Document JJ1Jg2OMNNyzvXxoKq8pd89Lr

NO. 98-03869-G GILBERTO ANTONIO BALLI, et al., Plaintiffs, v. OWENS CORNING (a/k/a OWENS CORNING CORPORATION), et al., Defendants. IN THE DISTRICT COURT NUECES COUNTY, TEXAS 319th JUDICIAL DISTRICT DEFENDANT REYNOLDS METALS COMPANY'S RESPONSES TO PLAINTIFFS' RULE 194 REQUESTS FOR DISCLOSURE Defendant Reynolds Metals Company ("Reynolds"), by counsel, pursuant to Rule 194 of the Texas Rules of Civil Procedure, responds as follows to Plaintiff Freddie Joe Bamec's ("Bamec") and Plaintiff Aurelio Sais Marroquin's ("Marroquin") Requests for Disclosure: A. The correct names of the parties to the lawsuit. Reynolds states that its correct name is Reynolds Metals Company; it is without knowledge as to the correct names of the other parties to the lawsuit. B. The name, address, and telephone number of any potential parties. At this time, Reynolds is not aware of any "potential parties." Reynolds reserves the right to supplement its response to this request pursuant to Texas Rule of Civil Procedure 193. C. The legal theories and, in general, the factual bases of the responding party's claims. Subject to the foregoing statement. Reynolds refers plaintiffs to its Special Exceptions, Original Answer and Affirmative Defenses to Plaintiffs' Original Asbestos Petition. Motion to Transfer Venue and Motion to Drop or Sever filed on September 14. 1998. At this time. Reynolds DFFFNDWT RFANOLDS MET\ES COMPANY'S RESPONSES TO PLAINTIFFS' RULE 194 REQL ESTS FOR DISCLOSURE - PAGE I expects that its defense will be based on documentary and testimonial evidence (including lay and expert testimony) that: Plaintiff Bamec was not exposed to harmful levels of asbestos as an independent contractor at Reynolds' Sherwin Plant; Plaintiff Marroquin was not exposed to harmful levels of asbestos as an independent contractor at Reynolds" San Patricio Plant; Plaintiffs have no asbestos-related illness or injury Reynolds did not breach any duty of care owed to Plaintiffs; Reynolds was not negligent; Plaintiffs voluntarily and knowingly assumed the risk of incurring the injuries or damages alleged; and Plaintiffs were contributorilv negligent. D. The amount and any method of calculating economic damages. At this time. Plaintiffs have not disclosed the amount of damages they seek nor the method of calculating such damages. Although Reynolds generally denies that grounds exist for damages. Reynolds cannot respond specifically to plaintiffs' claimed damages and/or damage calculation. Reynolds therefore reserves the right to supplement its response to this Request until such time as plaintiff has provided this information. E. The name, address, and telephone number of persons having knowledge of relevant facts, and a brief statement of each identified person's connection with the case. Investigation and discovery is ongoing in this matter, and. at this time, Reynolds does not know each and every individual who has knowledge of the relevant facts, nor does Reynolds know at this time whom it may call to testify at the trial of this matter. Reynolds therefore reserves the right to supplement its response to this Request in accordance with Rule 193 of the Texas Rules of DEFENDANT REYNOLDS METALS COMPANY S RESPONSES TO PLAINTIFFS RL LE 194 REOLESTS FOR DISCLQSL RE - PAGF 2 Civil Procedure. At this time. Reynolds identifies the following individuals who may have knowledge of relevant facts and w ho Reynolds may call to testify at the trial of this matter: 1) Plaintiffs Freddie Joe Bamec 4018 Kevin Corpus Christi, Texas 78413 Aurelio Sais Marroquin 102 West Avenue B Robstown, Texas 78380 2) Any and all Family Members of the Plaintiffs 3) Treating Physicians. Reynolds may call some or all of the following individuals as trial witnesses to offer testimony, including expert testimony, about their care, treatment and diagnosis of Plaintiffs : Dr. John Paul Schultze Dr. Mark Strauss Dr. Alan Zane Dr. Richard Evans Dr. Robert May Dr. Peter A. Petroff Dr. Ernesto Bondarevsky 4) Coworkers. To date. Plaintiffs Bamec and Marroquin have identified the following seventeen coworkers, who Reynolds may call to testify at trial. Dick Lungstrom Clarence Rosher DEFEM)AM REYNOLDS MET \LS COMPANY'S RESPONSES TO PLAINTIFFS' RILE 194 REQUESTS FOR DISCLOSURE - PAGE 3 Bill Sin Maurice Hershep Bill Horn Hanna Holsa Paul Barrego A1 Rivera Mike Barton Roger Olds Mike Roldan Damacio Sanchez Mingo Maldonado Leonard Wiess Robert Alizondo Robert Grajeda Dondald Guilloy Reynolds reserves the right to supplement its response to this request if and when it determines the names and locations of additional witnesses. 