Document 6bVpDYzxB54OE6Yg0vyZJNBOR
NO. 90G2055
WELDON R. MOAKE, and JANICE I. MOAKE; KEVIN R. MOAKE; DANA R. ASHLEY; and MACK K. MOAKE;
Plaintiffs,
VS.
OWENS-CORNING FIBERGLAS CORPORATION (a/k/a OWENS CORNING CORPORATION), et al.,
Defendants.
IN THE DISTRICT COURT BRAZORIA COUNTY, TEXAS 239TH JUDICIAL DISTRICT
REYNOLDS METALS COMPANY'S SUPPLEMENTAL RESPONSES TO PLAINTIFFS' REQUEST FOR RULE 194 REQUEST FOR DISCLOSURE Defendant Reynolds Metals Company ("Reynolds"), by counsel, pursuant to Rule 194 of the Texas Rules of Civil Procedure, responds as follows to Plaintiffs Request for Disclosures: A. The correct names of the parties to the lawsuit. Reynolds states that its correct name is Reynolds Metals Company; it is without knowledge as to the correct names of the other parties to the lawsuit. B. The name, address, and telephone number of any potential parties. At this time, Reynolds is aware not aware of any "potential parties." Reynolds reserves the right to supplement its response to this request. C. The legal theories and, in general, the factual bases of the responding party's claims. Reynolds refers plaintiffto its Special Exceptions, Original Answer and Affirmative Defenses to Plaintiffs' First Amended Asbestos Petition. Reynolds expects that its defense will be based on documentary and testimonial evidence (including lay and expert testimony) that:
Plaintiffs' claims against Reynolds are barred by the statute of limitations, as explained in Reynolds' Motion for Summary Judgment;
Plaintiff Moake was not exposed to harmful levels of airborne asbestos fibers on any premise owned, operated and/or controlled by Reynolds;
Plaintiff Moake has no asbestos-related illness or injury, as explained in the expert reports of Dr. Mark Wick and subsequent reports from other experts. This portion of this answer may need to be supplemented because ofplaintiffs' failure to provide medical records in a timely fashion;
Reynolds did not owe a legal duty to protect Plaintiff Moake against hazards incident to his work, as explained in Reynolds' Supplemental Motion for Summary Judgment;
Plaintiff Moake and/or his employer - who marketed and sold asbestos-containing products to Reynolds and installed those products - were in a superior position to know about and protect against potential health hazards associated with the inhalation of airborne asbestos fibers and they, in fact, knew or should have known about such potential hazards. As a supplier of asbestos-containing products, plaintiff and his employer are considered by law to be experts and are charged with the knowledge of any dangers associated with the products they sold. To the extent that Plaintiffs claim that Reynolds should have known of such hazards, then Plaintiff Moake and his employer should also. Documents from the National Insulation Manufacturers' Association and the National Insulation Contractors' Association bear this out.
Reynolds was not negligent; and
Plaintiff Moake was contributorily negligent, because he knew or is charged with knowing that asbestos exposure was associated with health hazards and, according to his testimony, took no steps to protect himself, his employees or Reynolds' employees from harm.
If Plaintiff Moake was exposed to harmful levels of asbestos while on Reynolds' property, such exposure resulted from the acts of other persons or entities for which Reynolds was not legally responsible, such as other contractors.
. The name, address, and telephone number of persons having knowledge of relevant facts, and a brief statement of each identified person's connection with the case.
