Document BRaEdV0a6g8ek65GOLXvwzvjJ

---- \i_r% UIO i. ^t.cr\r\ CAUSE NO. 2000-05-1962-C JAN 1 8 2001 COUNTY,TEXAS ROBERT HENRY VILLARREAL. Individually and as Personal Representative of the Heirs and Estate of JOHN HENRY VILLARREAL IN THE DISTRICT COURT OF Plaintiffs, vs. CAMERON GAF CORPORATION HOLDINGS. INC.), ET AL. Defendants. 197th JUDICIAL DISTRICT DEFENDANT UNION CARBIDE CORPORATION d/b/a UNION CARBIDE CHEMICALS AND PLASTICS. INC.'S FIRST AMENDED LIST OF POTENTIAL FACT/EXPERT WITNESSES Defendant Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc.'s fc List of Potential Fact/Expert Witnesses and Deposition Testimony to the above referenced cases. Respectfully submitted. POWERS & FROST, L.L.P. James H. Powers Texas State Bar No. 16217400 Sharia J. Frost Texas State Bar No. 07491100 Gwendolyn S. Frost 4Texas State Bar No. 07488750 2600 Two Flouston Center 909 Fannin Houston, Texas 77010 Telephone: (713) 767-1555 Facsimile: (713) 767-1799 ATTORNEYS FOR DEFENDANT UNION CARBIDE CORPORATION D/B/A UNION CARBIDE CHEMICALS AND PLASTICS, INC. CERTIFICATE OF SERVICE I hereby certify that a true and correct of Defendant Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc.'s List of Potential Fact/Expert Witnesses and D\position Testimony has been forwarded to Plaintiffs' counsel of record either by first class mail, .return receipt requested, delivery or facsimile on this the dav of _____ _________________ , 2001. a /tV F \CCR\Cameron'\V]|]arrea! JonnMJnton Carbide -- First Amended Expen List.doc UNION CARBIDE CORPORATION'S LIST OF POTENTIAL FACT/EXPERT WITNESSES 1. Dr. Peter Barrett 10 Martins Lane Hingham. MA 02043 (781)749-5876 (Physician) Witness will be able to testify about either the physical properties of Calidna, such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria, or both. 2. Dr. Eric Chatfield (Miscroscopist/Hygienist) Chatfield Technical Consultants 2071 Dickson Road Missisangua, Ontario Canada LSB 1YB (905) 896-9290 (Phone) (905) 896-1930 (Fax) Witness will be able to testify about either the physical properties of Calidria, such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria, or both. 3. Dr. Allen Gibbs (Pathologist) Pathology Department Landough Department Landough Hospital Penarth. Glamorgan UK CFC I XX 011-44-1222711711 011-44-1633259189 (Home) Witness will be able to testify about either the physical properties of Calidria. such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria, or both. F\CCR\CarneronU'illarTeal. JohrAlimon Carbide - First Amended Expert List.doc 4. Dr. Duane Hyde 319 Canal Street King City. CA 93930 (83 f)385-5170 (Physician) Witness will be able to testify about either the physical properties of Calidria, such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria. or both. 5. Dr. Ed Ilgren (Pathologist) 830 Montgomery Avenue - Apt. 503 Bryn Mawr, PA 19010 (610) 525-5960 Witness will be able to testify about either the physical properties of Calidria, such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria, or both. 6. Dr. Hilton C. Lewinsohn (Physician) 20 Chestnut Street, N-27 Exeter, NH 03833 (603) 778-2797 (home) * Dr. Lewinsohn is a Former Assistant Corporate Medical Director and is knowledgeable about and can testify on medical issues in relation to asbestos generally. 