Document DGw5mgqQ1MBRx4eGvkyVy60Rd

PLAINTIFF'S EXHIBIT AL-1826b JOSE ALFARO ANZUALDA. ET AL.. V. ALCOA. ET AL NO. 98-344-H ATTACHMENT A LIST OF EXPERT WITNESSES AND LAY WITNESSES Jim Archibald 13712 West Robertson Drive Sun City West, AZ 85375 Phone: 913-345-1500 Mr. Archibald began employment with Alcoa in 1952. Mr. Archibald retired in 1991. 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 Plaintiffs' medical records and radiographs, Dr. Barrett may also testify regarding the existence or non-existence of any asbestos-related disease in Plaintiffs. Dr. Barrett may testify as to review and interpretation of x-ray films, and whether other diseases or conditions were present in Plaintiffs. Based on his review of x-rays of other utility workers employed by Defendant at the Point Comfort facility, Dr. Barrett may also testify regarding the existence or non-existence of any asbestos-related disease in employees in Plaintiffs' job classification at the Point Comfort plant. Dr. Barrett's testimony will be based on his training, experience, education, review of Plaintiffs' medical records and radiographs, review of a series of x-rays of utility workers 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 ALCOA in particular for controlling the risks arising from exposure to asbestos and asbestoscontaining 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 Plaintiffs, 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. Wier. 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. 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. Dr. Sam H. Cade, Jr. Radiology Department Baylor University Medical Center 3500 Gaston Avenue Dallas, Texas 75242 Dr. Cade may be called to testify about the medical condition of the Plaintiffs; general principles of radiology; the various causes of changes seen in the review of x-rays; and the radiology of asbestos related disease. If Dr. Cade is to testify in any individual case, a report will be furnished with respect to any such case. 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 absestos-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 Plaintiffs specifically, and the effect that other substances have on human health generally and Plaintiffs' 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 Plaintiffs. Dr. Cagle may also testify regarding the medical condition of Plaintiffs based on review of medical records, x-rays, plaintiffs' experts' reports and supplemental reports. He wilLtestify to the physical condition of Plaintiffs, based on his review of Plaintiffs' records and his deposition testimony. 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. Bruce Cox 1645 Southpoint Lane New London, NC 28127 Phone: 336-461-2459 Mr. Cox is the plant manager at Alcoa Badin. He is leader of the primary metals safety and health lead team. He is an electrical engineer by education and training and has substantial experience with various engineering and management procedures and processes within Alcoa at many of their facilities. Mr. Cox may testify about Alcoa's policies and procedures, Alcoa' use and no-use of asbestos containing materials and safety precautions advised by Alcoa. In addition to offering factual testimony, Mr. Cox 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 E. Craighead, M.D. 1845 Four Winds Road Ferrisburgh, VT 05406 Phone: 802-425-3480 - Dr. Craighead is a pathologist. ............. .. Upon review of Plaintiffs' 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. 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 Plaintiffs' 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 Plaintiffs' 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 asbestos-related 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 Plaintiffs 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 Plaintiffs 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: 303-978^914 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 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. Dr. George Delclos Pulmonary Section F907, Methodist Hospital 6565Pannin, Houston, Texas Dr. Delclos may be called to testify about the medical condition of the Plaintiffs; anatomy and function of the respiratory and circulatory systems, including the protective systems of the body with regard to the inhalation and retention of dust, and the diagnosis and treatment of disease affecting such systems; the nature of asbestos and asbestosis; the symptomatology, disease process and diagnosis of asbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of obstructive pulmonary disease with asbestos fiber exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases of the respiratory system and other causes of obstructive and restrictive disease or defects of the respiratory system; the various causes of changes on x-rays, and the radiology of asbestos-related diseases; methods of diagnosis of various diseases particularly means of establishing the differential diagnosis of alleged asbestos-related diseases with other non-asbestos-related diseases; incidence of lung cancer among individuals with asbestosis or asbestos exposure without asbestosis, compared with non-asbestotic asbestos workers, non asbestos exposed workers, and with the general