Investigation is ongoing in this matter, and, at this time, Reynolds does not know each and
every individual who has knowledge of the relevant facts. Reynolds therefore reserves the right to
supplement its response to this Request in accordance with Rule 193 of the Texas Rules of Civil
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Procedure. At this time, Reynolds identifies the following individuals who may have knowledge of
relevant facts and who Reynolds may call to testify at the trial of this matter:
1) Plaintiffs
a) Weldon R Moake 1040 Laurel Oak Drive, Flower Mound, Texas 75208 (972)539-6966
b) Janice I. Moake 1040 Laurel Oak Drive, Flower Mound, Texas 75208 (972)539-6966
c) Kevin R Moake 528 Raintree Circle Coppell, Texas 75019 (972)462-0543
d) Dana R Ashley 5233 Tarton Corpus Christi, Texas 78413 (361) 992-7225
e) Mack K. Moake 601 Knobview Drive Shelbyville, Kentucky 40065 (502) 633-4142
2) Any and all Family Members of the Plaintiffs
3) Plaintiff Moake's Treating Physicians. Reynolds may any or all of Plaintiff
Moake's treating physicians as trial witnesses to offer testimony, including expert testimony, about
their care, treatment and diagnosis of Plaintiff Moake. At this time, Reynolds names the following
physicians identified in Mr. Moake's deposition:
Dr. Daniel Jackson 6560 Fannin, #1130 Houston, Texas 77030
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Dr. Dennis Costa 475 West Elm, Suite 101 Lewisville, Texas 75057
Dr. Glenn Genevese 651 Cross timbers, Suite 104 Flower Mound, Texas 75028
Dr. Art May 614 Edmonds Lane, Suite 101 Lewisville, Texas 75067
Dr. Bobby Chu 1001 Cross Timbers, Suite 1250 Flower Mound, Texas 75028
Dr. Alois Francis Keil 3130 S. Alameda Corpus Christi, Texas 78404
Dr. M.H. Blaine 3314 South Alameda Corpus Christi, Texas
Dr. Fred B. Brackett 613 Elizabeth, Suite 612 Corpus Christi, Texas 78404
Dr. Donald Iden 4521 South Staples Corpus Christi, Texas 78411
Dr. David Garza Corpus Christi, Texas
Dr. Charles Hedberg 613 elizabeth, Suite 604 Corpus Christi, Texas 78404
Dr. John Richard Porter 612 Elizabeth Street Corpus Christi, Texas 78404
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Dr. Paul Heath 1521 South Staples, Suite 704 Corpus Christi, Texas 78404
Dr. Sergio Tavares 612 Elizabeth Street, Suite 302 Corpus Christi, Texas 78404
Dr. Moon Dong Shin 1515 Holcombe Boulevard Houston, Texas 77030
Dr. Garrett L. Walsh 1515 Holcombe Boulevard Houston, Texas 77030
Dr. Katherine Pisters 1515 Holcombe Boulevard Houston, Texas 77030
Dr. Lyle Lloyd Brown 319 North Bonnie Brae Denton, Texas 76201
Dr. Donald E. Schwarz Presbyterian Hospital of Dallas 8200 Walnut Hill Lane Dallas, Texas 75231
Dr. Clark Byroad 575 North Valley Parkway, Suite 100 Lewisville, Texas 75067
Dr. Alan Rueben 9323 Garland Rd. Dallas, Texas 75218
Dr. Kenneth Goldberg 514 W. Main Street Lewisville, Texas 75057-0366
4) Coworkers. Reynolds may call Plaintiff Moake's coworkers including but not
limited to the following persons:
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Jack Hoover 2642 Tulane Drive Corpus Christi, Texas 78414 (361)937-1989
Marvin E. Wuensche 409 East Elizabeth Kingsville, Texas 78363 (361)592-6227
James Ford 303 Magdalena Drive Victoria, Texas 77904 (361)575-7863
Leroy Verdine 207 Beachwood Victoria, Texas 77901 (361)578-2057
L.D. Watkins 10402 Birdwood Corpus Christi, Texas 78410 (361)241-1647
Kenneth Kemp 204 Primerose Victoria, Texas 77904 (361)573-4878
Michael Dale Byerley RR2, Box 42 A-l Mathis, Texas 78368 (361)547-5561
Jack D. Westbrook P.O. Box 897 Odem, Texas 78370 (361)368-9037
Glen A. Curfman HC 70, Box 5879 Three Rivers, Texas 78071 (361)786-3007
David Salinas P.O. Box 301 Alice, Texas 78333 (361)777-2269
5) Reynolds Personnel/Witnesses
(a) Sherwin Alumina Plant Personnel. Reynolds may call some or all of the
following individuals who were employed at various times at the Sherwin Alumina Plant to testify
as to their personal knowledge concerning plant operations and plant conditions; the use of
asbestos-containing products in plant operations; the elimination and abatement of asbestos;
Reynolds' safety procedures, both in general and as they relate to asbestos (including the use of
respirators); Plaintiff Moake's potential for asbestos exposure; the contracts under which Plaintiff
Moake and his employer, Thorpe Insulation Company, sold and installed products at Reynolds'
plants; and, other matters relevant to plaintiffs claims and/or Reynolds' defenses:
Dr. John Frandolig RR1, Box 358 Lake Geneva, WI 53147
Dr. Frandolig was the Sherwin Alumina Plant Medical Director from 1989-91. He may be called to testify about his knowledge regarding Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about his knowledge related to asbestos exposure procedures.
Dr. Guy Racette 8122 Deck Street Corpus Christi, TX 78412
Dr. Racette was the Sherwin Alumina Plant Medical Director from 1991-93. He may be called to testify about his knowledge regarding Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about his knowledge related to asbestos exposure procedures.
Dr. Wendell Roberts 620 West Johnson Avenue Arkansas Pass, TX
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Dr. Roberts is the current Sherwin Alumina Plant physician. He may be called to testify about his knowledge regarding Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses.
