Document DGzxGdg4aVOz75wVzm6rjLVoB

PLAINTIFF'S EXHIBIT NO. 2000-2591 PY`glfjESrci JOSE ROSENDO MARTINEZ, SR. and ELENA IN THE COUNTY COURT LOPEZ MARTINEZ, ttPAso couNry. tea as Plaintiffs, vs. BV OfI'lltv AT LAW NO. THREE GAF CORPORATION (successor to RUBEROID CORPORATION), etal.. Defendants. EL PASO COUNTY, TEXAS ASARCO INCORPORATED'S DESIGNATION OF EXPERT WITNESSES COMES NOW ASARCO INCORPORATED and hereby designates die following expert witnesses on whom it may rely at the trial ofthis matter. ASARCO reserves its right to designate further expert and foot witnesses as forthar discovery is conducted in this action. 1. All individuals designated or to be designated as expat witnesses by Plaintiff, whether live or by deposition testimony. 2. All individuals designated orto be designated as an expert witness by any otherparty to this action, whether live or by deposition testimony, and without regard to that party's presenoe at the time of trial. 3. Allphysicians or otherhealth carepractitioners who have txeatedPUintiffat any time and for any condition and whose names, addresses, and qualifications are already knownto Plaintiff may be called to testify whether live or by deposition testimony. 4. All physicians who have prior to trial examined Plaintiff and/or Plaintiffs medical records, hospital records, laboratory test results, x-ray or other diagnostic imaging films and/or any other information ofwhateverkind relating to the health ofPlaintiff on behalfofany party, without 500260 1 regard to that party's presence at the time oftrial, who will testify as to the Plaintiffs clinical course and causation of any illness either live or by deposition testimony. 5. Allen PL. Gibbs. M.D.. Department of Pathology, Llandough Hospital, South Glamorgan, Penarth CF, 61XX, United Kingdom, is a pulmonary pathologist who received his medical degree from Newcastle Upon Tyne. He is a Fellow ofthe Royal College of Pathologists. He is a consultant pathologist to South Glamorgan Health Authority and is an honorary clinical teacher to die University of Wales College ofMedicine. Dr. Gibbs is also an honorary consultant to the MRC external staff team on occupational lung diseases at Llandough Hospital He was a senior lecturer in pathology at the University of Wales College of Medicine. He has special expertise in the diagnosis ofasbestos-related diseases and the pathogenicity ofthe various forms of asbestos for pulmonary and pleural diseases and has reviewed over 1,000 lung samples involving asbestos-related changes. Additionally, Dr. Gibbs has authored or co-authored over 45 articles, papers and chapters in the field ofpathology, many of which relate to asbestos-related disease. Dr. Gibbs may review the pathological evidence in this case and testify concerning whether it is diagnostic of asbestos-related disease.. On the basis ofDr. Gibbs' personal research into issues concerning asbestos-related disease, his knowledge of the medical literature and knowledge of the foots ofthis case as they are known to date, Dr. Gibbs may testify generally as to the dangers posed by the inhalation ofasbestos fibers, the relative risks associated with exposure to low levels of airborne asbestos dust in the general environment, and the risks posed to Plaintiff from bis alleged exposure to airborne asbestos dust. 6. Jeremiah Lvnch. C.I.H.. 25 Waterman Avenue, Rumaon, New Jersey. Mr. Lynch ia a Certified Industrial Hygienist. Mr. Lynch will testify generally as to his background, training and experience. Mr. Lynch will testify as to the methods and procedures involved in industrial hygiene, S00260 2 the methods and procedures utilized in die collection of airborne asbestos samples, including fiber measurement and counting techniques, and the use ofindustrial hygiene methods to control worker exposure to airborne asbestos dust Mr. Lynch will further testify concerning threshold limit values, the various threshold limit values for asbestos exposure, the basis for the original threshold limit value and its subsequent changes. Mr. Lynch will further testify concerning the setting and implementation of asbestos exposure limits by OSHA, and the subsequent changes to those limits, and OSHA regulations pertaining to Plaintiffs' workplace at various times. Mr. Lynch may also testify concerning the industrial hygiene programs implemented by Plaintifis' employers at various times, and how those programs compared to the industrial hygiene standards at various limes. Mr. Lynch will further testify with regard to the effectiveness of the industrial hygiene program at ASARCO as compared to the various standards applicable at different times. Mr. Lynch