO CD 04 CD O) N. CO COD CD 00 04 CO o 04 OQ. < COO COM) CM CM o CL < OCD 0O4) CM CM o CL < icnn <o CJ> pr*- rt < N. Tt cd o CD 00 CM C. D O) hin 0> CM O Co, M CL < CO tCM 0> CM CM o CL < CO ^ 00 O CM $CL o> < in ^ o CD 00 CM Cr*O 05 o> CO o CD 00 CM CD v~ o> CM in CD <J) CO CM o CL < CD cd hTt CO CM o 0l < CD CL < h 5 O) oz O OLU GO CM CD CD CD CO CM CD tCD CD CD CO CM CD CD N- T" CM o CL CM O CM a> CM CM O CL in o CM a> CM CM o 0. 00 Tt CD o CD 00 CM CD r*. CO CM O a CO M* CO O CD 00 CM CD CD in o> CM O CM O CL CM T" CM o> CM CM o CL CD Tfr N. o CD 00 CM CD CD -- CM O) CM CM O CL O M No CD 00 CM CD co CO ho CD oo CM CD O 00 in O) CO CM o CL T"* CD h- CO CM o CL in CD h- CO CM o CL o> No CD 00 CM CD cn 5) < < < O) < o> < < o> < a> O) < < < o> CM o O 00 J O 00 05 ! o h- CO M1 i m T-- CO O o o o 1 o CM o o to O a CL 1 CL a CL < Ii < < < \ CM CO CD in 00 o r- a> S o> N. CO ! T" CO o |o o o 1 o CM o O !O O o CL : o. CL CL < i< < < o I-- Q_ a: o </) LU Q LU H < oQ CM COD TO 6 Q o o OX oCO a z < CO z o zo z< S3 oX Q< LU o Si itLU >- Sso 0. o o LU x<2 0. < CO oO o _l O< LU Lx-- CO ox u_ XO o CD a a! LU OQ. L-- u. 2 Oo h- z o CL <g gx DC o oic--o I- Q LU X C3L i X CO lii o o _l -i x LL o u. 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LU o > CXOL oor i-- DC O P^ LL co z o^ CL CO 00 o> T-- o o oo 04 CO i i i i i i i i i ii<itiiii CO Nco O O o o C<L o o o O C<L COI m UJ s 3 o_l > CO z o UJ oCL L- oDC LL 2 o o I- z o CO CL >u DoC >Z 1-- Q_ 2x2 oO CD in TO") o o oo CO co 1 1 1 1 11 1 1 1 111J1111 t(1111111 in co CO o o iiii iiii o O C<L iiiiiii Il''-- CO o o o o <CL >0. O o z 0 CD m O) O 1 hin UJ O > CD UJ 2 CO J-- DC O u. o 1-- 2 00 od CL Z cLOo G> " o o o o co 1 1 1111I1111 CO CTV-| o o O CL < CCMO o o o C<L CO <o Ul o _<l X I- oLL >CQ CO UJ Q UJ &l if *c OO OO CO CQ QO zz << XX LU z UJ UJ z UJ UJ o_ O CD t -iJi--S ?r\ 0Sl 0S- t--c3 CO 23? 23? ci_o QQH 2 CL o CO O) to co CO o LO 00 > t I 1t I 1 1 11111 itiiti1ir C00D 08-28-1963 DRAWING #A-6435-PC ALCOA SMELTING P 0TR 00M S APC213381 A P C 2 1 3331 BUILDING 4 -1 8 : PLAN OF LOT LINES 1 & 2 SHOWING POT NUMBERS o < CQ O CV5 0 >. c <0 Q. 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UL CaNO>* X-- CCON O Oi o co N" h- CN CO CN 3 a LU Oi Iz- c<o LU 0 Q Oi <a. 0I--1 LU o Q LL LU co <o i r_ o^ Qi ? 