Deloris Ulke Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Ms. Ulke was the Head Nurse at Sherwin Alumina Plant Medical Department. She may be called to testify about her knowledge about Reynolds' attitude toward employee health in general, as well as general information regarding the Medical Department at the Sherwin Alumina Plant. She may also be called to testify about her knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses.
C. Arlon Boatman Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Boatman is the Health & Safety Manager for the Sherwin Alumina Plant who may be called to testify about his knowledge of Reynolds' safety procedures and the use of asbestos-containing products at the Sherwin Alumina Plant, as well as other information. He may also be called to testify about the operation of the Sherwin Alumina Plant Medical Department, including the Respiratory Surveillance Program. He may also be called to testify about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses.
Terry N. Roubidoux Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Roubidoux was the Safety Coordinator for the Sherwin Alumina Plant from 1992-June 1997. He is currently the Area II Business Unit Superintendent at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures and the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. He may also be called to
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testify about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses.
A.S. "Stan" Millsap 5541 Bear Lane, Ste. 236 Corpus Christi, TX 78405
Mr. Millsap was the Safety Coordinator at the Sherwin Alumina Plant. He may be called to testify about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding OSHA and MSHA requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be called to testify about his knowledge regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training. He may further be called to testify about his knowledge of asbestos abatement at the Sherwin Alumina Plant.
Darrell L. Lentz 2406 West Frank Street Apartment 114 Lufkin, Texas (409) 632-9345
Mr. Lentz was the Safety Director at the Sherwin Alumina Plant from 1977November 1982. He may be called to testify about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding OSHA and MSHA requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be called to testify about his knowledge regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training. He may further be called to testify about his knowledge of asbestos abatement at the Sherwin Alumina Plant.
Ernest L. Sweet 114 Glenwood Drive Liverpool, New York 13090 (315) 652-6543
Mr. Sweet was the Superintendent for Environmental Health and Safety from 1980- October 1985. He may be called to testify about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding OSHA and MSHA requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be called to testify about his knowledge regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training. He
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may further be called to testify about his knowledge of asbestos abatement at the Sherwin Alumina Plant.
William E. Hamblin Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Hamblin was a Senior Maintenance Engineer at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Lou Suffredini Austin, Texas
Mr. Suffredini was the Plant Manager of the Sherwin Alumina Plant. He was employed at the Sherwin Alumina Plant from the early 1950s-1977. He may be called to testify about his knowledge of Reynolds' safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Timothy D. Woods Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Woods is the Plant Controller at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Frank Strickland Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Strickland is the Purchasing Manager for Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
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D. T. Greeson Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Greeson is a Purchasing Agent for Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
James C. Tiffany Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Tiffany was the Plant Engineer at the Sherwin Alumina Plant from approximately 1973-76 and was a General Engineer, Maintenance Superintendent, and Senior Engineer for various periods from 1964-73 and 1985 to the present. He may be called to testify about his knowledge of the use of products that contained asbestos, the elimination of some asbestos-containing products, and asbestos abatement. He may also be called to testify about his knowledge of Reynolds' safety procedures, and use of safety equipment at the Sherwin Alumina Plant, as well as other information.
Jack C. Oates Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Oates was the Plant Engineer at the Sherwin Alumina Plant from 1980-84 and was Maintenance Engineer, Project Engineer, and Project Manager for various periods between 1967-74 and 1977-91. He is currently the Senior Engineering Supervisor at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant. He further may testify regarding Thorpe Insulation's work at the Sherwin Plant, including, but not limited to, the scope of Thorpe Insulation's work and the nature of the relationship between Thorpe Insulation and its employees and Reynolds. He also may testify as to other relevant information within the scope of his personal knowledge.
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Howard Grote Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Grote has been Project Engineer and Maintenance Engineer for various periods of time between 1970 and the present. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant. He further may testify regarding Thorpe Insulation's work at the Sherwin Plant, including, but not limited to, the scope of Thorpe Insulation's work and the nature of the relationship between Thorpe Insulation and its employees and Reynolds. He also may testify as to other relevant information within the scope of his personal knowledge.
Ed Peterson Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Grote has been in the Engineering Department at Reynolds' Sherwin Plant since 1973. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant. He further may testify regarding Thorpe Insulation's work at the Sherwin Plant, including, but not limited to, the scope of Thorpe Insulation's work and the nature of the relationship between Thorpe Insulation and its employees and Reynolds. He also may testify as to other relevant information within the scope of his personal knowledge.