5) Reynolds Personnel/Witnesses (a) Sherwin Alumina Plant Personnel. Reynolds may call some or all of the following individuals who were employed at various times at the Sherwin Alumina Plant to testify as to their personal knowledge concerning plant operations and plant conditions; the use of asbestos-containing products in plant operations: the elimination and abatement of asbestos; DEFENDANT REYNOLDS METALS COMPANY'S RESPONSES TO PLAINTIFFS' RILE 104 REQUESTS FOR PISCLOSL RE - PAGE 4 Reynolds' safety procedures, both in general and as they relate to asbestos (including the use of respirators); and. other matters relevant to plaintiff s claims and/or Reynolds' defenses; Dr. John Frandolig RR 1, Box 358 Lake Geneva, WI 53147 Dr. Frandolig was the Sherwin Alumina Plant Medical Director from 1989-91. He may be called to testify about his knowledge regarding Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about his knowledge related to asbestos exposure procedures. Dr. Guy Racette 8122 Deck Street Corpus Christi, TX 78412 Dr. Racette was the Sherwin Alumina Plant Medical Director from 1991-93. He may be called to testify about his knowledge regarding Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about his knowledge related to asbestos exposure procedures. Dr. Wendell Roberts 620 West Johnson Avenue Arkansas Pass, TX Dr. Roberts is the current Sherwin Alumina Plant physician. He may be called to testify about his knowledge regarding Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may also be called to testify about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses. Deloris Ulke Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Ms. Ulke was the Head Nurse at Sherwin Alumina Plant Medical Department. She may be called to testify about her knowledge about Reynolds' attitude toward employee health in general, as well as general information regarding the Medical Department at the Sherwin Alumina Plant. She may also be called to testify about her knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses. DEFENDAN f REA N01.DS METALS COMPANY S RESPONSES TO PLAINTIFFS Rl LE 194 REOLESTS FOR DISCLOSL RE - PAGE ? C. Arlon Boatman Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Boatman is the Health & Safety Manager for the Sherwin Alumina Plant who may be called to testify about his knowledge of Reynolds' safety procedures and the use of asbestos-containing products at the Sherwin Alumina Plant, as well as other information. He may also be called to testify about the operation of the Sherwin Alumina Plant Medical Department, including the Respiratory Surveillance Program. He may also be called to testify about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses. Terry N. Roubidoux Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Roubidoux was the Safety Coordinator for the Sherwin Alumina Plant from 1992-June 1997. He is currently the Area II Business Unit Superintendent at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures and the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. He may also be called to testify about his knowledge related to asbestos exposure procedures and other matters relevant to plaintiffs claims and/or Reynolds' defenses. A.S. "Stan" Millsap 5541 Bear Lane, Ste. 236 Corpus Christi, TX 78405 Mr. Millsap was the Safety Coordinator at the Sherwin Alumina Plant. He may be called to testify about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding OSHA and MSHA requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be called to testify' about his knowledge regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training. He may further be called to testify' about his knowledge of asbestos abatement at the Sherwin Alumina Plant. DEFEND WT REYNOLDS METALS COMP WV S RESPONSES TO PLAINTIFFS' RILE 194 REQUESTS FOR DISC L.OSL RE - PAGE 0 Darrell L. Lentz 2406 West Frank Street Apartment 114 Lufkin, Texas (409) 632-9345 Mr. Lentz was the Safety Director at the Sherwin Alumina Plant from 1977November 1982. He may be called to testify about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding OSHA and MSHA requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be called to testify about his knowledge regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training. He may further be called to testify about his knowledge of asbestos abatement at the Sherwin Alumina Plant. Ernest L. Sweet 114 Glenwood Drive Liverpool, New York 13090 (315)652-6543 Mr. Sweet was the Superintendent for Environmental Health and Safety from 1980- October 1985. He may be called to testify about his knowledge regarding respirator use at the Sherwin Alumina Plant, regarding OSHA and MSHA requirements and the implementation of the requirements at the