population; the import of any exhibit (including without limitation, corporate documents of defendants) introduced as evidence, or any items prepared for use or used for demonstrative purposes by any witness; cigarette smoking and its effect on the lung and other organs; the relationship of cigarette smoking to cancer of the lung and cancers of other sites with reference to epidemiological studies and physiologic effect; difference between impairment and disability; effect of asbestosis, or asbestos exposure without asbestosis, on disability and life expectancy; effect of pleural plaques or other pleural manifestations of asbestos exposure on lung function or life expectancy; the lack of a relationship between presence of pleural plaques and a later development of any form of cancer; cancer incidence in the general population and among asbestos workers and its potential causes; the history of evolution and knowledge of asbestos related diseases; the incidence of mesothelioma among various kinds of workers exposed to asbestos, and the relative importance of various fiber types in the cause of lung cancer and mesothelioma; epidemiology of lung cancer, mesothelioma and asbestos-related disease in general; and to the extent not covered above, asbestos medicine in general. If Dr. Delclos is to testify in any individual case, a report will be furnished with respect to any such case. Dr. Henry Demopoulos Health Maintenance Services 7 Westchester Plaza Elmsford, NY 10523 Dr. Demopoulos may be called to testify about the medical condition of the Plaintiffs; general pathology; the pathology of asbestos-related diseases; and the pathology of the Plaintiffs; the incidence/risk of cancer among various populations. He 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. He may discuss historical literature regarding asbestos exposure and its health consequences. Dr. Demopoulos 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. Demopoulos 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. 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. Kenneth Dolezal 514 Travis Street Port Lavaca, TX 77979 Phone: 512-552-3403 Mr. Dolezal is a former Alcoa employee. Mr. Dolezal was employed with Alcoa from 1956 through 1994. He has worked at Alcoa's Point Comfort and Badin facilities and also worked at an Alcoa plant in Brazil. He has worked as a supervisor in the potroom, as well as in the clarification and electrolyte areas. Mr. Dolezal may offer testimony relating to any of his Alcoa positions. Mr. Dolezal may offer testimony relating to the use and substitution of asbestos-containing materials and use of respirators and face masks. Additionally, Mr. Dolezal 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. IHs anticipated that his testimony may include "expert testimony," based on his experience, background and training in the field. Dr. Scott R. Donaldson North Texas Pulmonary Associates 375 Municipal Drive, Suite 140 Richardson, Texas 75080 Dr. Donaldson may be called to testify about the medical condition of the Plaintiffs; anatomy and function of the respiratory and circulatory systems, including the protective systems of the body with regard to the inhalation and retention of dust, and the diagnosis and treatment of disease affecting such systems; the nature of asbestos and asbestosis; the symptomatology, disease process and diagnosis of asbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of obstructive pulmonary disease with asbestos fiber exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases of the respiratory system and other causes of obstructive and restrictive disease or defects of the respiratory system; the various causes of changes on x-rays, and the radiology of asbestos-related diseases; methods of diagnosis of various diseases particularly means of establishing the differential diagnosis of alleged asbestos-related diseases with other non-asbestos-related diseases; incidence of lung cancer among individuals with asbestosis or asbestos exposure without asbestosis, compared with non-asbestotic asbestos workers, non asbestos exposed workers, and with the general population; the import of any exhibit (including without limitation, corporate documents of defendants) introduced as evidence, or any items prepared for use or used for demonstrative purposes by any witness; cigarette smoking and its effect on the lung and other organs; the relationship of cigarette smoking to cancer of the lung and cancers of other sites with reference to epidemiological studies and physiologic effect; difference between impairment and disability; effect of asbestosis, or asbestos exposure without asbestosis, on disability and life expectancy; effect of pleural plaques or other pleural manifestations of asbestos exposure on lung function or life expectancy; the lack of a relationship between presence of pleural plaques and a later development of any form of cancer; cancer incidence in the general population and among asbestos workers and its potential causes; the history of evolution and knowledge of asbestos related diseases; the incidence of mesothelioma among various kinds of workers exposed to asbestos, and the relative importance of various fiber types in the cause of lung cancer and mesothelioma; epidemiology of lung cancer, mesothelioma and asbestos-related disease in general; and to the extent not covered above, asbestos medicine in general. If Dr. Donaldson is to testify in any individual case, a report will be furnished with respect to any such case. Jack Drake P.O. Box 1208 1702 Sager Rockdale, TX 76567 Phone: 512^46-2933 Mr. Drake is a former Alcoa employee. Mr. Drake began his employment in 1953 and served as Alcoa Rockdale plant manager from 1977 until 1982 and Texas area manager from 1982 until 1994. He was trained and educated as an engineer. He worked at several Alcoa facilities and may testify to many of the policies and procedures followed by Alcoa. In addition to offering factual testimony, Mr. Drake 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. 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. I.A. 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 Plaintiffs. Dr. Feingold may testify regarding review and interpretation of x-ray films, and whether other diseases or conditions were present in Plaintiffs. 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 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 Plaintiffs 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 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 Dr. Gregory Foster North Texas Pulmonary Associates 375 Municipal Drive, Suite 140 Richardson, Texas 75080 Dr. Foster be called to testify about the medical condition of the Plaintiffs; anatomy and function of the respiratory and circulatory systems, including the protective systems of the body with regard to the inhalation and retention of dust, and the diagnosis and treatment of disease affecting such systems; the nature of asbestos and asbestosis; the symptomatology, disease process and diagnosis of asbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of obstructive pulmonary disease with asbestos fiber exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases of the respiratory system and other causes of obstructive and restrictive disease or defects of the respiratory system; the various causes of changes on x-rays, and the radiology of asbestos-related diseases; methods of diagnosis of various diseases particularly means of establishing the differential diagnosis of alleged asbestos-related diseases with other non-asbestos-related diseases; incidence of lung cancer among individuals with asbestosis or asbestos exposure without asbestosis, compared with non-asbestotic asbestos workers, non asbestos exposed workers, and with the general population; the import of any exhibit (including without limitation, corporate documents of defendants) introduced as evidence, or any. items prepared for use or used for demonstrative purposes by any witness; cigarette smoking and its effect on the lung and other organs; the relationship of cigarette smoking to cancer of the lung and cancers of other sites with reference to epidemiological studies and physiologic effect; difference between impairment and disability; effect of asbestosis, or asbestos exposure without asbestosis, on disability and life expectancy; effect of pleural plaques or other pleural manifestations of asbestos exposure on lung function or life expectancy; the lack of a relationship between presence of pleural plaques and a later development of any form of cancer; cancer incidence in the general population and among asbestos workers and its potential causes; the history of evolution and knowledge of asbestos related diseases; the incidence of mesothelioma among various kinds of workers exposed to asbestos, and the relative importance of various fiber types in the cause of lung cancer and mesothelioma; epidemiology of lung cancer, mesothelioma and asbestosrelated disease in general; and to the extent not covered above, asbestos medicine in general. If Dr. Foster is to testify in any individual case, a report will be furnished with respect to any such case. 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. Z. Tommy Gibson P.O. Box 2511 Albemarle, NC 28001 Phone: 704-983-3715 Mr. Gibson is currently the Director of Safety at the Alcoa Badin facility. He has held various previous assignments throughout Alcoa. During Mr. Gibson's tenure at Alcoa he has handled safety discussions and may testify concerning the safety awards received by Alcoa Badin, Alcoa corporation generally and Alcoa plants throughout the world. Mr. Gibson may testify concerning the safety statistics and record of Alcoa Badin as it is compared to other industries both similar and dissimilar in the United States. He will discuss the capital expenditure on health and safety yearly at the Alcoa Badin plant and similar facilities owned by Alcoa. He will also testify concerning Alcoa's 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 may testify that Alcoa employees were covered under the appropriate Worker's Compensation statute during the relevant time periods. He may testify concerning the aluminum smelting process generally. Mr. Gibson has served as a potroom, electrode, and ingot engineer and may testify regarding the procedures in these areas at various times. He may testify as to employees' potential exposure to asbestos-containing products during the