Paul Matula Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Matula is a Designer in the Engineering Department of Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
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Mario Rivera Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Rivera was a maintenance supervisor in Area 50 of Sherwin Alumina Plant. He is currently in the Industrial Hygiene Department of the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Charles Chapman Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Chapman was a maintenance supervisor in Area 50 of Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Jeffrey Downs Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Downs is the current maintenance supervisor in Area 50 of Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Gary Cedotal Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Cedotal was the maintenance supervisor for Areas IV and V of the Sherwin Alumina Plant from 1989-93. He is currently the Shift Maintenance Supervisor. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
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Ernest Coulter Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Coulter was the Maintenance Supervisor and General Foreman in the Maintenance Department at the Sherwin Alumina Plant from 1963-90. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Ludwig Jahn Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Jahn has been the Maintenance Supervisor in the Maintenance Department at the Sherwin Alumina Plant since 1989. Prior to this position, Mr. Jahn held numerous jobs in the Maintenance Department in the 1970s. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Hector De La Garza Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. De La Garza is in the Environmental Department of the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Adan J. Villarreal Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Villarreal is a Cost Accountant at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment.
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the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Lester Charles Homan Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Homan is a Senior Accountant at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Ernest Boulware 215 Seco Portland, TX 78374
Mr. Boulware is a retired carpenter, laborer and maintenance mechanic from the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Frank Hall, Jr. 401 Rabbit Run Road Arkansas Pass, TX 78336
Mr. Hall is a building and trade mechanic, employed with the Sherwin Alumina Plant since the late 1950s. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Weldon Hesseltine Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Hesseltine is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1955. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
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Leroy Rhoads Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Rhoads is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1969. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, the involvement of the Union in safety matters at the Sherwin Alumina Plant, as well as other information.
Howard Cave Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Cave is a member of the Maintenance Department at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Ronald Hesseltine Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Hesseltine is a supervisor, employed with the Sherwin Alumina Plant. He worked as an hourly equipment cleaner from 1965-88. He was promoted to supervisor in 1988 and worked as a supervisor in Areas IV and V from 1994-96. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Jimmie Lehman Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Lehman is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work
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environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Howard Bittel Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Bittel is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1987. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Chuck Coulter Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Coulter is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Willie Enriquez Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Enriquez is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Mike Gonzales, Jr. Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Gonzales is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work
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environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
A. Littlejohn Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Littlejohn is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Tony Dunn Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469
Mr. Dunn was the Process Engineer at the Sherwin Alumina Plant from 1963-70 and was Technical Manager and Superintendent, and Operating Superintendent for various periods between 1974-76 and 1978-95. He is currently the Training Manager at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
(b) San Patricio Reduction Plant Personnel. Reynolds may call some or all
of the following individuals who were employed at various times at the San Patricio Reduction
Plant to testify as to their personal knowledge concerning plant operations and plant conditions; the
use of asbestos-containing products in plant operations; the elimination and abatement of asbestos;
Reynolds' safety procedures, both in general and as they relate to asbestos (including the use of
respirators); Plaintiff Moake's potential for asbestos exposure; the contracts under which Plaintiff
Moake and his employer, Thorpe Insulation Company, sold and installed products at Reynolds'
plants; and, other matters relevant to plaintiffs claims and/or Reynolds' defenses:
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Robert Dale Gamble, M.D. 5301 St Andrew Corpus Christi, Texas 78413 (512) 991-2985
Dr. Gamble was the San Patricio Reduction Plant and/or Sherwin Alumina Plant Medical Director from 1975-85. He has knowledge regarding the Respiratory Surveillance Program at the San Patricio Reduction Plant. He also may have knowledge of Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may have knowledge related to asbestos exposure procedures.
Harry R. Bratt, M.D. 2040 Birch Ave. Saint Helena, CA 94574
Dr. Bratt was the San Patricio Reduction Plant and/or Sherwin Alumina Plant Medical Director from 1971-75. He has knowledge regarding the Respiratory Surveillance Program at the San Patricio Reduction Plant. He also may have knowledge of Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may have knowledge related to asbestos exposure procedures.
Mr. E. W. Dressen 221 Blanco Portland, Texas 78374 (512)643-2104
Mr. Dressen was the an Engineer and Reduction Superintendent at the San Patricio Reduction Plant. He also was the acting plant manager of the San Patricio Reduction Plant from 1974-79 and from 1981 until the plant closed. He may have knowledge regarding plant operations; various applications of asbestos-containing products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; and Reynolds' attitude toward safety and employee health in general.
Kenneth E. Murphree 458 Caroline Acres Point Hot Springs, Arkansas 71913 (501) 525-3726
Mr. Murphee was the plant manager of the San Patricio Reduction Plant from 197981. He may have knowledge regarding plant operations; various applications of asbestoscontaining products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information.