Sherwin Alumina Plant, as well as information related to other safety procedures. He may also be called to testify about his knowledge regarding the responsibilities of the Safety Department as they relate to asbestos at the Sherwin Alumina Plant, safety meetings that were conducted and employee training. He may further be called to testify about his knowledge of asbestos abatement at the Sherwin Alumina Plant. William E. Hamblin Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Hamblin was a Senior Maintenance Engineer at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Lou Suffredini Austin, Texas DEFEND \M RE> NOLDS ME I' VLS COMPANY S RESPONSES TO PLAINTIFFS RL1.H 194 REGIES FS FOR DISCLOSIRE - P\GE 7 Mr. Suffredini was the Plant Manager of the Sherwin Alumina Plant. He was employed at the Sherwin Alumina Plant from the early 1950s-1977. He may be called to testify about his knowledge of Reynolds' safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Timothy D. Woods Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Woods is the Plant Controller at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Frank Strickland Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Strickland is the Purchasing Manager for Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. D. T. Greeson Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Greeson is a Purchasing Agent for Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. James C. Tiffany Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 DEFEND WT REYNOLDS METALS COMPANY'S RESPONSES TO PLAINTIFFS RILE 194 REOLESTS FOR DISCLOSURE - PAGE 3 Mr. Tiffany was the Plant Engineer at the Sherwin Alumina Plant from approximately 1973-76 and was a General Engineer, Maintenance Superintendent, and Senior Engineer for various periods from 1964-73 and 1985 to the present. He may be called to testify about his knowledge of the use of products that contained asbestos, the elimination of some asbestos-containing products, and asbestos abatement. He may also be called to testify about his knowledge of Reynolds' safety procedures, and use of safety equipment at the Sherwin Alumina Plant, as well as other information. Jack C. Oates Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Oates was the Plant Engineer at the Sherwin Alumina Plant from 1980-84 and was Maintenance Engineer, Project Engineer, and Project Manager for various periods between 1967-74 and 1977-91. He is currently the Senior Engineering Supervisor at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant. Howard Grote Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Grote has been Project Engineer and Maintenance Engineer for various periods of time between 1970 and the present. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant. Ed Peterson Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Peterson has been in the Engineering Department at Reynolds' Sherwin Plant since 1973. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant. DEFENDANT RFA NQLDS MET -MS COMPAWS RESPONSES TO PLAINTIFFS RILE 194 RHQLESTS FOR DISCLOSLRE - PAGE 9 Paul Matula Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Matula is a Designer in the Engineering Department of Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Mario Rivera Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Rivera was a maintenance supervisor in Area 50 of Sherwin Alumina Plant. He is currently in the Industrial Hygiene Department of the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Charles Chapman Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Chapman was a maintenance supervisor in Area 50 of Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Jeffrey Downs Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Downs is the current maintenance supervisor in Area 50 of Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. DEFENDANT RFA NOLDS METALS COMPANY S RESPONSES TO PLAINTIFFS' RILE 194 REQUESTS FOR DISCLOSURE PAGE 10 Gary Cedotal Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Cedotal was the maintenance supervisor for Areas IV and V of the Sherwin Alumina Plant from 1989-93. He is currently the Shift Maintenance Supervisor. He may be called to testily about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Ernest Coulter Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Coulter was the Maintenance Supervisor and General Foreman in the Maintenance Department at the Sherwin Alumina Plant from 1963-90. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Ludwig Jahn Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Jahn has been the Maintenance Supervisor in the Maintenance Department at the Sherwin Alumina Plant since 1989. Prior to this position, Mr. Jahn held numerous jobs in the Maintenance Department in the 1970s. