Document KR525pVLwJ9vVqg0284Jy6gEK
Cooper was a party at the time) in any case alleging exposure to asbestos and/or asbestos-containing products / materials, reflecting testimony by:
(a) Any and all lay witnesses;
(b) Any and all independent expert witnesses;
(c) Any and/all controlled expert witnesses; and/or
(d) Any and all other persons possessing knowledge and/or information concerning the facts of this case.
N/A.
7. Any and all documents referring to, relating to,
and/or reflecting any and/or all of the
plaintiff(s)/decedent in this case.
N/A. By way of further response, answering defendant does not have any documents in its possession related to plaintiff that was not received from plaintiff's counsel.
8. Any and all documents and/or exhibits that will
and/or might be used by you at trial and/or in any other
proceeding in this case.
It is unknown at this time which documents and/or exhibits answering defendant intends to use at trial and/or
any other proceeding in this case.
Answering defendant
reserves the right to supplement this response.
ELZUFON AUSTIN REARDON TARLOV & MONDELL, P.A.
MATTHEW P. DONELSON Bar No. 4243 300 Delaware Avenue, P.0. Box 1630 Wilmington, Delaware (302) 428-3181
17TM Floor 19899-1630