3O Ol CL ICCxD--TO> ro^o4 CN Id Z Z O lcuo itr ZD< Z Qi CL O O LU riLO CO z O < LU 3 CO CL 0 LU 8 < 01 Qi O LU ^ _ LU i-- I-- br ol P z <0. LU _! Up LU > < Q<2 O X LU Z CD $2 W* X<0Qi 7^ o<q Qi CD d 3 LU 3 CL Qi CQ CCCDDD x-- LCON oin Oi o LL ID CN CO CD CD Is3 oi ^CL O LU N- zs So N < LU CL 0LU LU Q LU CD z CO co <o Xo O CL CL 1-- 3O 0. CL hCCTD-> x-- in X-- CON O hO iS fee 0 3 01 CD O LU IL CL is b co IS a: o i- z O LU o Q Z CO LU LU s >" 1C LiEU o--a. <C/3 IUEJ NCO. 05 x- rl CN or^ 00 00 0CO5 o 05 CN 05 05 11-10-1967 PURCHASING DEPARTMENT REQUISITION NO. 099797 FOR APC215529 USE IN BUILDING 54E BANDSAW DUST COLLECTOR DEPARTMENT 21 APC215529 co 05 Q < CD O CD 0 >* c ro CL E 0 O E u 0 0 _J O CNJ O !5 CO T- jc D? 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OCL << 0C00Cr~OM50 X < 0c LU CO O to 0 1 0 < 0 o0C>O5 o~ 00 > >- < 2 "35 X UJ m 2 UJ > O z 0 z Z< 00 2z 0 z iL-U UJ UJ z UJ 1LU--UJ 1U--J LU 2 U1--J UJ 2 LU UJ 0 > UJ UJ UJ UJ UJ Ul X _l t1-- hi-- t1-- <2 IX I- 2 2 O o I- Z 0 UJ O O O 0 0 0 PUJ z UJ 0 > X UJ Ul Z IX o^ O UJ z UJ 0 > z UJ 0 >- ZD X X UJ z UJ 0 >X < X 0: 3 D o< dg co a: (V J-- HO whj O Ul 1 < X 01-- Z> a z 111 1 1 1 t1 _l < X 1-- 0 3Q C0O5 Z 1 1 1 1 t1 _J < X|_ ^05 3 ?: Q25 T--CO CO 05 T-- 1I111 00 CO 05 1 T- ! ! 05 ! * co * 05 1 1 1 1 O) CO 05 *-- <1 05 1 CO 1 1 05 1 1 LO CM O T-- (111I111 O CM T-- i ! co ! j^ ! ! 10 ! !0 i1 1 1 t1 1 1 LO T"~ NO 1 1 -A 1 1 O 1 1 CM 1 t-- com Is- CO 05 05 05 05 05 05 -r- 1 00 Is- CO 05 1 05 CO 11 CO O 1O O 1O O 1 1 O Q. 1 CL < 1 1 < 05 r>- CO 05 CO 0ccoo5 Oo Oo oO C<L <CL >- c<x D CCMM X CO CX <UJ CL I 00 z I-- UJ LU UJ UJ UJ UJ UJ LU O o UJ z UJ 0 > X iS OI0s---5 COM COM 1 1111 i1111111 o o UJ 2 UJ 0 > X < cr h~ CO 3 Q o Oh-) r0Ot--5 C0O 0 OO Q < CD O O LL LL O W anda Joe M cReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List % CO Q f'w Z CM LU O <CL % CO I*co o CM UJ CD a<o. 00 CO CM o o o C<L o> CM CM O aO C<L O) CD CM O O O <Q. in in CM omo O CL < CD CD O CM CM ID OO O O oO CL CL << in o CM CM in oo oo OO 0<. C<L Ui om 0 0 iO- feoo w ohCD 3 CD 1a: ^-!3 01z O Lii oLU DC ^ mx O >-oI "SzcCoO o CD a: o o 2 i O O O W CD LU _l CD I-- CD LU 3 CD OH O LU X DC CL C<D LU CD DC o " O' < a CD UJ LU a - CD CD LU DC 3 "5 Q OH 3 L.-CD o DC 9 o < Oz D_ LU LU , LL " O0C WZ3 O -CD ristsn| 83S < 3 OH Op DC > ll E DC O O CO H P LL OI oO LU X CO yDC <LU O& O3 . . CO o tsi 0 LU C<D 3 >~ UJ CD CD _J Q 0> LU fH T" 1" DC 08 CD o UJ h- OC CD UI LU CD C<D < UJ Q<C O UI u. CD CL O UI I- o DC CL DC | 0^Q> 3 CD O CD h0". o o^< 3 "2 |4!S oDC 3 f) LL 5cO 0 cn I LL tn CD XOH uj a: tO Q. CM b CD -I UJ cd CL CD UI qh d ^ CD DC O f- Ofc ozz z ^ 2 o ?. OCO IBsQ oi < 2 9 O PS 8i 23OLU CD on LU CL a DC uj 01 CM dZ LU id uj O3 cr co h-- _I O CD LL 3 3 ^ CD X oUJ Z O CD Q i= Z Zr!oC CL CD Sc?Q LU DC LU LU U" DC LU rn O wbo CD U- O Cl CD X T-^ 3 CD XEQC _1 CD cm' O O OfflU <r LU