pot lining operation. Further, he may testify concerning the frequency with which a potman may be exposed to asbestos during the pot lining operation. Additionally, Mr. Gibson may testify concerning present and past managementunion contracts and the labor relations policies and procedures. He may testify concerning communication with the union for employees concerning safety issues. Mr. Gibson is involved with Alcoa 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. Gibson may testify as to the economic issues admissible in the punitive damages phase (if any) of the trial. Mr. Gibson may testify to the involvement of Alcoa Badin in the community and Alcoa's contribution to charities and other non profit organizations that benefit the citizens of Stanley County. In addition to offering factual testimony, Mr. Gibson 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. Michael Graham Medical Examiner's Office 1300 Clark St. St. Louis, Missouri Upon review of Plaintiffs' medical records and pathology materials, the Dr. Graham may testify about Plaintiffs' medical conditions and its causes. His testimony may include a discussion of asbestos and its effects on human health generally and on the Plaintiffs' conditions specifically and the effect of other substances on human health generally and on the Plaintiffs' conditions specifically. Dr. Graham 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. He 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. Graham may apply these principles to Plaintiffs' cases. Dr. Graham may discuss asbestosis, bronchitis, bronchiolitis, emphysema, peribronchial fibrosis, smokers pigment and Chronic Obstructive Pulmonary Disease, their interaction and their relationship to cancer. 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. Peter Heidbrink Board Certified Pulmonary Specialist Southwest Pulmonary Associates St. Paul Professional Building #2 5959 Harry Hines Boulevard, Suite 711 Dallas, Texas 75235. Dr. Heidbrink may be called to testify about the medical condition of the Plaintiffs; anatomy and function of the respiratory and circulatory systems, including the protective systems of the body with regard to the inhalation and retention of dust, and the diagnosis and treatment of disease affecting such systems; the nature of asbestos and asbestosis; the symptomatology, disease process and diagnosis of asbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of obstructive pulmonary disease with asbestos fiber exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases of the respiratory system and other causes of obstructive and restrictive disease or defects of the respiratory system; the various causes of changes on x-rays, and the radiology of asbestos-related diseases; methods of diagnosis of various diseases particularly means of establishing the differential diagnosis of alleged asbestos-related diseases with other non-asbestos-related diseases; incidence of lung cancer among individuals with asbestosis or asbestos exposure without asbestosis, compared with non-asbestotic asbestos workers, non asbestos exposed workers, and with the general population; the import of any exhibit (including without limitation, corporate documents of defendants) introduced as evidence, or any items prepared for use or used for demonstrative purposes by any witness; cigarette smoking and its effect on the lung and other organs; the relationship of cigarette smoking to cancer of the lung and cancers of other sites with reference to epidemiological studies and physiologic effect; difference between impairment and disability; effect of asbestosis, or asbestos exposure without asbestosis, on disability and life expectancy; effect of pleural plaques or other pleural manifestations of asbestos exposure on lung function or life expectancy; the lack of a relationship between presence of pleural plaques and a later development of any form of cancer; cancer incidence in the general population and among asbestos workers and its potential causes; the history of evolution and knowledge of asbestos related diseases; the incidence of mesothelioma among various kinds of workers exposed to asbestos, and the relative importance of various fiber types in the cause of lung cancer and mesothelioma; epidemiology of lung cancer, mesothelioma and asbestos-related disease in general; and to the extent not covered above, asbestos medicine in general. If Dr. Heidbrink is to testify in any individual case, a report will be furnished with respect to any such case. 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 managementunion 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. 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 Plaintiffs medical records and pathology specimens, he may testify about Plaintiffs' medical condition and/or the cause of Plaintiffs' death, if applicable. His testimony may include a discussion of the diagnosis in this case, the cause of Plaintiffs' death, methods of making a differential diagnosis, the causes or potential causes of Plaintiffs' 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 Plaintiffs' 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. 