may also testify as to the asbestos exposures which Plaintiff would have had at various times during his employment history. Mr. Lynch will also testify with regardto environmental exposures to airborne asbestos experienced by millions of Americans for which there is no epidemiological evidence of disease. Mr. Lynch may offer such other opinions as may become necessary to rebut the opinions ofPlaintiffs experts. Mr. Lynch, will base his testimony on the available medical and scientific literature, applicable statutes and regulations, his own training and experience, the opinions and reports ofother experts named or to be named by ASARCO or any other party, whether live or by deposition, the testimony ofall other witnesses named or to be namedby ASARCO or any otherparty, whether live or by deposition, and any documents introduced into evidence or otherwise used by any party at the timeoftriaL 500260 3 7. Ernest Mastromatteo. M.D.. 19 Carey Road, Toronto, Ontario, Canada M4S 1N9. Dr. Ernest Mastiomatteo is a medical doctor specializing in occupational and environmental health. He is currently Professor Emeritus, Occupational and Environmental Health, University ofToronto and self- employed as a consultant in Occupational and Environmental Health. Dr. Mastromatteo received his Doctor of Medicine degree from the University ofToronto in 1947. He received a Diploma in Public Health from toe University ofToronto in 1950 and a Diploma in Industrial Health from toe University ofToronto in 1958. In 1958 Dr. Mastromatteo was certified in Occupational Medicine by the American Board ofPieventive Medicine. In 1981 Dr. Mastromatteo was certified in OccupationalMedicine by toe Canadian Board of Occupational Medicine. From 1949 to 1952Dr. Mastromatteo served as the Medical DirectoroftheVirden Local Health Unit, Virden, Manitoba, hi 1952 Dr. Mastromatteo commenced employment as a physician and consultant with the Ontario Ministry of Health. In 1968 be became toe Director of toe Division of Occupational and Environmental Health ofthe Ontario Ministry ofHealth. Heremained in that position until 1974. From 1966to 1974, Dr. Mastromatteo also served as a Consultant in Occupational Diseases to toe Ontario Workers! Compensation Board. From 1968 to 1974 Dr. Mastromatteo was a part-time professor at the University of Toronto and from 1972 to 1974 he was Professor and toe Head of the Department of Occupational and Environmental Health ofthe University ofToronto. In 1974, Dr. Mastromatteo became Chief of the Occupational Health and Safety Branch oftoe International Labour Office fILO") in Geneva, Switzerland. He remained in that position until 1976. From 1976to 1985 Dr. Mastromatteo wasemployed asDirectorofOccupationalHealth forInco Limited, Toronto, Canada From 1985 to 1994 Dr. Mastromatteo was employed as toe Program Director, Occupational andEnvironmentalHealth, ofORC Canadalnc., Toronto Canada. During thatperiod,from 1985 to 1990, Dr. Mastromatteo also served as a consultant to the Occupational Health Policy Branch 500260 4 of the Ontario Workers' Compensation Board. From 1976 to the present, Dr. Mastromatteo has served as an Honorary Consultant to the Occupational Health Clinic ofSt. Michael's Hospital, Toronto, rr.*ria Dr. Mastromatteo is a member ofthe Ontario Medical Association, and Chaired the Section on Occupational Health and the Committee on Public Health, He is a member ofthe c^nttAiam Medical Association. Dr. Mastromatteo was elected to the Ramazzini Medical Society in 196$ and has been a member ofthe International Commission on Occupational Health since 1968. Dr. Mastromatteo is an Honorary Lifetime Member of the American Conference of Governmental Industrial Hygienists ("ACGIH''). Dr. Mastromatteo has served as a member ofthe ACG1H Threshold Limit Value ("TLV") Committee since 1964. He was Chair of the TLV Committee from 1985 to 1990 and President ofdie ACGlHfbrthe 1969-1970term. Dr. Mastromatteo has receivednumeroushonorsand awardsinthe field of occupational medicine. Among his other awards, in 1981 be received the Stokinger Award for Scientific Contributions to Occupational Toxicology in the United States. In 1986 he received the Yant Award for Scientific Contributions to Industrial Hygiene in theUnited States. In 1987Dr. Mastromatteo received the Knudsen Award for his contributions to Occupational Medicine in foe United States. In 1987 he was also inducted into foe Safety and Health Hall ofFame International. Dr. Mastromatteo will furthertestify that as a longstanding memberofthe American Conference of Governmental Industrial Hygienists Threshold Limit Value Committee, he is familiar with that