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Hector De La Garza Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 DEFEND \NT RFA COLDS METMS COMPANY S RESPONSES TO PLAINTIFFS RILE 194 REOLESTS FOR D1SCLOSLRF. - PAGE ! 1 Mr. De La Garza is in the Environmental Department of the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Adan J. Villarreal Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Villarreal is a Cost Accountant at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Lester Charles Homan Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Homan is a Senior Accountant at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Ernest Boulware 215 Seco Portland, TX 78374 Mr. Boulware is a retired carpenter, laborer and maintenance mechanic from the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Frank Hall, Jr. 401 Rabbit Run Road Arkansas Pass, TX 78336 Mr. Hall is a building and trade mechanic, employed with the Sherwin Alumina Plant since the late 1950s. He may be called to testify concerning his knowledge of the work environment. Reynolds' safety procedures, the use of products which contained DEFENDANT REYNOLDS METALS COMPANY'S RESPONSES TO PLAINTIFFS RLLE 194 REOLESTS FOR DISCLOSE RE - PAGE 12 asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Weldon Hesseltine Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Hesseltine is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1955. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Leroy Rhoads Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Rhoads is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1969. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, the involvement of the Union in safety matters at the Sherwin Alumina Plant, as well as other information. Howard Cave Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Cave is a member of the Maintenance Department at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Ronald Hesseltine Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Hesseltine is a supervisor, employed with the Sherwin Alumina Plant. He worked as an hourly equipment cleaner from 1965-88. He was promoted to supervisor in DPI END AST RE> COLDS METALS COMPANY'S RESPONSES TO PLAINTIFFS RLLE 194 RF.OLESTS FOR DISCLQSl. RE - PAGE 13 1988 and worked as a supervisor in Areas IV and V from 1994-96. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Jimmie Lehman Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Lehman is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Howard Bittel Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Bittel is a building and trade mechanic, employed with the Sherwin Alumina Plant since 1987. He may be called to testily concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Chuck Coulter Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Coulter is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testily concerning his knowledge of the work environment. Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Willie Enriquez Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 DEFENDANT REYNOLDS MET \LS COMPWVS RESPONSES TO PLAINTIFFS' RULE 194 REOIESTS FOR D1SCLOSLRE - P \GE 14 Mr. Enriquez is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Mike Gonzales, Jr. Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Gonzales is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. A. Littlejohn Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory , TX 78469 Mr. Littlejohn is a building and trade mechanic, employed with the Sherwin Alumina Plant. He may be called to testify concerning his knowledge of the work environment, Reynolds' safety procedures, the use of products which contained asbestos, and the abatement of asbestos at the Sherwin Alumina Plant, as well as other information. Tony Dunn Sherwin Alumina Plant P.O. Box 9911 Highway 361 Gregory, TX 78469 Mr. Dunn was the Process Engineer at the Sherwin Alumina Plant from 1963-70 and was Technical Manager and Superintendent, and Operating Superintendent for various periods between 1974-76 and 1978-95. He is currently the Training Manager at the Sherwin Alumina Plant. He may be called to testify about his knowledge of Reynolds' safety procedures, safety equipment, the use of products which contained asbestos, and abatement of asbestos at the Sherwin Alumina Plant, as well as other information. (b) San Patricio Reduction Plant Personnel. Reynolds may call some or all of the following individuals who were employed at various times at the San Patricio Reduction DFFEMJAN F REYNOLDS METALS COMPANY'S RESPONSES TO PLAINTIFFS RULE 194 REOL