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William E. Campbell 7746 East Laguna Azul Apartment #272 Mesa, Arizona 85208 (602) 357-9978
Mr. Campbell was the plant manager ofthe San Patricio Reduction Plant from 1972-77. He may have knowledge regarding plant operations; various applications of asbestos-containing products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information.
Mr. Harry V. Helton 509 Kilmarnock Drive Richmond, Virginia 23229 (804) 740-7705
Mr. Helton was employed at the San Patricio Reduction Plant from 1966-72 and held positions as potroom supervisor, general plant supervisor and, from 1971-72, plant manager. He may have knowledge regarding plant operations; various applications of asbestos-containing products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information.
Mr. Clyde Doyce Hester 546 Evergreen Drive Corpus Christi, Texas 78412
Mr. Hester was the chief chemist at the San Patricio Reduction Plant from 1953-89. He may have general knowledge about the plant processes, environmental issues (including asbestos abatement issues) and other information.
Mr. Allen G. Hill 418 Fetick Avenue Taft, Texas 78390-2808 (512) 528-2749
Mr. Hill was a chemist at the San Patricio Reduction Plant from 1967-85. He may have general knowledge about the plant processes, environmental issues (including asbestos abatement issues) and other information.
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Mr. William D. Pipes P.O. Box 148 Crozier, Virginia 23039 (804) 784-1250
Mr. Pipes held the following titles at the San Patricio Reduction Plant from 196677: process engineer, power plant supervisor; and maintenance superintendent. He also was the plant engineer from 1979-82. He therefore has personal knowledge ofthe plant design, construction and processes. He also has knowledge about the selection of independent contractors and the relationship of Reynolds to independent contractors and their employees. He may have knowledge about the use and application of asbestoscontaining products, elimination and/or substitution of asbestos-containing products, general health and safety issues and other relevant information.
Mr. Kenneth W. Younger 12604 Hardings Trace Court Richmond, Virginia 23233 (804)281-4111
Mr. Younger was a project engineer at the San Patricio Reduction Plant from 197077 and 1980-85. He may have knowledge about the use and application of asbestoscontaining products, elimination and/or substitution of asbestos-containing products, general health and safety issues and other relevant information.
Mr. Brice G. Nelson 1045 Wilshire Corpus Christi, Texas 78411 (512) 852-4535
Mr. Nelson was involved in the original construction and operation of the carbon plant at the San Patricio Reduction Plant, and he worked at the San Patricio Reduction Plant from approximately 1951-69, and from 1974-76. He may have knowledge regarding the construction and processes of the San Patricio Reduction Plant in general, the availability and use of personal protective equipment, general health and safety issues and applications of asbestos products in the plant.
Mr. Raymond L. Bennett 414 Reynolds Avenue Taft, Texas 78390 (512)528-3284
Mr. Bennett was the power plant supervisor at the San Patricio Reduction Plant from approximately 1953-84. He may have knowledge regarding plant operations in general and the operation of the power plant in particular. He also may have knowledge regarding applications of asbestos products in the power plant.
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Mr. John L. Massey P.O. Box 73 Bayside, Texas 78340 (512) 529-6692
Mr. Massey was a foreman in the San Patricio Reduction Plant maintenance department from approximately 1952-88. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use ofpersonal protective equipment, general health and safety issues and other relevant information.
Mr. James C. Black 224 Bafanridge Drive Hot Springs, AR 71901 (501) 624-7244
Mr. Black was employed at the San Patricio Reduction Plant as a potroom foreman from 1960-63. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues, and other relevant information.
Mr. Clyde A. Krueger 131 Granby Portland, Texas 78374 (512) 643-2421
Mr. Krueger was a general foreman at the San Patricio Reduction Plant from 195284. He may have general knowledge about the plant processes, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues.
Mr. William E. Shepp 244 Ross Road Kelso, Washington 98626 (360) 578-2429
Mr. Shepp was a potroom engineer and casthouse supervisor at the San Patricio Reduction Plant. He may have knowledge about the use and application of asbestoscontaining products, elimination and/or substitution of asbestos-containing products, general health and safety issues and other relevant information.
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Mr. Harold L. Bern, Jr. 2341 East Lynnwood Drive Longview, Washington 98632 (206)425-8082
Mr. Bern was the Personnel Manager at the San Patricio Reduction Plant from 1979-82 and may have knowledge about information relevant to this lawsuit.
Mr. Joel W. Whitlock 6837 SE Cottrell Road Gresham Oregon 97080-8911 (503) 663-2096
Mr. Whitlock was employed at the San Patricio Reduction Plant from 1958-71 and, during that time, held the following titles and positions: potroom general clerk; potroom foreman; anode foreman; pot relining supervisor; maintenance supervisor and plant safety engineer. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues, and other relevant information.