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. Dr. Robert Jones Tulane Medical Center 1700 Perdido Street New Orleans, Louisiana Dr. Jones may be called to testify about the medical condition of the Plaintiffs; anatomy and function of the respiratory and circulatory systems, including the protective systems of the body with regard to the inhalation and retention of dust, and the diagnosis and treatment of disease affecting such systems; the nature of asbestos and asbestosis; the symptomatology, disease process and diagnosis of asbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of obstructive pulmonary disease with asbestos fiber exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases of the respiratory system and other causes of obstructive and restrictive disease or defects of the respiratory system; the various causes of changes on x-rays, and the radiology of asbestos-related diseases; methods of diagnosis of various diseases particularly means of establishing the differential diagnosis of alleged asbestos-related diseases with other non-asbestos-related diseases; incidence of lung cancer among individuals with asbestosis or asbestos exposure without asbestosis, compared with non-asbestotic asbestos workers, non asbestos exposed workers, and with the general population; the import of any exhibit (including without limitation, corporate documents of defendants) introduced as evidence, or any items prepared for use or used for demonstrative purposes by any witness; cigarette smoking and its effect on the lung and other organs; the relationship of cigarette smoking to cancer of the lung and cancers of other sites with reference to epidemiological studies and physiologic effect; difference between impairment and disability; effect of asbestosis, or asbestos exposure without asbestosis, on disability and life expectancy; effect of pleural plaques or other pleural manifestations of asbestos exposure on lung function or life expectancy; the lack of a relationship between presence of pleural plaques and a later development of any form of cancer; cancer incidence in the general population and among asbestos workers and its potential causes; the history of evolution and knowledge of asbestos related diseases; the incidence of mesothelioma among various kinds of workers exposed to asbestos, and the relative importance of various fiber types in the cause of lung cancer and mesothelioma; epidemiology of lung cancer, mesothelioma and asbestos-related disease in general; and to the extent not covered above, asbestos medicine in general. If Dr. Jones is to testify in any individual case, a report will be furnished with respect to any such case. 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 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 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 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. Willfam Kimpei 47 Kramer Place Mandeville, LA 70471 Phone: 504-727-4675 _ ...... Mr. Kimpei is a former employee at Alcoa's Point Comfort, Texas plant. Mr. Kimpei began his employment with Alcoa in 1977 at Alcoa's Bauxite, Arkansas plant. During his employment with Alcoa, Mr. Kimpei has also worked in the Calcination and Clarification Departments, worked as an Engineering Supervisor, and as a Procurement Manager. Mr. Kimpei may offer testimony relating to any of his Alcoa positions. Mr. Kimpei 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 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. Greg Kraft 2005 Sager Road Rockdale, Texas 76567 Phone: 512-446-5716 Mr. Kraft is currently employed as Environmental Manager for Rockdale Operations and the Primary Metals Division and is fully knowledgeable of the policies and procedures therein. Mr. Kraft 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. Kraft 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. Glade Lantz 1803 O'Kelley Rockdale, Texas 76567 Phone: 512^46-6453 Mr. Lantz was employed by Alcoa in various capacities from 1951 until he retired in 1994. He served as the technical manager for the Rockdale plant from 1978 until 1994. Mr. Lantz 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. Lantz 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 Plaintiffs. He may comment on the work of Dr. Longo and others. Dr. Lee may also testify regarding potential exposure of Plaintiffs 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 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 Plaintiffs 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. 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 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 asbestoscontaining 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. 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. 