ESI S FOR DISCLOSE RE - PAGE 15 Plant to testify as to their personal knowledge concerning plant operations and plant conditions; the use of asbestos-containing products in plant operations; the elimination and abatement of asbestos; Reynolds' safety procedures, both in general and as they relate to asbestos (including the use of respirators); and, other matters relevant to plaintiff s claims and/or Reynolds' defenses: Robert Dale Gamble, M.D. 5301 St. Andrew Corpus Christi, Texas 78413 (512) 991-2985 Dr. Gamble was the San Patricio Reduction Plant and/or Sherwin Alumina Plant Medical Director from 1975-85. He has knowledge regarding the Respiratory Surveillance Program at the San Patricio Reduction Plant. He also may have knowledge of Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may have knowledge related to asbestos exposure procedures. Harry R. Bratt, M.D. 2040 Birch Ave. Saint Helena, CA 94574 Dr. Bratt was the San Patricio Reduction Plant and/or Sherwin Alumina Plant Medical Director from 1971-75. He has knowledge regarding the Respiratory Surveillance Program at the San Patricio Reduction Plant. He also may have knowledge of Reynolds' safety procedures in general, as well as specific safety procedures as they relate to asbestos. He may have knowledge related to asbestos exposure procedures. Mr. E. W. Dressen 221 Blanco Portland, Texas 78374 (512) 643-2104 Mr. Dressen was the an Engineer and Reduction Superintendent at the San Patricio Reduction Plant. He also was the acting plant manager of the San Patricio Reduction Plant from 1974-79 and from 1981 until the plant closed. He may have knowledge regarding plant operations; various applications of asbestos-containing products throughout the plant; the use. elimination and/or substitution of asbestos-containing products; and Reynolds' attitude toward safety and employee health in general. Kenneth E. Murphree 458 Caroline Acres Point Hot Springs, Arkansas 71913 (501)525-3726 DEFENDAN f REYNOLDS METALS CQMP.AM S RESPONSES TO PLAINTIFFS RILE 194 REOLESTS FOR DISCLOSl.RE - PAGE 16 Mr. Murphee was the plant manager of the San Patricio Reduction Plant from 197981. He may have knowledge regarding plant operations; various applications of asbestoscontaining products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information. William E. Campbell 7746 East Laguna Azul Apartment #272 Mesa, Arizona 85208 (602) 357-9978 Mr. Campbell was the plant manager of the San Patricio Reduction Plant from 1972-77. He may have knowledge regarding plant operations; various applications of asbestos-containing products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information. Mr. Harry V. Helton 509 Kilmarnock Drive Richmond, Virginia 23229 (804) 740-7705 Mr. Helton was employed at the San Patricio Reduction Plant from 1966-72 and held positions as potroom supervisor, general plant supervisor and, from 1971-72, plant manager. He may have knowledge regarding plant operations; various applications of asbestos-containing products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information. Mr. Clyde Doyce Hester 546 Evergreen Drive Corpus Christi, Texas 78412 Mr. Hester was the chief chemist at the San Patricio Reduction Plant from 1953-89. He may have general knowledge about the plant processes, environmental issues (including asbestos abatement issues) and other information. Mr. Allen G. Hill 418 Fetick Avenue Taft, Texas 78390-2808 (512) 528-2749 DEFEND \N f RE'i NQLDS MET \LS COMPANY S RESPONSES TO PLAINTIFFS RLLE 194 REQUESTS FOR D1SCLOSLRE - P-\GE 1 7 Mr. Hill was a chemist at the San Patricio Reduction Plant from 1967-85. He may have general knowledge about the plant processes, environmental issues (including asbestos abatement issues) and other information. Mr. William D. Pipes P.O. Box 148 Crozier, Virginia 23039 (804) 784-1250 Mr. Pipes held the following titles at the San Patricio Reduction Plant from 196677: process engineer, power plant supervisor; and maintenance superintendent. He also was the plant engineer from 1979-82. He may have knowledge about the use and application of asbestos-containing products, elimination and/or substitution of asbestoscontaining products, general health and safety issues and other relevant information. Mr. Kenneth W. Younger 12604 Hardings Trace Court Richmond, Virginia 23233 (804) 281-4111 Mr. Younger was a project engineer at the San Patricio Reduction Plant from 197077 and 1980-85. He may have knowledge about the use and application of asbestoscontaining products, elimination and/or substitution of asbestos-containing products, general health and safety issues and other relevant information. Mr. Brice G. Nelson 1045 Wilshire Corpus