t- I- UJ <3 I-- CD UJ UI _l CL CD CD LU < CL UI CD I-- CD UI CD CD < a <z^ oX Cq= C<L DC d CL 3 3 LU CL CD a 7 Q CO L-- LU CD CO UiH> o":5 ac i- 3 d< 3 >o QC LU -i LU C3D 0_l CD LU CL CL ed LU O > a: < CM > 3O3 |x| _ LU -o UJ OH Z > LL => C O CD qch-9 o| U___ I 2 DC O3 CD LU CL CD X3 UI O UJ > o DC CL 0<- N- LU o> rO) H co < CM gQ CM r^ a> o CM CM ha> C-a> T--I co o CMi CMi CD Oo 5cm o ro.2 o CM O CO o Q O' o in to oo Q < co O a LL LL O Wanda Joe McReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List 3QfcZLU mo CM O O O CL < CD CinO in o o O CL < r-. CO CM in o o O CL < iii o> TO") io iiiiiii o a 0. < co OT*") MO 111 CM O 1111 CM O O O 111 o O 0< 1111 a < oZLU QQ co o CM O O o CL < co co in m o o O CL < h- tt ha> CO o> 111 00 CO CM in o iii Y~ o T" 't o I(11 y-- r- o o O a. < ti o O CL < o o 111 o o CL < 1111 CL < O LU COL cUoJ LL XO 33 9X3<L*U U => > CO o - CO <3 H0-. DC 0Q LI LU o0 O 1>m CO u a: cm LU X 0- LU Q U<3 o> CoO; wQ uOg Q_ LU ~ CO Cl o LU Z - CL 3 X OCzO LL X o "> X CO < Et co CD 5 LU \--CM I"'- ^ CO X O CL LU O) OCL O 0. r- CL co O O3 CL CO CL COL X UJ CL >- LU H Z z a: 3 DC Q < OCL CO LU X H Iz- <Z UJ in X co UJ o Oo L2U o CL > C<L cl co^ CL :0. < 3Q Z < r- LU LU C<L CL _J CD < CO LU W -- X DUCJ ChM- < LU CL CD < 9; LU CO Ic--o c<o <3f LU QC LU <ou- 3H CO LO Z _l O0 5X zo ie o 0 1 < UJ X CO o CO LU UCOl oz CO LU < CL LL LU O) *cl O LU co CO Piu QC o. 33 CL LU CD LU 3 0- < Z o 3 CO LU > > O Q X *C CL LU CD 2 LU H- Qo UJ X CO co o o >- LU > I-- I-- DC o > CO co < < * LU UJ 3 _J o <O H LU CL LU CL UJ Q CO CO CO co < CO Z < : 0- O UJ _J CL CO LU I-- < Q CM IB o a> ro o zQ CM o> CM CD tiii CO i NO) ti CO N* O) i CO tii ho> 00CMI o I 'M* o o CD CM A iiitiiii CM O tI o 1111t111 Yo CM O iiiiiii in o CM o co o> ooo CM o < --i CD O 02-20-1974 ASBESTOS DUST CLEAN-UP BY VACUUM CLEANER WITH APC220837 APC220841 REPORTS Wanda Joe McReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List 't *3*Q Z coo> tClT-> o o M- CM N- o o 'O*3' O MO o CO O O CD CO O CM CM -M- OO OO oLU O O oO O 0<. 0<. CL < C<L C<L C<L 4fc 0CO5 <J> o o co CM CO CO O ^3Z o o o -M" O O CM OO fCO o o CM CM '3 O O O o o oLU CQ O Oo CL < 0. < C<L C<L O C<L C<L CO UJ CL 0LU O CQ X _1 CL UJ CULl CD Oo< co LU 2 co UJ UJ CL LU I-- O ouj h^ CL Q ? < LL XCL > oLU t-- O oCO CD uj 52 *co Q_ O Oi- o Oh-I- LU ^ 01 < 3 CL CD UJ U. z CL 3 3 CO Q. X UJ co CO LU CD CO X o CL < CD Z CL 3 Q UJ o O co UJ o UJ O ^ CD o i- 9 H CO Z CO UJ Q z z cUol 3 0 UJ X LU X CL LL I<OOQ-' i9^>.8oco 3 o O < < ooOto o oQ CO LU 5z ox 2 UJ UJ - cn oc uj x Q_ I- UJ O CL LU O Q I-- co UJ H I-- CO Q CO 11 CO UJ CD CO 1 1 1 1 < CO hoT~ 111111111 1 CM o CO o CvO- 1111111111111111t11 111 <C I-- co z < c<d z Io 1t UJ 1 H-- 1 O1 VC 1 0. CO ro> T-- I11111111 1 CSJ CM CO o 1111ft1111111111111 111 CI--O CO UJ H H CO 3 Q CO H CO UJ CD 11 1 1 1 CO I < CO o> T-- 111111111i1 CO o o in <1t1111111111111111 T- t11 LU t- _I CD X 5 <$ <>X X Uj o CO CL CL OZ2 xx0 < CO O H 9 CL H2I <Oh co o> 'ICM ri* O cT--o co I-- CO UJ CD 11 UJ < 1< 1X t CO 111111 O CO I111I11|1111111*1111111| t11 1 N. ov>6) CM in o NT". T~ C0 H CO UJ CO 3 O CO 1(|1 1 h" CO UJ 1 CD 1 CO 1Ii111 < co 11111111111 r- t-- co o T-- 111111111111 <11 I 0T--0 1111 1 1 1 111111 1i1I1I11111111111111I111 111 119 3 o < CQ O CO CD c CO CL E o O E 3 (O Q;CD co O CM CO O .g XI Z> X HI CO o CO z *-* CD CD -o CO = CO 3 CO CD O c O CD Q > CD o: o CD O CO "O c CO CM 5 o aj ro Q Q LL LL O 3fc c- co Q Z co oO' o Hi O C<L h- co Z CO Oo' o LU oo CQ 0<. O CL 0 1 CO LU Z D<C oo I-- Q_ a: o o ooc CO LU co Q ac-oCUQJ hCT-> 85 CO co uj m0 co 3 << O' N LU o> <I- i r*- CNi I Q OoO CO oo CT> o C<L O' co CD OCM' O C<L O LU co z uj I-- -I -J CO DC co Q O O O H S CL o < LU LU O CQ CL Z 06 CL CL C<O -? --* 5< I CO _<l co _<i 2 OS DC LU I<- DC CO CL Ui z < 2 I- Z co UJ m Q I< Q5 i- z o z Z o Q| co < LL O -t 3 CO Z 3 CO LU Z O UJ CO LU I- DC < CL Ui DC OO o co*; Ro D LU J-- O z x< CO DC UI LmU !z= O l- O 3 co O DC UJ CL CO < O a. 2 O) r^CNl CM oCMo CO oO' o O C<L 0CM0 CO o't o Oa<. co DC X o CO 3 0. CL O O < X CO 02 UJ CM z< ** CO N- 2 CO OC DC 2 LU s| Om a dQ o< o h- CD T" 00 T-- CM ii iiii iiiiiiii hCCMO OO o Ql < CCMOoMO1 a Q_ < O' hcn- co CM DC UI CD UI O LU a a UI < o in 3 $ CO z o H- 2 o Q LU O UJ 1 aT--> 11 1| N* CM CT--M 11111111 CCCMOO oo I! oac>o ! CO !i CCMM O !O CL : q. < iiii < to CCMO oo<* 2!!!! coMcCCMMoo' O Q_ i: oq_ < :< CO 3 CL DC O O < X co O u O DC UI X CO h- CM I CL UJ CQ DC 2 UI O UI Q 1 O HUJ CO CL a; x i= o GTr^"-) o CO CM T-- <111 I1111111| Is o z co 3 DC UJ CO QUJ CO 3 UI g8< CD 6? _J X z UI z o OCl- ^o _<l h- CO DC LU DC O CO > Z Cl- U UI UJ ui 2 C O CD LU DC i-- < 2 OR 3 =j o 3 o -=! 0_ U- 2 o6 <0. LU 02 Z E CL CL h- UI < Ui CO CL CL IUJ X LU LU I- UJ a o in <hj-) CM CM CO o CM OO O' LO CM CM CM CM Q < CO O Q Q_ u_ O APC241946 APC241947 Wanda Joe McReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List 11-11-1977 PROCEDURE FOR HANDLING ASBESTOS TYPE INSULATION MATERIAL 4t oCO Q 5-- Z o o LU O C<L It CN T-- e> o o LU CO O a<. !! LLOO !11I C51--D CVI i1:1111 a Q<. i J!! lCTOD* ;1 rr CN !O 1!1 C<L CN !!1;1 1 CoN CCON CN O l CL i1 < i o> '! oO> !S CCCMNN 1O : cl ii < oO) oCO oo a <CL o o> o CooO o C<L 05 0CO0 C.