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. Jack E. Peterson, P.E., CIH, Ph.D. Peterson Associates 2830 Via Viejas Oeste Alpine, CA 91901 Phone: (619)445-9668 Mr. Peterson 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. Peterson 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. Peterson 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. Peterson may discuss historic literature regarding asbestos exposure and its health consequences, and recommended methods for controlling those consequences. Mr. Peterson 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. Peterson 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. Peterson 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. Peterson may testify about the approaches generally and by 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. Peterson may comment about testing done by or on behalf of the Plaintiffs, 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. Peterson'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. Peterson may testify about matters referred to in the designations of Dr. First, Dr. Balzer and Dr. Wier. Ken Peterson HC2 Box 380 Palacios, TX 77465 Phone: 512-972-2906 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 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, 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 testify 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. Al 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, MrL 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. Records Custodian Alcoa Wenatchee Works 6200 Malaga Highway Malaga, WA 98828-9728 Phone: 509-663-9227 Records Custodian Alcoa Warrick Operations Highway 66 Newburgh, IN 47629 Phone: 812-853-6111 Records Custodian Alcoa Badin Works Highway 740 Badin, NC 28009 Phone: 704-422-3621 Records Custodian Alcoa Corporate Offices 201 Isabella Street Pittsburgh, PA 15212 Phone: 412-553-4545 Records Custodian Alcoa Point Comfort Operations State Highway 35 Point Comfort, TX 77978 Phone: 512-987-6180 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 Records Custodian Alcoa Technical Center 7th Street Road Route 780 Alcoa Center, PA 15069 Phone: 412-339-6651 Records Custodian Alcoa Tennessee Operations 1100 East Hunt Road Alcoa, TN 37701 Phone: 423-977-2011 Records Custodian Massena Operations Park Avenue East Massena, NY 13662 Phone: 315-764-4011 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 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 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: 615-977^244 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 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 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. Janie Sendejo P.O. Box 1303 Port Lavaca, TX 77979 Phone: 512-552^661 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. Dr. James Robert Shepherd, III University of Texas Health Center at Tyler Department of Radiology P.O. Box 2003 Tyler, Texas 75710 Dr. Shepherd may be called to testify about the medical condition of the Plaintiffs; general principles of radiology; the various causes of changes seen in the review of x-rays; and the radiology of asbestos related disease. If Dr. Shepherd is to testify in any individual case, a report will be furnished with respect to any such case. 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 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 ma7 include "expert testimony," based on his experience, background and training in the field. Dr. Russell P. Sherwin Department of Pathology USC School of Medicine Los Angeles, California Upon review of Plaintiffs' medical records and pathology materials, Dr. Sherwin may testify about Plaintiffs' medical conditions and its causes. His testimony may include a discussion of asbestos and its effects on human health generally and on the Plaintiffs' conditions specifically and the effect of other substances on human health generally and on the Plaintiffs' conditions specifically. Dr. Sherwin 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. He 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. He may apply these principles to Plaintiffs' cases. Dr. Sherwin may discuss asbestosis, bronchitis, bronchiolitis, emphysema, peribronchial fibrosis, smokers pigment and Chronic Obstructive Pulmonary Disease, their interaction and their relationship to cancer. 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 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. Dr. Paul M. Stevens _ ......... Board Certified Pulmonary Disease Specialist and Professor of Medicine at the Baylor College of Medicine Methodist Hospital Houston, Texas Dr. Stevens may be called to testify about the medical condition of the Plaintiffs; anatomy and function of the respiratory and circulatory systems, including the protective systems of the body with regard to the inhalation and retention of dust, and the diagnosis and treatment of disease affecting such systems; the nature of asbestos and asbestosis; the symptomatology, disease process and diagnosis of asbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of obstructive pulmonary disease with asbestos fiber exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases of the respiratory system and other causes of obstructive and restrictive disease or defects of the respiratory system; the various causes of changes on x-rays, and the radiology of asbestos-related diseases; methods of diagnosis of various diseases particularly means of establishing the differential diagnosis of alleged asbestos-related diseases with other non-asbestos-related diseases; incidence of lung cancer among individuals with asbestosis or asbestos exposure without asbestosis, compared with non-asbestotic asbestos workers, non asbestos exposed