Christi, Texas 78411 (512) 852-4535 Mr. Nelson was involved in the original construction and operation of the carbon plant at the San Patricio Reduction Plant, and he worked at the San Patricio Reduction Plant from approximately 1951-69, and from 1974-76. He may have knowledge regarding the construction and processes of the San Patricio Reduction Plant in general, the availability and use of personal protective equipment, general health and safety issues and applications of asbestos products in the plant. Mr. Raymond L. Bennett 414 Reynolds Avenue Taft, Texas 78390 (512) 528-3284 Mr. Bennett was the power plant supervisor at the San Patricio Reduction Plant from approximately 1953-84. He may have knowledge regarding plant operations in DEFENDANT REA \OLDS METALS COMP VN\ S RESPONSES TO PLAINTIFFS' RULE 194 REQUESTS FOR DISCLOSURE - PAGE 18 general and the operation of the power plant in particular. He also may have knowledge regarding applications of asbestos products in the power plant. Mr. John L. Massey P.O. Box 73 Bayside, Texas 78340 (512) 529-6692 Mr. Massey was a foreman in the San Patricio Reduction Plant maintenance department from approximately 1952-88. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment, general health and safety issues and other relevant information. Mr. James C. Black 224 Bafanridge Drive Hot Springs, AR 71901 (501) 624-7244 Mr. Black was employed at the San Patricio Reduction Plant as a potroom foreman from 1960-63. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues, and other relevant information. Mr. Clyde A. Krueger 131 Granby Portland, Texas 78374 (512) 643-2421 Mr. Krueger was a general foreman at the San Patricio Reduction Plant from 195284. He may have general knowledge about the plant processes, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues. Mr. William E. Shepp 244 Ross Road Kelso, Washington 98626 (360) 578-2429 Mr. Shepp was a potroom engineer and casthouse supervisor at the San Patricio Reduction Plant. He may have knowledge about the use and application of asbestoscontaining products, elimination and/or substitution of asbestos-containing products, general health and safety issues and other relevant information. DEFENDAS f REYNOLDS METALS COMPANY'S RESPONSES TO PLAINTIFFS' RLLF. 194 REQUESTS FOR DISCLOSURE - PAGE 19 Mr. Harold L. Bern, Jr. 2341 East Lynnwood Drive Longview, Washington 98632 (206) 425-8082 Mr. Bern was the Personnel Manager at the San Patricio Reduction Plant from 1979-82 and may have knowledge about information relevant to this lawsuit. Mr. Joel W. Whitlock 6837 SE Cottrell Road Gresham Oregon 97080-8911 (503) 663-2096 Mr. Whitlock was employed at the San Patricio Reduction Plant from 1958-71 and, during that time, held the following titles and positions: potroom general clerk; potroom foreman; anode foreman; pot relining supervisor; maintenance supervisor and plant safety engineer. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety' issues, and other relevant information. Mr. Jack H. Norris, Jr. 4318 St. George Corpus Christi, Texas 78413 (512) 853-1021 Mr. Norris was a purchasing agent at the San Patricio Reduction Plant from 1976-86 and plant purchasing manager from 1986-88. He may have knowledge about the purchase, use and application of asbestos-containing products and/or substitutes for asbestoscontaining products, the purchase and use of safety equipment (including respirators), asbestos abatement and other relevant information. Richard C. Easterline 15 Serra Lane Massena, New York 13662 (315) 769-1996 Mr. Easterline was employed at the San Patricio Reduction Plant from 1968-82 and held positions as an engineer and carbon services supervisor. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safetv issues, and other relevant information. DEFENDANT REYNOLDS METALS COMPANY S RESPONSES TQ PLAINTIFFS' RILE 194 REQUESTS FOR DISCLOSE RE - P AGE 20 John W. Ford c/o Reynolds International P.O. Box 27002 Richmond, Virginia 23261 (503) 666-0203 Mr. Ford was the plant maintenance supervisor at the San Patricio Reduction Plant from 1979-83. He may have general knowledge regarding plant operations, the use and application of asbestos-containing products, the availability and use of personal protective equipment and general health and safety issues, and other relevant information. (c) Reynolds Corporate Personnel. Reynolds may call some or all of the following individuals to testify regarding their personal knowledge on matters of safety, medical and industrial hygiene issues on the corporate level and/or at the San Patricio Reduction Plant specifically; plant operations and conditions; the use, elimination and/or substitution of