organization's criteria for establishing threshold limit values. In setting those thresholds, foe ACGIH examines all offoe available evidence and bases its decision on foe weight of evidence. As such, foe ACGIH examines the studies and evaluates those studies based on their methodology, and scientific reasoning. Based on its review ofthe best medical evidence, foe ACGIH set its first threshold limit value for asbestos in 1946 and has changed it from time to time where the medical evidence haswarranted such 500260 5 a change. Dr. Mastromatteo will testify as to the threshold limit value at different points in time and the medical knowledge that was available to the ACGH concerning die health effects of asbestos. Dr. Mastromatteo will further testify that the Occupational Safety and Health Administration (OSHA) does not rely on the weight ofevidence but sets its PEL based on a different control strategy. OSHA determines a safe level then sets die permissible exposure limit (PEL) by adding factors of between ten (10) and one hundred (100) times. OSHA has set die PEL for all types ofasbestos at 0.1 0cc. That level ofexposure is many times below die level ofexposure which one would expect to cause disease in the average worker. 8. Howard E. Aver. 2812 Linwood Avenue, Cincinnati, Ohio. Mr. Ayer is a Certified Industrial Hygienist and a Certified Safety Professional. He is Emeritus Professor of Environmental Health, Division of Environmental Hygiene and Safety, University of Cincinnati. Mr. Ayer received his Bachelors in Chemical Engineering in 1948 from die University ofMinnesota. He received a Masters ofScience in Industrial Hygiene Engineering from Harvard University in 19S5. Mr. Ayerwas employed by the United StatesPublic Health Servicc (USPHS) from 1948to 1972. During that timeperiod he served with die National Institute for Occupational Safety and Health, and its predecessor organizations (Division ofOccupational Health. Occupational Health Program and Bureau of Occupational Safety and Health), assigned by the USPHS to the Kansas State Board ofHealth, die Occupational Health Field Station in Salt Lake City, Utah, and the Occupational Health Field Headquarters in Cincinnati, Ohio. Mr. Ayerwas Assistant Chiefofthe Engineering Section fiom 1961 to 1964, Chieffrom 1964 to 1967, and Assistant Director ofdie Division ofField Studies from 1967 to 1972. Mr. Ayerhas been with the University ofCincinnati, Institute ofEnvironmental Health (Kettering Laboratory) as a Professor and Emeritus Professor since 1972. From 1982 to 1983, Mr. Ayer took a sabbatical year in safety engineering at Texas A&M. 500260 Mr. Ayer has served on numerous committees in die field ofindustrial hygiene. As a member of the ACGIH, Mr. Ayer served on the Air Sampling Instruments Committee, the Energy Committee; the Ventilation Committee, and die Committee on Environmental Factors inthePneumoconioses (which he chaired forthree years). Mr. Ayer also chaired the adhocjoint A1HA-ACCHH CommitteeonUniform Methods in Impinger Counting. Mr. Ayerhas authored over40 published papers on matters ofindustrial hygiene. Mr. Ayer's testimony will be based on his knowledge, training and experience in the field of industrial hygiene as it relates to asbestos and asbestos-containing products. Mr. Ayer will also testify as to the state of industrial hygiene at various points in time. M. Ayer may also testify as to the asbestos exposures which Plaintiff would have had at various times during his employment history. Defendant ASARCO reserves the right to supplement this information based on documents or testimony concerning exposure levels which to date have not been discovered. 9. flrrtny Vf T Jnyap Ph TV nirectnr Environmental Sciences Laboratory offoe Institute ofApplied Sciences, BrooklynCollege ofthe CityUniversityofNewYork, Brooklyn,New York 11210. Dr. Langer received his Bachelor of Arts degree b Geology from Hunter College, City University of New York in 1956. In 1962, Dr. Langer received his Master of Arts in Petrology (geology) from Columbia University. Dr. Langer received his Ph.D. in Mineralogy from Columbia in 1965. Dr. Langermay testify as to his background, training, experience, fellowship*, memberships and other professional activities, honors and awards, editorial board service, appointments, publications in peer reviewed journals, abstracts and symposia proceedings, contributions to books, monographs and reports, national, international and regional committees and consultations, national and international invited seminars, lectures, meetings and conferences, and his participation in post-graduate education 500260 7 courses as fully set forth on his C.V. Dr. Laager may further testify as to his extensive study and experimentation with regard to die family ofminerals commonly referred to as asbestos. 