Document 719VgQzkpkg730VJp0Qe43y5R

PLAINTIFF'S EXHIBIT CEL-489 CAUSE NO. 97-0844-E JOSE J. CANO, JR., Individually and as Personal Representative of the Heirs and Estate of JOSE J. CANO, SR., Deceased and MARIA CANO; RUBEN EURESTE; and VELENA FAY MOORE, Individually and as Personal Representative of the Heirs and Estate of LEO MOORE, Deceased Plaintiffs vs. OWENS CORNING, et al., Defendants IN THE DISTRICT COURT DALLAS COUNTY, TEXAS 28th JUDICIAL DISTRICT DEFENDANTS CNA HOLDINGS, INC. AND CELANESE LTD.'S FIRST SUPPLEMENTAL RULE 194 DISCLOSURES In accordance with Rule 194 of the Texas Rules of Civil Procedure, and as a supplement to Plaintiffs' Request for Disclosure, Defendants CNA Holdings, Inc. and Celanese Ltd. provide the following: (a) CNA Holdings, Inc. (f/k/a HNA Holdings, Inc.); Celanese Ltd. (collectively "Celanese"). (c) Celanese owed no duty, legal or otherwise, to plaintiff and is therefore not liable for any ofplaintiff's alleged injuries or damages. (e) See Defendants' Designation of Trial Witnesses and Exhibit A thereto, which was served on plaintiff on May 12, 2000. (f) See Defendants' Designation of Expert Witnesses and attachments thereto, served on plaintiff on May 12, 2000. Defendants' Medical Experts will or have been provided with the records referenced in subpart (k) below and any x-rays. Defendants' CNA Holdings, Inc. and Celanese Ltd.'s First Supplemental Rule 194 Disclosures - Page 1 (k) Celanese is in possession of various medical records of plaintiff Jose Cano by virtue of authorizations furnished by him. Please see the lists of those records below. Because the records are voluminous, they are not being produced herewith. The records are available, however, for inspection and copying during regular business hours at the offices of Rose* Walker, L.L.P., 1701 N. Market Street, Suite 200; Dallas, TX 75202. 1. Records from Pulmonary & Critical Care Consultants of Austin (Drs. Frank Mazza and Paul Harford) 2. Records from Doctor's Regional Medical Center/Corpus Christi Medical Center Hospital 3. Records from Riverside Hospital (now Columbia NW Hospital) 4. Records from Dr. Albert Wood Respectfully submitted, Ja rviA. Will'-------- NonaB. Walker State Bar No. 19890600 RoseWalker, L.L.P. 1701 N. Market Street, Suite 200 Dallas, Texas 75202 214.752.8600 (phone) 214.752.8700 (facsimile) Michael E. Hutchins Hawkins & Parnell, L.L.P. 4000 Sun Trust Plaza 303 Peachtree Street, N.E. Atlanta, Georgia 30308-3243 404/614-7400 Telecopy: 404/614-7500 ATTORNEYS FOR DEFENDANTS CNA HOLDINGS, INC. (F/K/A HOECHST CELANESE CORPORATION, F/K/A CELANESE CORPORATION) AND CELANESE LTD. Defendants' CNA Holdings, Inc. and Celanese Ltd.'s First Supplemental Rule 194 Disclosures - Page 2 CERTIFICATE OF SERVICE In accordance with Rule 21 of the Texas Rules of Civil Procedure, the foregoing Supplemental Rule 194 disclosures have been served upon the following counsel for Plaintiff by hand delivery on this day of May, 2000: Russell Budd Melissa Hutts Holly Huart Stephanie Finch Baron & Budd, P.C. 3102 Oak Lawn; Suite 1100 Dallas, TX 75219 Nona Walker I:\CELANESE\HC - Cano\Discovery\Supplemental Designations.WPD Defendants' CNA Holdings, Inc. and Celanese Ltd.'s First Supplemental Rule 194 Disclosures - Page 3