7. Professor Fred A. Mumpton (Geologist) 31 Sherwood Drive Lewiston. New York 14902 (716) 637-2324 Witness will be able to testify about either the physical properties of Calidria. such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria, or both. F`\CCR\Cameron\Vil!arreal. John\Umon Carbide -- First Amended Expen Lisi.doc HlED--___ O'CLOCK___ Li. t AURORA DE LA GARZA DIST. CLERK JAN 18 2001 CAUSE NO. 2000-05-1962-C DISlfVn^5lF ftl* COUNTY. TEXAS OEpur ROBERT HENRY VILLARREAL. IN THE DISTRICT COURT OF v Individually and as Personal Representative of the Heirs and Estate of JOHN HENRY VILLARREAL Plaintiffs, vs. GAF CORPORATION HOLDINGS, INC.), ET AL. Defendants. CAMERON COUNTY, TEXAS 197TM JUDICIAL DISTRICT DEFENDANT UNION CARBIDE CORPORATION d/b/a UNION CARBIDE CHEMICALS AND PLASTICS. INC.'S FIRST AMENDED LIST OF POTENTIAL FACT/EXPERT WITNESSES Defendant Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc.'s t- List of Potential Fact/Expert Witnesses and Deposition Testimony to the above referenced cases. Respectfully submitted. POWERS & FROST, L.L.P. James H. Powers Texas State Bar No. 16217400 Sharia J. Frost Texas State Bar No. 07491100 Gwendolyn S. Frost 4Texas State Bar No. 07488750 2600 Two Houston Center 909 Fannin Houston, Texas 77010 Telephone: (713) 767-1555 Facsimile: (713) 767-1799 ATTORNEYS FOR DEFENDANT UNION CARBIDE CORPORATION D/B/A UNION CARBIDE CHEMICALS AND PLASTICS, INC. CERTIFICATE OF SERVICE 1 hereby certify that a true and correct of Defendant Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics. Inc.'s List of Potential Fact/Expert Witnesses and Deposition Testimony has been forwarded to Plaintiffs' counsel of record either by first class mail, return receipt requested, delivery or facsimile on this the dav of ____ _______________ , 2001. F:\CCR\CameronA illarreal. JohnMjmon Carbide -- First Amended Expert Liscdoc UNION CARBIDE CORPORATION'S LIST OF POTENTIAL FACT/EXPERT WITNESSES 1. Dr. Peter Barrett 10 Martins Lane Hingham. MA 02043 (781)749-5876 (Physician) Witness will be able to testify about either the physical properties of Calidna, such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria, or both. Dr. Eric Chatfield (Miscroscopist/Hygienist) Chatfieid Technical Consultants 2071 Dickson Road Missisangua, Ontario Canada LSB 1YB (905) 896-9290 (Phone) (905) 896-1930 (Fax) Witness will be able to testify about either the physical properties of Calidna. such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria, or both. 3. Dr. Allen Gibbs (Pathologist) Pathology Department Landough Department Landough Hospital Penarth, Glamorgan UKCFCIXX 011-44-1222711711 011-44-1633259189 (Home) Witness will be able to testify about either the physical properties of Calidria. such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria, or both. 3F.\CCR\CameronWi!larreal. JohnVUnton Carbide -- First Amended Expert List doc 4. Dr. Duane Hyde 319 Canal Street King City. CA 93930 (831)385-5170 (Physician) Witness will be able to testify about either the physical properties of Calidria, such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidna, or both. Dr. Ed Ilgren (Pathologist) 830 Montgomery Avenue - Apt. 503 Bryn Mawr, PA 19010 (610)525-5960 Witness will be able to testify about either the physical properties of Calidria. such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria, or both. 6. Dr. Hilton C. Lewinsohn (Physician) 20 Chestnut Street, N-27 Exeter, NH 03833 (603) 778-2797 (home) Dr. Lewinsohn is a Former Assistant Corporate Medical Director and is knowledgeable about and can testify on medical issues in relation to asbestos generally. 7. Professor Fred A. Mumpton (Geologist) 31 Sherwood Drive Lewiston, New York 14902 (716) 637-2324 Witness will be able to testify about either the physical properties of Calidria. such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidna, or both. -4 F \CCR\Cameron\Vilianeal JormVUnion Carbide -- First Amended Expert List.doc 8. Professor Fred Pooley (Mineralogist) School of Engineering Department of Mining & Metals University of Wales P.O. Box 917 Cardiff. Wales CF21XH 011-44-1222 874-0000 Witness will be able to testify about either the physical properties of Calidna, such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidna, or