10. Robert Murray. M.D.. South Hill, Church Road, Newton Green, Sudbury, Suffolk, CO 10 OQP, United Kingdom. Dr. Murray was an occupational health consultant He qualified in medicine in 1939 at Glasgow University. From 1941 to 1946 he served in the RA.M.C. in West Africa, India and Burma and was mentioned in despatches. Dr. Murray received bis Diploma in Public Health in January, 1947. In April 1947 he became one ofonly 12 ofHer Majesty's Medical Inspectors ofFactories and was assigned to the Bast Lancashire Division based inManchester where he remained until 19S6. While there, his Chief was E.R.A. Merewether. Dr. Murray regularly visited the asbestos factories within his jurisdiction including Turner Brother's Asbestos, British Belting and Asbestos, and Cape Asbestos. As a Medical Inspector, Dr. Murray's duties included assisting foe District Inspector in foe implementation ofthose parts ofthe Acts and Regulations dealing with occupational health. This included the Asbestos Industry Regulations of 1931. In 1949 he received the Diploma in Industrial Health of the Society of Apothecaries and lectured in Professor Lane's Department ofOccupational Health in Manchester. Dr. Murray joined the International Labour Office (ILO) in Geneva in 1956 and remained thereuntil 1961. Dr. Murray then became Medical Advisor to the TUC in London, a post which he held until 1974. During the 1960's and 1970's he assisted the TUC in its actions against asbestos which lead to the Asbestos Regulations of 1969. In 1974, Dr. Murray began independently consulting in occupational health. He consulted with a number offirms and organizations including the Asbestos Information Association. He served as the Convenor of the Medical Advisory Panel and Scientific Advisory Panel until 1992. In 1975 he became Secretary-Treasurer ofthe Permanent 600280 a Commission on Occupational Health, now known as the International Commission on Occupational Health, and from 1981 to 1987 he was its President. Dr. Murray's other qualifications include Membership (1963) and later Fellowship (1970) of the Royal College of Physicians of Glasgow, honorary Doctor ofTechnology of the University ofBradfbrd, honorary Fellowship ofthe Institution ofOccupational Safety and Health, Fellowship ofthe Faculty ofOccupational Medicine ofthe Royal College of Physicians ofIreland, Fellowship of the corresponding Faculty of the Royal College of Physicians of London, honorary Fellowship of the Royal Society ofMedicine, honorary Fellowship of the Institute ofOccupational Hygienist* and honorary Doctor of Science of the University of Glasgow. Dr. Murray kept in close touch with the increasing amount ofliterature concerning asbestos. He assisted the Asbestos Institute in Montreal m its efforts to ensure die safe use of asbestos. He participated in the ILO discussions in 1985 and 1986 whieh resulted in the Convention and Recommendation on the Safe Use of Asbestos and participated in seminars in Turkey, Malaysia, Thailand and Taiwan. On thebasis ofDr. Murray's personal knowledge and experience concerning issues regarding the health hazards of asbestos, and the historical developments relating io the development of knowledge concerning asbestos-related diseases and his knowledge of die medical literature, Dr. Murray wilt testify by deposition or videotape as to the state of knowledge concerning what an employer could have and should have known during particular time periods with regard to both the dangers of asbestos use and methods ofminimizing those dangers via proper hygiene measures. 11. Robert Brown. 1169 Pointeview Road, Chapin, South Carolina. Mr. Brownreceived his B.S in chemical engineering from the University of South Carolina in 1935. In or about 1948 300260 9 or 1949, he obtained a Master of Public Health Degree from Johns Hopkins University School of Hygiene and Public Health. Mr. Brown began his career in 1936 as a chemical engineer with the Division oflndustrial Hygiene of the South Carolina State Board of Health where he worked with an industrial hygiene physician. Mr. Brown was responsible for performing a complete survey on a large sampling basis, including dust studies, of South Carolina industries and to develop information of any existing or suspected industrial hygiene problems. In January, 1942, Mr. Brown was employed as the Chiefoflndustrial Hygiene Services for foe Health Division ofthe City ofSt. Louis, Missouri. In 1949, he accepted a position on the faculty ofthe School