Document MJMVxa1V5nMKBbK97zOY0LEx9

JOHN T. ORGAN PLAINTIFF'S EXHIBIT CAUSE NO. 00CV1053 S IN THE DISTRICT COUR' VS. GAF CORPORATION, ET AL GALVESTON COUNTY, TEXAS 122nd JUDICIAL DISTRICT DEFENDANT PHARMACIA CORPORATION'S, FORMERLY KNOWN AS MONSANTO COMPANY, INITIAL DESIGNATION OF EXPERT WITNESSES AND SUPPLEMENTATION OF RESPONSES TO REQUESTS FOR DISCLOSURE AND INTERROGATORIES Pursuant to the Texas Rules ofCivil Procedure, and the Court's Scheduling Order, Defendant Pharmacia Corporation, formerly known as Monsanto Company ("Monsanto") (sometimes referred to herein as "Defendant") files its initial Designation ofExpert Witnesses and Supplementation ofResponses to Requests for Disclosure and Interrogatories as applicable attached hereto as Exhibit 1. Respectfully submitted, ELLIS, CARSTARPHEN, DOUGHERTY & GOLDENTHAL P.C. By:________/ VU / Edward M. Carstarphen State Bar No. 03906700 G. Joe Ellis State Bar No. 06575050 Douglas B. Dougherty State Bar No. 06031560 Lawrence E. Goldenthal State Bar No. 08089508 720 N. Post Oak., Ste. 330 Houston, Texas 77024 (713) 647-6800 (Telephone) (713)647-6884 (Facsimile) ATTORNEYS FOR DEFENDANT PHARMACIA CORPORATION, FORMERLY KNOWN AS MONSANTO COMPANY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy ofthe above and foregoing was served upon Plaintiffs counsel ofrecord by certified mail, return receipt requested on all other known counsel by regular mail as follows on this JAZ day of August, 2001: Elizabeth Schick Lou Thompson Stephanie Finch Baron & Budd The Centrum, Suite 1100 3102 Oak Lawn Avenue Dallas, Texas 75219 K:\Solutia\Organ\Pleadings\DEW.wpd 2 CAUSE NO. 00CV1053 JOHN T. ORGAN VS. GAF CORPORATION, ET AL. IN THE DISTRICT COURT OF GALVESTON COUNTY, TEXAS 1 22nd JUDICIAL DISTRICT DEFENDANT PHARMACIA CORPORATION'S, FORMERLY KNOWN AS MONSANTO COMPANY, CERTIFICATE OF WRITTEN DISCOVERY I hereby certify that on the ^ day of August, 2001, a true and correct copy of the following document was sent to counsel for Plaintiff, Elizabeth Schick, Lou Thompson and Stephanie Finch, Baron & Budd, P.C., The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219, by U.S. Certified Mail, return receipt requested, and to all other known counsel of record by regular U.S. Mail 1. Defendant Pharmacia Corporation's, Formerly Known as Monsanto Company Initial Designation ofExpert Witnesses and Supplementation ofResponses to Requests for Disclosure and Interrogatories. Respectfully submitted, ELLIS, CARSTARPHEN, DOUGHERTY & GOLDENTHAL, P.C. . By: Edward M. Carstarphen State Bar No. 03906700 G. Joe Ellis State Bar No. 06575050 Douglas B. Dougherty State Bar No. 06031560 Lawrence E. Goldenthal State Bar No. 08089508 720 N. Post Oak Rd., Suite 330 Houston, Texas 77024 (713) 647-6800 (713) 647-6884 (fax) ATTORNEYS FOR DEFENDANT PHARMACIA CORPORATION, FORMERLY KNOWN AS MONSANTO COMPANY EXHIBIT 1 I. Defendant Pharmacia Corporation's, formerly known as Monsanto Company, Initial Designation of Expert Witnesses Monsanto hereby designates the following persons who may be called as expert witnesses and (1) who have been retained by Defendant and/or other Defendants in this cause, or (2) who may provide testimony in the nature ofexpert or opinion type testimony despite the fact that they are not "retained experts." This designation is served based upon the pleadings and discovery responses served by Plaintiff to date. Defendant reserves the right to supplement this designation as discovery progresses and as Plaintiff continues to supplement discovery and appear for independent medical examinations, ifany. Defendant reserves the right to amend and supplement this Designation. This designation shall also serve as Monsanto's supplementation of applicable responses to requests for disclosure and interrogatories. 1. Dr. John Craighead Department of Pathology University of Vermont College of Medicine Burlington, Vermont 05405 (802) 425-3480 Dr. Craighead is a medical doctor and pathologist and may testify concerning the state of medical knowledge, at relevant points in time, regarding the effects of exposure to asbestos. 2. Mr. John A. Pendergrass 6700 Milkhouse Court Mobile, Alabama 36695 Mr. Pendergrass is an industrial hygienist and may testify concerning industry practice and standards, state of the art of industrial hygiene, and state of knowledge concerning exposure to asbestos and effects thereofat relevant times, and may testify concerning the reasonableness ofreliance upon established acceptable and safe levels ofexposure to asbestos. K:\Solutia\Organ\Pleadings\DEW.wpd 3 3. J. LeRoy Balzer, Ph.D. 408 Horse Trail Ct. Alamo, California 94556 Dr. Balzer is an industrial hygienist and may testify concerning industry practice and standards, state of the art of industrial hygiene, and state of knowledge concerning exposure to asbestos and effects thereofat relevant times, and may testify concerning the reasonableness ofreliance upon established acceptable and safe levels ofexposure to asbestos. 