both. 10. Dr. Hamson Rhodes (Industrial Hygienist) 1037 Lakeside Court Grand Junction. CO 81506 (970)242-4932 Witness will be able to testify about either the physical properties of Calidna. such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidria, or both. 11. Dr. Robert Sawyer (Physician) Entek Environmental & Technical Services, Inc. Rensselaer Technology Park 125 Defreest Drive Troy. NY 12180 (518)283-9200 (800)278-6433 Dr. Robert Sawyer Home Address: P.O. Box 1407 Guilford, CT 06437 (203)453-3060 Witness will be able to testify about either the physical properties of Calidria, such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidna. or both. 5 F \CCR\Cameron\Vi!larTeal. John\bmon Carbide -- First Amended Expert List doc 12. Dr. Mark Van Baalen Harvard University Cambridge. MA (617)495-0705 (Mineralogist) Witness will be able to testify about either the physical properties of Calidna. such as its short fiber length, lack of tremolite or other contamination and other unique properties, or the lack of health hazards from exposure to Calidna. or both. 13. Carl Demehl - Former Industnal Hygienist, deceased (by deposition) Former UCC employee who may have information regarding the general history of the Texas City plant, current and past industrial hygiene practices, medical programs and safety procedures pertaining to asbestos. 14. Dr. Robert Plevan - Industnal Hygienist. Union Carbide Corporation. 39 Old Ridgeburv Road. Danbury. CT. 06817 (203) 794-2000 Current UCC employee who may have information regarding the general history of thfe Texas City plant, current and past industnal hygiene practices, medical programs and safety procedures pertaining to asbestos. 15. Newt Ketchum - Address unavailable Former UCC employee who may have information regarding the general history of the Texas City plant, current and past industrial hygiene practices, medical programs and safety procedures pertaining to asbestos. 16.' Newell Bolton - Hilton Head, South Carolina Former UCC employee who may have information regarding the general history' of the Texas City plant, current and past industrial hygiene practices, medical programs and safety procedures pertaining to asbestos. 17. Roy Joyner. M.D. - Address unavailable Former UCC employee who may have information regarding the general history of the Texas City plant, current and past industnal hygiene practices, medical programs and safety procedures pertaining to asbestos. -o- F \CCR\Cameron^Vil!yrrcai. Johndjnton Carbide - First Amended Expert List doc 18. Don Deese - Address unavailable Former UCC employee who may have information regarding the general history of the Texas Citv plant, current and past industrial hygiene practices, medical programs and safety procedures pertaining to asbestos. 19. Dick LaCour. c/o Union Carbide Corporation, 3301 5th Avenue South, Texas City, Texas 77590. (409)945-7411 Current UCC employee who may have information regarding the general history of the Texas City plant, current and past industrial hygiene practices, medical programs and safety procedures pertaining to asbestos. 20. Charlie Phinney, c/o Union Carbide Corporation, 3301 5th Avenue South. Texas City. Texas 77590. (409)945-7411 Former UCC employee who may have information regarding the general history of the Texas City plant, current and past industrial hygiene practices, medical programs and safety procedures pertaining to asbestos. 21. Earl Vicnair, c/o Union Carbide Corporation, 3301 5th Avenue South, Texas City. Texas 77590,(409) 945-7411 Current employee of UCC's Maintenance Department who may have knowledge of current and past safety practices with respect to past usage of asbestos-containing materials. F \CCR\Cameron\Viliarrea[, John\Umon Caroide - Firsi Amended Expen List.doc