of Public Health at Yale University where he taught public and occupational health. In 1951, Mr. Brown joined the Maryland State Department ofHealth to facilitate the development offoe Maryland Bureau oflndustrial Hygiene. Mr. Brown accepted a position with the National Sanitation Foundation in Ann Arbor, Michigan in 196S. In 1967 he became the president of the National Sanitation Foundation and remained in that capacity until his retirement in 1980. Mr. Brownwas a charter memberand organizeroffoe National Conference ofGovernmental and Industrial Hygienists (NCGIH), established in or around 1938. This organization later changed its name to the American Conference of Governmental and Industrial Hygienists (ACGIH). Mr. Brown served as a member of this organization's Executive Committee, Constitutional Review Committee and Industrial Hygiene Codes Committee. The latter committee was responsible for establishing maximum allowable concentrations (MAC) and threshold limit values (TLV). In 1946 foe Subcommittee on Threshold Limits of foe ACGIH recommended a MAC for asbestos of 6 million particles per cubic foot of air. 600260 10 Mr. Brown was also a member of the American Industrial Hygiene Association (AIHA). This organization also proposed TLVs and MAC'S which were published as Hygiene Standards in the April, 1958 issue American Industrial Hygiene Association Journal and recommended maximum atmospheric concentrations for asbestos over 8 hours of5 million particles per cubic foot ofair. This publication also listed potential hazards of asbestos which noted that in addition to asbestosis there had been reports of an increased risk of lung cancer. On the basis of Mr. Brown's personal knowledge of the facts surrounding the adoption of asbestos exposure standards, his training and experience in the areas ofindustrial hygiene and his review of the literature, Mr. Brown will testify by videotape or deposition, with regard to the composition ofthe membership ofthe ACGIH and its predecessor, the NCGIH and the AIHA. Mr. Brown will also testify by videotape or deposition, with regard to the facts and circumstances surrounding the proposal and adoption of the asbestos standards and his involvement in these processes. In addition, Mr. Brown may testify by videotape or deposition, with regard to the state of industrial hygiene knowledge during the 1930's, 1940's and 1950's. 12. Leonard J. Bristol. M.D. Dr. Bristol received his MJD. ini 944 from the Long Island College of Medicine. From 1944 to 1945 he had a general rotating internship at St Catherine's Hospital in Brooklyn, New York and from July, 1945, to April, 1946, was a resident in radiology at the Long Island College Hospital. From 1946 to 1948, Dr. Bristol was andrologist at the United States Naval Hospital, National Naval Medical Center in Bethesda Maryland. During that period of time he also served as a fltll-dme fellow in the Department ofRadiology at the Johns-Hopkins University Medical School. He was certified by the American College ofRadiologists in 1949, In 1949, he assumed a full-time position as a radiologist at die Trudeau Sanitorium and die Saranac Lake Laboratory where he remained through the end of 1978. Dr. Bristol has been engaged in the 500260 It PM practice ofradiology at the General Hospital in Saranac Lake, the Placid MemorialHospital, in Lake Placid, the Alice Hyde Hospital in Malone, New York and was a member of the Department of Radiology at the Edward L. Trudeau Foundation through 1978. Since 1949 approximately SO percent of Dr. Bristol's practice involved chest diseases and 25 to 30 percent ofhis overall practice involved occupational lung disease. He has reviewed several hundred thousand films ofworkers with occupational lung disease. Dr. Bristol was instrumental in the development of the ILO/UICC classifications for asbestos related diseases. On the basis of Dr. Bristol's knowledge, training and experience as a radiologist and his personal knowledge of the research and experiments conducted by the Trudeau Foundation and Saranac Laboratories, Dr. Bristol may testify by deposition or videotape as to die general radiological characteristics and diagnosis of asbestos-related diseases. 