asbestos- containing products; and, on other matters relevant to plaintiffs claims and/or Reynolds' defenses: Woolson W. Doane, M.D. 14 W. Runsick Drive Richmond, Virginia Dr. Doane was Reynolds' Corporate Medical Director from 1993-97. He may be called to testify about his knowledge concerning corporate medical issues and the Respiratory Surv eillance Program at the Sherwin and San Patricio plants. David Warren, M.D. 8705 Tarytown Drive Richmond, Virginia 23229 Dr. Warren was the acting Corporate Medical Director from 1992-93. He may be called to testify about his knowledge concerning corporate medical issues. E. Claiborne Irby, M.D. 11-1/2 Tapoan Road Richmond, Virginia 23226 Dr. Irby was an Associate Corporate Medical Director from 1959-77, and Corporate Medical Director for Reynolds from 1977 until his retirement in 1992. He may be called as a factual witness, but because he also qualifies as an expert, he may offer expert, he may DEFENDANT RE'i \QLDS METALS COMPANY'S RESPONSES TO PLAINTIFFS RLLE 194 REQUESTS FOR DISCLOSIRE - PAGE 21 offer expert testimony in the fields of occupational medicine, state-of-the-art, governmental regulations, and medical issues in general as they may relate to occupational asbestos exposures. James MacMillan, M.D. 306 Gunby Drive Richmond, Virginia 23229 Dr. MacMillan was the Corporate Medical Director of Reynolds from 1956-77. He may be called to testify about his knowledge concerning corporate medical issues. Mr. Homer Mac Cole Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 (804) 281-3506 Mr. Cole is the Corporate Director of Industrial Hygiene and Toxicology at Reynolds. He has been an industrial hygienist at Reynolds since 1972. Mr. Cole performed industrial hygiene surveys at the San Patricio Reduction Plant and may testify regarding such surveys as well as' other factual matters based on his personal experience and knowledge, including, but not limited to, plant conditions, various uses of asbestoscontaining products in plant applications, the elimination and substitution of asbestoscontaining products, and general issues related to industrial hygiene and safety. Although Mr. Cole will testify as a factual witness, he qualifies as an expert and may offer expert testimony in the fields of industrial hygiene, occupational health and safety, state-of-theart. governmental regulations of workplace exposures, threshold limit values, the measurement of occupational asbestos exposures as well as other potential occupational hazards, respiratory protection, and proper work practices. Mr. Ronald E. Benton Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 (804)281-2000 Mr. Benton is Manager of Industrial Hygiene and Safety Services at Reynolds. He has been at Reynolds since 1974. He performed industrial hygiene surveys at the San Patricio Reduction Plant and may testify regarding such surveys as well as other factual matters based on his personal experience and knowledge. Mr. Benton may testify as a factual witness, but because he qualifies as an expert, he may offer expert testimony in the fields of industrial hygiene, occupational and environmental health and safety, stateof-the-art. governmental regulations of workplace exposures, threshold limit values, the measurement of occupational asbestos exposures as well as other potential occupational hazards, respiratory protection, and proper work practices. DEFENDANT RE'i NOLOS METALS COMPANY'S RESPONSES TO PLAINTIFFS' Rl.'LE 194 REOLESTS FOR DiSCLOSl.RE - P^GE 22 Ms. Linda Maillet Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 Ms. Maillet was the Regional Industrial Hygienist at the Corporate Headquarters of Reynolds for the Eastern Region. She is currently the Principal Health, Safety and Regulatory Affairs Scientist at the Corporate Headquarters. Ms. Laurie Shelby Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 Ms. Shelby was the Manager of Industrial Hygiene Programs at the Corporate Headquarters of Reynolds. She is currently the Manager of Health and Safety Programs. Mr. Richard Mansur 1416 Coronet Drive Richmond, Virginia 23229-4806 (804) 282-4438 Mr. Mansur was the Manager of the Industrial Hygiene Department at the Corporate Headquarters of Reynolds from 1969-75. Mr. James D. Davidson Mr. Davidson was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1976-82. Ms. Stacey Hansen 12701 Mirror Pond Way Midlothian, Virginia 23113 (804) 794-1736 Ms. Hansen was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1990-93. Mr. Dale Prokopchak 2704 Empress Court Richmond, Virginia 23233 (804) 360-3301 DEFENDANT REYNOLDS METALS COMPANY'S RESPONSES TO PLAINTIFFS' RLLE 194 REOLESTS FOR DISCLOSURE - PAGE 23 Mr. Prokopchak