--O CN O C<L lO oCOo CO oCN C<L r^. oO) o o o O Q<. COD O) OO O o CL < o CO o > CO LU UJ DC Q UJ co co oo QOac.:HCUcc<aOoJr uj , O I0--_ LU UJ gs a: > UI oCO o Z CL co LU UJ X Z UJ UJ CL Q Fj-L*U 101 <5 id-c <x CO CO 3O O z o Z a> uj - 2 a: Sg 5 3O oo o -- O fa> Z UJ O co Isa> 5 CO CL dc L Q Q <Z o u. S 05 a: I CC LU Is>- o CO ; I Q!! CO UJ CD 3 o dc x >a3n x O CL c<o co 3 a o ooc I- o u. CO ocIcU--aoI c<o o z< co oIc--o UcoI co CO -J << oa: yoc {2s >o z< QC UJ z <Iz- oa CO X < z UJ <o <OT <H Z O _i ma: $ co 5 LU QO UI z uco o_ 3 CL UI oc UI O UJ Z X UI UJ H- X CO yUJ for-- 2 CL UI U< CO Iz- UI (X < CULI a O o DC I- o CL <a;o LO LU at-- cf> y-- T-- 11111 ChDO) 1tII1111 t! o--i O LU NCDOT--) yL o o 11 1111(1111111 ChoT--O>CoO CoO cIsoO) co o00I o cIso o> LOI i o> o OJ 3 o irso N- 00 a> O CN CN CN CO Q 132 ot APC213995 APC213996 12-02-1981 JUSTIFICATION FOR EMPLOYEE WORK CLOTHING LAUNDERING AND DRYING EQUIPMENT - CIVIL MAINTENANCE DEPARTMENT Q< "3 CO O CD 0 > C CD Q. E o O E 3 CO 0 O CNI CO O -Q !c =) X LU 0 O zcd >-- 0 c 0 0 O 0c CO 35 o c 3 0 o 5 0 Q >s a0: o 0o ~3 CD "O c 0 o LL LL O % o 't 0T--0 in z o o 111 O CL < z% oo co in o oo LU CD O 0<. 0 O LL 0 UJ 1= UJ oz _l 0 -- UJ 0. CL 3 o: Q o CO LU Z 3 O Kg Q J- 0 o oo 0 Ul 00 Ul 0N0* LU o> I- ooi < cp Q cf> o CO o 03 ro O CO co Q C00M03 03 CM O 0<. 00 oo 03 CM O X < UJ z UJ o >X _<l X I-- 0 3 Q Z 0z o UJ CL o I-- X Ul Q O3 U. 0 63 r_ CL to ?o O CL CL Q_ CO CD T-- o o CO 0h- 00 CoM o O X< 0 COM O O X< Q ^ Ul T1 z UJ o CQ X >oO X 3 X o < X I-- 0 o3 oQ Xo I- CO o X X 0 X 3 0 0 tr tp x < t X 0 CQ z` < 3 0 O! <0 0 L-- h* hCO UJ O CL lu * fn < CD C0 2 Q_ <0 < < LU <OXQ O) ho> T- (D O 00 O in co *" t i i i ii iiiii>iii ii<i>iiii MM-0 O O O X< C0M 0O O o X < 0 O I-- 0 0 CO 0< 0 < O O Oo 0o 3X b CL 2b 00 0 0 h- O CO < LU -1 CO CL CO UJ < CL O) NO) h-* CM oo O CD CO 1 1 1 1 1 1 1iJ111111 111 0 M- CM O X< C0M M- CM O X< 0 3 0 0 X 0 < 0 X < 0 o h" CO i LU CD CO i <i o 00 o> ii Is-. CM ion r-. i*iiiiiiiiiiii CO iii 0 0 o o O X< o 0 0 o o o X< < o 0 So P ox z< 5* <o 0Q 90 og X0 X oo 00 c</3 9x i<- X o 0oi rr. 0 h- 1-- 0> 0 0X0 co yj co 0>0 <0< 00 o> V OO CM O 00 CO T-- 11 1 1 1 1 1 1 111 ItI11111111 111 139 o < CO O Q LL. LL O NONE NONE CURRICULUM VITAE OF JOHN E. CRAIGHEAD, M.D. Wanda Joe McReynolds et al. V. U.S. Gypsum Company, et al Cause No. 0101021B Defendant's Exhibit List % T-- h- 1! Oin) \o ! CM Q CD O) ! CD ; co * cn J T- Z CO CM | CM 1 CM !! C^M LU O ! O 1 o 0. ' CL i 0. < :ti < !11 < i co i CM Z in CD <j) s S CloD { CD :! CD ! t-- o CO ; cm CM ! CM ! CM LU CD O !O 1o OL : cl ! CL < \< !