Mr. Jack H. Norris, Jr. 4318 St George Corpus Christi, Texas 78413 (512) 853-1021
Mr. Norris was a purchasing agent at the San Patricio Reduction Plant from 1976-86 and plant purchasing manager from 1986-88. He may have knowledge about the purchase, use and application of asbestos-containing products and/or substitutes for asbestoscontaining products, the purchase and use of safety equipment (including respirators), asbestos abatement and other relevant information.
Richard C. Easterline 15 Serra Lane Massena, New York 13662 (315) 769-1996
Mr. Easterline was employed at the San Patricio Reduction Plant from 1968-82 and held positions as an engineer and carbon services supervisor. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues, and other relevant information.
John W. Ford do Reynolds International
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P.O. Box 27002 Richmond, Virginia 23261 (503) 666-0203
Mr. Ford was the plant maintenance supervisor at the San Patricio Reduction Plant from 1979-83. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use ofpersonal protective equipment and general health and safety issues, and other relevant information.
(c) Reynolds Corporate Personnel. Reynolds may call some or all of the
following individuals to testify regarding their personal knowledge on matters of safety, medical
and industrial hygiene issues on the corporate level and/or at the Sherwin and/or San Patricio plants
specifically; plant operations and conditions; the use, elimination and/or substitution of asbestos-
containing products; and, on other matters relevant to plaintiffs claims and/or Reynolds' defenses:
Dr. Woolson W. Doane 14 Runswick Drive Richmond, Virginia 23233-5413
Dr. Doane was Reynolds' Corporate Medical Director from 1993-June 1997. He may be called to testify about his knowledge concerning corporate medical issues and the Respiratory Surveillance Program at the Sherwin and San Patricio plants.
David Warren, M.D. 8705 Taiytown Drive Richmond, Virginia 23229
Dr. Warren was the acting Corporate Medical Director from 1992-93. He may be called to testify about his knowledge concerning corporate medical issues and the Respiratory Surveillance Program at the Sherwin and San Patricio plants.
E. Claiborne Irby, M.D. 11-1/2 Tapoan Road Richmond, Virginia 23226
Dr. Irby was an Associate Corporate Medical Director from 1959-77, and Corporate Medical Director for Reynolds from 1977 until his retirement in 1992. He may be called as a factual witness, but because he also qualifies as an expert, he may offer expert, he may offer expert testimony in the fields of occupational medicine, state-of-the-art, governmental regulations, and medical issues in general as they may relate to occupational asbestos exposures.
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James MacMillan, M.D. 306 Gunby Drive Richmond, Virginia 23229
Dr. MacMillan was the Corporate Medical Director of Reynolds from 1956-77. He may be called to testify about his knowledge concerning corporate medical issues and the Respiratory Surveillance Program at the Sherwin and San Patricio plants.
Mr. Homer Mac Cole Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 (804) 281-3506
Mr. Cole is the Corporate Director of Industrial Hygiene and Toxicology at Reynolds. He has been an industrial hygienist at Reynolds since 1972. Mr. Cole performed industrial hygiene surveys at the Sherwin and San Patricio plants and may testify regarding such surveys as well as other factual matters based on his personal experience and knowledge, including, but not limited to, plant conditions, various uses of asbestos-containing products in plant applications, the elimination and substitution of asbestos-containing products, and general issues related to industrial hygiene and safety. Although Mr. Cole will testify as a factual witness, he qualifies as an expert and may offer expert testimony in the fields of industrial hygiene, occupational health and safety, state-of-the-art, governmental regulations of workplace exposures, threshold limit values, the measurement of occupational asbestos exposures as well as other potential occupational hazards, respiratory protection, and proper work practices.
Mr. Ronald E. Benton Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230
Mr. Benton is Manager of Industrial Hygiene and Safety Services at Reynolds. He has been at Reynolds since 1974. He performed industrial hygiene surveys at the Sherwin and San Patricio and may testify regarding such surveys as well as other factual matters based on his personal experience and knowledge. Mr. Benton may testify as a factual witness, but because he qualifies as an expert, he may offer expert testimony in the fields of industrial hygiene, occupational and environmental health and safety, state-of-the-art, governmental regulations of workplace exposures, threshold limit values, the measurement of occupational asbestos exposures as well as other potential occupationsl hazards, respiratory protection, and proper work practices.
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Ms. Linda Maillet Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230
Ms. Maillet was the Regional Industrial Hygienist at the Corporate Headquarters of Reynolds for the Eastern Region. She is currently the Principal Health, Safety and Regulatory Affairs Scientist at the Corporate Headquarters.