workers, and with the general population; the import of any exhibit (including without limitation, corporate documents of defendants) introduced as evidence, or any items prepared for use or used for demonstrative purposes by any witness; cigarette smoking and its effect on the lung and other organs; the relationship of cigarette smoking to cancer of the lung and cancers of other sites with reference to epidemiological studies and physiologic effect; difference between impairment and disability; effect of asbestosis, or asbestos exposure without asbestosis, on disability and life expectancy; effect of pleural plaques or other pleural manifestations of asbestos exposure on lung function or life expectancy; the lack of a relationship between presence of pleural plaques and a later development of any form of cancer; cancer incidence in the general population and among asbestos workers and its potential causes; the history of evolution and knowledge of asbestos related diseases; the incidence of mesothelioma among various kinds of workers exposed to asbestos, and the relative importance of various fiber types in the cause of lung cancer and mesothelioma; epidemiology of lung cancer, mesothelioma and asbestos-related disease in general; and to the extent not covered above, asbestos medicine in general. If Dr. Stevens is to testify in any individual case, a report will be furnished with respect to any such case. Dr. Gail Stockman 703 E. Marshall, Ste. 4002 Longview, Texas Dr. Stockman may be called to testify about the medical condition of the Plaintiffs; anatomy and function of the respiratory and circulatory systems, including the protective systems of the body with regard to the inhalation and retention of dust, and the diagnosis and treatment of disease affecting such systems; the nature of asbestos and asbestosis; the symptomatology, disease process and diagnosis of asbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of obstructive pulmonary disease with asbestos fiber exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases of the respiratory system and other causes of obstructive and restrictive disease or defects of the respiratory system; the various causes of changes on x-rays, and the radiology of asbestos-related diseases; methods of diagnosis of various diseases particularly means of establishing the differential diagnosis of alleged asbestos-related diseases with other non-asbestos-related diseases; incidence of lung cancer among individuals with asbestosis or asbestos exposure without asbestosis, compared with non-asbestotic asbestos workers, non asbestos exposed workers, and with the general population; the import of any exhibit (including without limitation, corporate documents of defendants) introduced as evidence, or any items prepared for use or used for demonstrative purposes by any witness; cigarette smoking and its effect on the lung and other organs; the relationship of cigarette smoking to cancer of the lung and cancers of other sites with reference to epidemiological studies and physiologic effect; difference between impairment and disability; effect of asbestosis, or asbestos exposure without asbestosis, on disability and life expectancy; effect of pleural plaques or other pleural manifestations of asbestos exposure on lung function or life expectancy; the lack of a relationship between presence of pleural plaques and a later development of any form of cancer; cancer incidence in the general population and among asbestos workers and its potential causes; the history of evolution and knowledge of asbestos related diseases; the incidence of mesothelioma among various kinds of workers exposed to asbestos, and the relative importance of various fiber types in the cause of lung cancer and mesothelioma; epidemiology of lung cancer, mesothelioma and asbestos-related disease in general; and to the extent not covered above, asbestos medicine in general. If Dr. Stockman is to testify in any individual case, a report will be furnished with respect to any such case. 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 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: 512-552-9815 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 I ndustrial 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. 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. Dr. Hans Weill Tulane Medical Center 1700 Perdido Street New Orleans, Louisiana Dr. Weill may be called to testify about the medical condition of the Plaintiffs; anatomy and function of the respiratory and circulatory systems, including the protective systems of the body with regard to the inhalation and retention of dust, and the diagnosis and treatment of disease affecting such systems; the nature of asbestos and asbestosis; the symptomatology, disease process and diagnosis of asbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of obstructive pulmonary disease with asbestos fiber exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases of the respiratory system and other causes of obstructive and restrictive disease or defects of the respiratory system; the various causes of changes on x-rays, and the radiology of asbestos-related diseases; methods of diagnosis of various diseases particularly