was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1988-89. Ms. Deborah R. Hudgins Ms. Hudgins was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1984-88. Mr. Harry L. Skalsky 6910 West Grace Street Richmond, Virginia 23261 Mr. Skalsky was a Medical Corporate Toxicologist at the Corporate Headquarters of Reynolds 1979-85. Ms. Karen Kestle 1336 Merrymeade Avenue Glen Allen, Virginia 23060 (806) 264-1789 Ms. Kestle was the Senior Insurance Administrator at the Corporate Headquarters of Reynolds. Mr. Bobby J. Sasser Mr. Sasser was the Corporate Safety Director for Reynolds from 1973-95. Mr. Joseph Nichols 2300 Cedarfield Parkway Apartment 161 Richmond, Virginia 23233 (804) 282-8245 Mr. Nichols was the Corporate Safety Director for Reynolds from 1945-73. 6) Records Custodians. Reynolds may call, live or by deposition or affidavit, various records custodians to authenticate relevant records, including, but not limited to, the records of Plaintiffs' medical care providers and the records of their employers. 7) Other Parties' Witnesses. Reynolds reserves the right to call and/or elicit testimony from any individual identified by plaintiffs and any other party to this lawsuit and, DEPENDANT REYNOLDS METALS COMPANY S RESPONSES TO PLAINTIFFS RLLE 194 REQUESTS FOR DISCLOSURE - PAGE 24 accordingly, will supplement its response to this request when those individuals have been identified. 8) Rebuttal / Impeachment Witnesses. Reynolds reserves the right to call rebuttal and/or impeachment witnesses and will supplement its response to this request if and when it has sufficient information to determine the need for such testimony. F. For any testifying expert: (1) The expert's name, address, and telephone number; (2) The subject matter on which the expert will testify; (3) The general substance of the expert's mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; (4) If the expert is retained by, employed by, or otherwise subject to the control of the responding party: (A) All documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and (B) The expert's current resume and bibliography. Pursuant to Rule 195 of the Texas Rules of Civil Procedure, Reynolds refers plaintiffs toits designation of Expert Witnesses that will be filed in accordance with the scheduling order of this court and the Texas Rules of Civil Procedure. G. Any discoverable indemnity and insuring agreements. Reynolds has insurance coverage sufficient to cover plaintiffs claims with the following insurance companies: Travelers Insurance (9/30/53 through 9/30/66) DEFHNFMN f RE't NQ1.DS METM.S COMPANY'S RESPONSES TO PLAINTIFFS' RULE 194 REOLESTS FOR DISCLOSI RE - PAGE 25  Liberty Mutual Group (9/30/66 through 9/30/78) H. Any discoverable settlement agreements. None. I. Any discoverable witness statements. None. J. All medical records and bills that are reasonably related to the injuries or damages asserted or, in lieu thereof, an authorization permitting the disclosure of such medical records and bills. See Reynolds' Response to Request K. K. All medical records and bills obtained by the responding party by virtue of an authorization furnished by the requesting party. Subject to plaintiffs' agreement to pay Reynolds one-half of its cost in retrieving these records, Reynolds will produce these records at $.15 per page or will make them available to plaintiff s counsel for inspection and copying at a mutually convenient time and place. DEFENDANT REWOLDS METALS COMPANY'S RESPONSES TO PLAINTIFFS' Rl'LF. 19-1 REQUESTS FOR D1SCLOSLRE - PAGE 26 REYNOLDS METALS COMPANY By: David Craig Tandin (Texas Bar No. 11863720) John D. Epps (Texas Bar. No. 00796079) Harry M. Johnson, III (Texas Bar No. 00797740) HUNTON & WILLIAMS 951 East Byrd Street Riverfront Plaza, East Tower Richmond, Virginia 23219 (804) 788-8200 (804) 788-8218 (facsimile) R. Clay Hoblit (Texas Bar No. 09743100) CHAVES, GONZALES & HOBLIT, L.L.P. 2000 Frost Bank Plaza 802 North Carancahua Corpus Christi, TX 78470 (512) 888-9392 (512) 888-9187 (facsimile) Attorneys for Reynolds Metals Company DEFEND AST REYNOLDS METALS COMP AM S RESPONSES TO PLAINTIFFS RLLF. 194 REQUESTS FOR DISCLOSE RF. - PAGE 27 CERTIFICATE OF SERVICE I hereby certify that on the C*' day of August, 2000, a true and correct copy of the above and foregoing instrument is being served by certified mail, return receipt requested, on the following Plaintiffs' counsel: Stephanie Finch BARON & BUDD. P.C. The Centrum Suite 1100 3102 Oak Lawn Avenue Dallas, Texas 75219 All other known counsel of record are given notice of this pleading by regular United States mail only. DEFE\DA\T REYNOLDS METALS COMPANY S RESPONSES TO PLAINTIFFS RL1.E 194 REQUESTS FOR D1SCLOSLRE - PAGE 28