Ms. Laurie Shelby Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230
Ms. Shelby was the Manager of Industrial Hygiene Programs at the Corporate Headquarters of Reynolds. She is currently the Manager of Health and Safety Programs.
Mr. Richard Mansur 1416 Coronet Drive Richmond, Virginia 23229-4806 (804) 282-4438
Mr. Mansur was the Manager of the Industrial Hygiene Department at the Corporate Headquarters of Reynolds from 1969-75.
Mr. James D. Davidson
Mr. Davidson was a Stafflndustrial Hygienist at the Corporate Headquarters of Reynolds from 1976-82.
Ms. Stacey Hansen 12701 Mirror Pond Way Midlothian, Virginia 23113 (804) 794-1736
Ms. Hansen was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1990-93.
Mr. Dale Prokopchak 2704 Empress Court Richmond, Virginia 23233 (804) 360-3301
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Mr. Prokopchak was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1988-89.
Ms. Deborah R. Hudgins
Ms. Hudgins was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1984-88.
Mr. Harry L. Skalsky 6910 West Grace Street Richmond, Virginia 23261
Mr. Skalsky was a Medical Corporate Toxicologist at the Corporate Headquarters of Reynolds 1979-85.
Ms. Karen Kestle 1336 Merrymeade Avenue Glen Allen, Virginia 23060 (806) 264-1789
Ms. Kestle was the Senior Insurance Administrator at the Corporate Headquarters of Reynolds.
Mr. Bobby J. Sasser
Mr. Sasser was the Corporate Safety Director for Reynolds from 1973-95.
Mr. Joseph Nichols 2300 Cedarfleld Parkway Apartment 161 Richmond, Virginia 23233 (804) 282-8245
Mr. Nichols was the Corporate Safety Director for Reynolds from 1945-73.
(c) Other Reynolds' Witnesses
Service Environmental Co. P.O. Box 2355 Beaumont, TX 77704
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Service Environmental Co. may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of
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products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Industrial Specialist Inc. P.O. Box 1630 Lake Jackson, TX 77569
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Industrial Specialist Inc. may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Estes Refractory & Insulation 6300 Highway 70 N. P.O. Box 600 Belle Rose, LA 70544
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Estes may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
TGI Stephens 777 N. Eldrige, Suite 315 Houston, TX 77079
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of TGI Stephens may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Thermo Tech Inc. P.O. Box 3109 Orange, TX 77631
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Thermo Tech may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
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Gilman Insulation Co. P.O. Box 4074 Corpus Christi, TX 78469
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Gilman Insulation may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Falcon Associates P.O. Box 7777 Philadelphia, PA 19175
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Falcon Associates may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Brand Remediation Services, Inc. 1914 Austin Street Orange, TX 77630
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Brand Remediation may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Northwinds Abatement, Inc. 903 Port Houston Street Houston, TX 77029
Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Northwinds Abatement may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Casanova Industrial Insulation P.O. Box 4761 Corpus Christi, TX 78408
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Performed insulation and/or asbestos abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Cassanova Industrial may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Northwest Envirocon, Inc. 16811 El Camino Real Suite 119 Houston, TX 77058
Performed asbestos audits and abatement work at the Sherwin Alumina Plant. Accordingly, certain agents or employees of Northwest Envirocon may be called to testify concerning Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information.
Alex Baca Baca Safety Consulting 6214 Battery Lane San Antonio, Texas 78233 (210) 657-0705
Mr. Baca is a retired inspector for the United States Department of Labor Mine Safety Health Administration. He was a Federal Mine Safety and Health Inspector from 197 until January, 1998 with duties to enforce the Safety and Health Regulations on Mining Operations and to gain compliance with such regulations. Pursuant to this position, Mr. Baca inspected the Sherwin Alumina Plant. Mr. Baca may testify regarding such inspections as well as to other factual matters based on his personal experience and knowledge.
Robert E. Ruckstuhl Proactive Safety Consultants Company, Inc. Post Office box 260955 Corpus Christi, Texas 78426-0955 (512) 767-1663
Mr. Ruckstuhl is a consultant who specializes in the area of asbestos safety and training. He has performed consulting functions and training seminars related to asbestos safety and asbestos abatement issues at the Sherwin Alumina Plant and may testify regarding such consulting services and training seminars as well as other factual matters based on his personal experience and knowledge.
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6) Records Custodians. Reynolds may call, live or by deposition or affidavit, various
records custodians to authenticate relevant records, including, but not limited to, the records of Mr.