means of establishing the differential diagnosis of alleged asbestos-related diseases with other non-asbestos-related diseases; incidence of lung cancer among individuals with asbestosis or asbestos exposure without asbestosis, compared with non-asbestotic asbestos workers, non asbestos exposed workers, and with the general population; the import of any exhibit (including without limitation, corporate documents of defendants) introduced as evidence, or any items prepared for use or used for demonstrative purposes by any witness; cigarette smoking and its effect on the lung and other organs; the relationship of cigarette smoking to cancer of the lung and cancers of other sites with reference to epidemiological studies and physiologic effect; difference between impairment and disability; effect of asbestosis, or asbestos exposure without asbestosis, on disability and life expectancy; effect of pleural plaques or other pleural manifestations of asbestos exposure on lung function or life expectancy; the lack of a relationship between presence of pleural plaques and a later development of any form of cancer; cancer incidence in the general population and among asbestos workers and its potential causes; the history of evolution and knowledge of asbestos related diseases; the incidence of mesothelioma among various kinds of workers exposed to asbestos, and the relative importance of various fiber types in the cause of lung cancer and mesothelioma; epidemiology of lung cancer, mesothelioma and asbestos-related disease in general; and to the extent not covered above, asbestos medicine in general. If Dr. Weill is to testify in any individual case, a report will be furnished with respect to any such case. Dr. Weill 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. He may discuss historical literature regarding asbestos exposure and its health consequences. Dr. Weill 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. He 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. 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 Plaintiffs 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 asbestosrelated 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 Plaintiffs' place of employment. 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. Dr. R. Keith Wilson Respiratory Consultants of Houston 6565 Fannin Fondren Building Houston, Texas 77030. Dr. Wilson may be called to testify about the medical condition of the Plaintiffs; anatomy and function of the respiratory and circulatory systems, including the protective systems of the body with regard to the inhalation and retention of dust, and the diagnosis and treatment of disease affecting such systems; the nature of asbestos and asbestosis; the symptomatology, disease process and diagnosis of asbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of obstructive pulmonary disease with asbestos fiber exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases of the respiratory system and other causes of obstructive and restrictive disease or defects of the respiratory system; the various causes of changes on x-rays, and the radiology of asbestos-related diseases; methods of diagnosis of various diseases particularly means of establishing the differential diagnosis of alleged asbestos-related diseases with other non-asbestos-related diseases; incidence of lung cancer among individuals with asbestosis or asbestos exposure without asbestosis, compared with non-asbestotic asbestos workers, non asbestos exposed workers, and with the general population; the import of any exhibit (including without limitation, corporate documents of defendants) introduced as evidence, or any items prepared for use or used for demonstrative purposes by any witness; cigarette smoking and its effect on the lung and other organs; the relationship of cigarette smoking to cancer of the lung and cancers of other sites with reference to epidemiological studies and physiologic effect; difference between impairment and disability; effect of asbestosis, or asbestos exposure without asbestosis, on disability and life expectancy; effect of pleural plaques or other pleural manifestations of asbestos exposure on lung function or life expectancy; the lack of a relationship between presence of pleural plaques and a later development of any form of cancer; cancer incidence in the general population and among asbestos workers and its potential causes; the history of evolution and knowledge of asbestos related diseases; the incidence of mesothelioma among various kinds of workers exposed to asbestos, and the relative importance of various fiber types in the cause of lung cancer and mesothelioma; epidemiology of lung cancer, mesothelioma and asbestos-related disease in general; and to the extent not covered above, asbestos medicine in general. If Dr. Wilson is to testify in any individual case, a report will be furnished with respect to any such case. 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 plaintiffs) 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. All doctors and other health care professionals who have treated or examined plaintiff or plaintiffs. Records Custodians as many be necessary to authenticate documents to be used by Alcoa at trial.