13. John E. Craighead. MD.. 1845 Four Winds Road, Fcrrisburgh, VT 05456. Dr. Craighead is a clinical and anatomical pathologist specializing in pulmonary pathology. Dr. Craighead will testify generally as to his background, training end experience. Dr. Craighead will testify as to his knowledge of pathology and asbestos-related diseases. He will Anther testify as to the general medical issues concerning the development, cause, and diagnosis of asbestos-related disease and/or other diseases that may mimic asbestos-related diseases. Dr. Craighead will testify generally as to the dangers posed by die inhalation of asbestos fibers and the relative risks associated with exposure to low levels of airborne asbestos. Dr. Craighead may also address thresholds of exposure below which there is no measurable increased risk of contracting an asbestos-related disease and the latency periods required for the development of the various asbestos-related diseases. 500260 12 Dr. Craighead may review the pathological evidence in this case, if any, and testify concerning whether it is diagnostic of asbestos-related disease. Dr. Craighead may also testify concerning asbestos fiber counts in the lung tissue ofdifferent populations and their significance with regard to dose-response relationships and causation. Dr. Craighead may offer such other opinions as may become necessary to rebut the opinions of Plaintiffs experts. Dr. Craighead may base his testimony on the available medical and scientific literature, his own training and expertence, the opinions and reports ofother experts named or to be named by any other party, whether presented live or by deposition, the testimony of all other witnesses named or to be named by any other party, whether live or by deposition, and any documents introduced into evidence or otherwise used by any party at the time oftrial. 14. ASARCO reserves the right to seek leave ofcourt to call experts who are substituted for experts on this list who become unavailable. ASARCO further reserves the right to call additional expert witnesses for the purpose of rebuttal or impeachment, if necessary at the time of trial. Thd general description of the area of expertise of each expert's anticipated testimony is not intended to limit such testimony, but is merely an indication of the broad area in which they may offer testimony. ASARCO reserves the right to supplement this designation up to the time of trial. 500260 V Respectfully submitted, RAY, McCHRlSXIAN it JEANS. P.C. A Professional Corporation 5822 Cromo Drive, Suite 400 El Paso, Texas 79912 915-832-7200 Telephone 915-832-73331 Facsimile Date: March 8,2001 By. ROBIN COLLINS Texas State Bar Number 0462350 DAVID S. JEANS Texas State Bar Number 10597400 Of Counsel; PORZIO, BROMBERG & NEWMAN, P.C. 100 Southgate Parkway Morristown, New Jersey 07962-1997 (973) 538-4006 Fax: (973) 538-5146 Attorneys for Defendant ASARCO Incorporated, formerly known as American Smelting and Refining Company CERTIFICATE OF SERVICE I hereby certify that pursuant to Rule 21, TJRCJP., on the above date a true and correct copy of the foregoing instrument was delivered as follows: See Attached Service List Delivered Vb: ___ Facsimile ___ Certified Mail ___ Regular Mail ___ Hand Delivery ___ Overnight Mail 500260 14 NO. 2000-2591 01 MAR-8 PH 2:II JOSE ROSENDO MARTINEZ, SR. and ELENA IN THE COUNTY COI^ OUNTY. TEXAS LOPEZ MARTINEZ, Plaintiffs, vs. U* AT LAW NO. THREE m[ L VERITY GAP CORPORATION (successor to RUBEROID CORPORATION), etal.. Defendants. EL PASO COUNTY, TEXAS CERTIFICATE OF WRITTEN DISCOVERY Defendant hereby certifies to the Court that the following discovery requests, in the above-referenced cause, has been properly served upon Plaintiff. 1. Defendant ASARCO Incorporated's Designation ofExpert Witnesses. Respectfully Submitted, RAY, MCCHRISTIAN & JEANS, P.C. By:. David S. JeansSBOT #1059740 Robb Collins SBOT # 04623500 5822 Cramo, Suite 400 El Paso, Texas 79912 (915) 832-7200 FAX: 832-7333 Of Counsel: PORZIO, BROMBERG & NEWMAN, P.C. 100 Southgate Parkway Morristown, New Jersey 07962-1997 (973) 538-4006 FAX: 538-5146 Attorneys for Defendant, ASARCO Incorporated, formerly known as American Smelting and Refining Co. Q CATE OF SERVICE I hereby certify that pursuant to Rale 21, T.R.C.P., on the above date a true and correct copy of the foregoing instrument was delivered as follows: See Attached Service List Delivered Via: JC Facsimile ___ Certified Mail ___ Regular Mail ___ Hand Delivery ___ Overnight Mail By. <2IS Of Counsel 68314 2 Ray, McChristian & Jeans AttomytaadCwaatlan at Law A Profasslona] Corporation SBXCtWBD El PaM, Tncat 79912 (915) 02-7200 Tdaphao. (915) 02*7333 Facalatila March 8,2001 ItoMlCbliM* IMRwa DwUS. Jnm toilMfcp MuW.MeCWsjm, Jr* Todd&MstUhSdUKdaMinMt CMmMMm fa--AHiwH.lf! LmUtMmki- Jin^ ItttyZmli >--*l| jTM<L Ms. Nicole Brown Kennedy BARON & BUDD, P.C. The Centrum, Suite 1100 3102 Oak Lawn Avenue Dallas,Texas 75219 RE: Martinez v. ASARCO Cause No. 2000-2591 Dear Ms. Kennedy: Enclosed please find ASARCO Incorporated's Designation of Expert Witnesses which has been filed today. RC/sc #<L