Moake's medical care providers and the records of his employers:
William Stephen Custodian of Records for Kenneth Goldbert, MD, Medical Records Department
Yvonne Garcia Medical Records Clerk for Paul W. Heath, MD
Leona M. Gunter Medical Records Custodian for Fred Brackett, MD
Emily J. Graves Medical Records Custodian for Lyle Lloyd Brown, MD
Rose Herrera Medical Records Custodian for Richard Porter, MD
Clark Claire Byroad Medical Records Custodian for Clark Byroad, MD
Tania Honeycutt Medical Records Custodian for Glenn Genovese, MD
Tammy Walls Medical Records Custodian for Bobby Chu, MD
Sharon Grayum Records Custodian St Luke's Episcopal Hospital 6720 Bertner, #Y-115, Houston, Texas 77030
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Nicole Mathis Medical Records Custodian/Manager The University of Texas M.D. Anderson Cancer Center 1515 Holcombe Btvd., Houston, Texas 77030
Mary L. Yancy Custodian of Records for Pathology M.D. Anderson Cancer Center 1515 Holcombe Blvd., Houston, Texas 77030
Rebecca Woods Custodian of Records Spohn Hospital Shoreline
Paul Gutierrez Custodian of Records Kelsey-Seybold Clinic/Dr. Friedwald 1111 Augusta Drive, Houston Texas 77057
Barbara J. Schwarz Custodian of Records University of Texas M.D. Anderson Cancer Center, Department of Pathology Box 085,1515 Holcombe Blvd., Houston, Texas 77030
Deborah Montelongo Custodian of Records Cardiovascular Associates/Dr. Sergio Tavares 613 Elizabeth St, Corpus Christi, Texas 78404
Jean M. Wolak Custodian of Records Medical Center of Lewisville 500 W. Main St., Lewisville, Texas 75057
7) Other Witnesses. Reynolds reserves the right to call and/or elicit testimony from
any individual identified by plaintiff and any other party to this lawsuit. At this time, Reynolds
further expects to call as witnesses the following individuals:
Melvin Proctor
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Tyson Miller Leonard Donohue Ron Tomg J. T. Thorpe (corporate representative) A Bechtel witness or witnesses knowledgeable about Bechtel's work at Reynolds' Sherwin and San Patrico Plants A Lummus witness or witnesses knowledgeable about Lummus' work at Reynolds' Sherwin and San Patricio Plants A Stearns and Rodgers witness or witnesses knowledgeable about Stearns and Rogers' work at Reynolds' Sherwin and San Patricio Plants. 8) Rebuttal/Impeachment Witnesses. Reynolds reserves the right to call rebuttal and/or impeachment witnesses and will supplement its response to this request if and when it has sufficient information to determine the need for such testimony. F. For any testifying expert: (1) The expert's name, address, and telephone number; (2) The subject matter on which the expert will testify; (3) The general substance of the expert's mental impressions and opinions and
a brief summary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; (4) If the expert is retained by, employed by, or otherwise subject to the control of the responding party:
(A) 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.
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Reynolds refers plaintiffs to its designation of expert witnesses served on or about August 28, 2000. Materials provided to expert witnesses will be made available for inspection at a mutually convenient time and place. G. Any discoverable indemnity and insuring agreements.
Reynolds has insurance coverage sufficient to cover plaintiffs' claims with the following insurance companies:
Travelers Insurance (9/30/53 through 9/30/66); and Liberty Mutual Group (9/30/66 through 9/30/78). I. Any discoverable witness statements. None. K. All medical records and bills obtained by the responding party by virtue of an authorization furnished by the requesting party. Subject to plaintiffs agreement to pay Reynolds one-half of its cost in retrieving these records, Reynolds will produce these records at $.30 per page or will make them available to plaintiffs counsel for inspection and copying at a mutually convenient time and place.
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REYNOLDS METALS COMPANY,
David Craig Landin (Texas Bar No. 11863720) John D. Epps (Texas Bar No. 00796079) Eric G. Reeves (Texas Bar No. 24026170) HUNTON & WILLIAMS
951 East Byrd Street Riverfront Plaza, East Tower Richmond, Virginia 23219 (804) 788-8200 (804) 788-8218 (facsimile)
R. Clay Hoblit (Texas Bar No. 09743100) CHAVES, GONZALES & HOBLIT, L.L.P. 2000 Frost Bank Plaza 202 North Carancahua Corpus Christi, Texas 78470 (512) 888-9392 (512) 888-9187 (facsimile)
CERTIFICATE OF SERVICE
I hereby certify that on September 22, 2000, a true and correct copy of the above and
foregoing instrument is being served by certified mail, return receipt requested, on the following
Plaintiffs' counsel:
William K. Tapscott, Esq. Baron & Budd, P.C. The Centrum, Suite 1100 3102 Oak Lawn Avenue Dallas, Texas 75219
All other known counsel of record are given notice of this pleading by regular United States mail
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