< CO 00 o ! CO CM ! co T-- ! CM O' | co CM 1 CM O 1O O. 1 LL < 1ii < CM ! CM CD CM !i 0LO5 T-- ! CM O' CM !! CnM o !O CL : cl < 1< o o o 5 < cr T-- O o o < ir DC < Q LU CL LU Z LU Z Z< >01- h- > <' 33COO dc I- C<L < < I o CO co DC < CL LU 0 X <_l DC L- LU oo 0> X0 N LU DC L-- ctuo co O C<O I-- ac 0. o CL CO ID DC CO z o W LU t DC LL < o CL CO 0Q Z I-- < CO 3 Q Z CO CO < 3 O Q LU CO CO > LU DC 2 CL o ohOQ<o-: > OO O OO CM 3o aj 6ro Q co LU LU LL CO CO _<l z< LU _l CL < C/3 D CO OTC0--M0) o O UJ o LU CL 0 I-- DC DC Cl Z o iI ii ;: O, Oiu ; : i-- i : ?o occ i11 i11 CL CL i\ !I co GO !1 1I T-- : i:: itiii !iiti o iiiii i>iii i j 5- J! it*iii<iiiii iiiiiiiiii iiiiiiii -1 o co _i --<1 <P DuCu o< < LU 2 DC CO O h" CO CO UJ UJ CD Xi-- CO < z C0oT-->O0 0o0 CoO COM' T" 11111111 1 111t11111 11111t1111111l11111111 coCoDo LU CL DC LU I-- CO DC LU > o o H z: _l < 3 z o< CL 2 CO Go>O oo TT--" CO T~ >tiiiii i iiiiii iitiiiiitii iiiiiiiiiiii<i> 0CoD0o LU Q. oc O LU I- CO a: O U>J co CD CD o DC o h- z _l < 3 z Ul CD o 1-- o<o CL 2 o CO CoO> oo--1 "r" o< --) u_ o LU ll _l UJ 11t111 1 I11 z o CO DC UJ CL 11 111111111 I iiiii111tir iii i i 1 in iiiiiiii iir ti iiiitiiii i tiiiiiiiiii iii 146 - to CD >* C CO Q. Eo O E 3 CO &50 CO o CoM CO 3X LLI CO OV CO c 0 Cl) 0 -O CO c CO 3 0 >40-- o c O 0 Q >* aa:) o CD O 5 CO "O c CO Q < CO O a LL a z LU LU zo % Z o LU LU z o CD q x: 0. z' oa: Zo 2 CL DC O a: o in O LU LU < Q 3 O a; DC 3 o LU S Q to o ai ro O h- Q NO. 01-01021-B WANDA JOE MCREYNOLDS, ET AL., Plaintiffs, VS. U.S. GYPSUM COMPANY et al., Defendants. IN THE DISTRICT COURT DALLAS COUNTY, TEXAS 44TM JUDICIAL DISTRICT ALCOA INC.'S CERTIFICATE OF WRITTEN DISCOVERY I hereby certify that a true and correct copy ofthe following instrument was forwarded to all known parties of interest this the ^ day of June, 2001, via United States Mail. 1. Alcoa's Responses to Plaintiffs Rule 194 Request for Disclosure. Respectfully submitted. KENNETH D. MORRIS State Bar No. 00791303 FORMAN, PERRY, WATKINS, KRUTZ & TARDY, PLLC 1349 Empire Cental, Suite 400 Dallas, Texas 75247 Telephone: (214)905-2924 Facsimile: (214)905-3976 ATTORNEYS FOR DEFENDANT ALCOA INC. Of Counsel: Ronald B. Walker WALKER, KEELING & CARROLL, L.L.P. 210 E. Constitution Victoria, TX 77902 (361)576-6800 (361)576-6196 (fax) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served by hand delivery, telephonic document transfer, certified mail, return receipt requested, or regular mail to all parties on this the If* day of June, 2001. KENNETH D. MORRIS