4. B. K. Kwon, M.S.P.H. 601 Montrose Rd., Suite 509 Rockville, MD 20852 Mr. Kwon is an industrial hygienist and may testify concerning industry practice and standards, state of the art of industrial hygiene, and state of knowledge concerning exposure to asbestos and effects thereofat relevant times, and may testify concerning the reasonableness ofreliance upon established acceptable and safe levels ofexposure to asbestos. 5. Mr. Lawrence R. Birkner, CIH, CSP 2026 El Monte Drive Thousand Oaks, CA 91362 (805)494-8173 Mr. Birkner is an industrial hygienist and may testify concerning industry practice and standards, state of the art of industrial hygiene, and state of knowledge concerning exposure to asbestos and effects thereofat relevant times, and may testify concerning the reasonableness ofreliance upon established acceptable and safe levels ofexposure to asbestos. 6. James T. Knorpp, PE, CSP 2149 Misty's Run Keller, TX (817) 379-0840 Mr. Knorpp is a safety professional and professional engineer and may testify concerning his education, training and experience, as well as his factual observations and mental impressions and opinions and the basis for them, in the following areas: the creation, role and significance of OSHA, and relevant rules and regulations, concerning asbestos products in the work place; the process of establishing, historical development, and K:\Solutia\Organ\Pleadings\DEW.wpd 4 significance ofmaximum allowable concentrations, permissible exposure limits, threshold limit values, regulatory standards, and similar concepts, in general and specifically with regard to asbestos at relevant times and the reasonableness ofreliance upon established acceptable and safe levels of exposure to asbestos; employer's responsibility for employee/worker work site conditions and safety, including the employer's role in connection with OSHA. Mr. Knorpp may also testify regarding matters in response to testimony of Plaintiffs' experts. 7. Dr. Mark R. Wick, M.D., FCAP University of Virginia Health System Department of Pathology Box 214 O.M.S. Building, Room 2882 Charlottesville, VA 22908 (804) 924-9038 Dr. Wick is a medical doctor and pathologist and may testify concerning his education, training and experience, as well as his factual observations and mental impressions and opinions and the basis therefor, in the following areas: historical developments regarding asbestos utilization; medical aspects of asbestos-related diseases; state of the art in medicine and state ofmedical knowledge, at relevant points in time, concerning asbestos and asbestos exposure and the effects thereof; relevant medical and scientific literature; the diagnostic criteria used to diagnose asbestos-related diseases; the relative risk, as well as reasonably perceived risk during relevant periods oftime, from various levels ofpotential exposure to asbestos, as well as particular type ofasbestos fiber involved; existence ofa dose-response relationship and the concept of threshold levels for asbestos-related diseases; and the rate ofoccurrence or incidence ofcertain diseases in given populations. Dr. Wick may also review Plaintiffs ' medical records and may also review, examine and/or analyze pathology material, including tissue samples and/orblocks and/or slides, and may opine as to the appropriate diagnosis ofPlaintiffs' alleged diseases as well as their etiology. Dr. Wick may also testify regarding matters in response to testimony ofPlaintiffs' experts. 8. Dr. William L. Dyson, Ph.D, CEH Workplace Hygiene, L.L.C. 1022 Jefferson Road P.O. Box 49176 Greensboro, NC 27410-1642 Dr. Dyson is an industrial hygienist and safety professional and may testify concerning his education, training and experience, as well as his factual observations and mental impressions and opinions and the basis for them, in the following areas: properties, use of K:\Solutia\Organ\Pleadings\DEW.wpd 5 and historical developments concerning asbestos and asbestos-containing products; industry practice and standards in general and specifically concerning industrial hygiene and asbestos; state of knowledge concerning exposure to asbestos and effects thereof at relevant times; the process ofestablishing, historical development and significance of maximum allowable concentrations, permissible exposure limits, threshold limit values, regulatory standards, and similar concepts, in general and specifically with regard to asbestos at relevant times and the reasonableness ofreliance upon established acceptable and safe levels ofexposure to asbestos products during relevant periods oftime; how potential exposure levels from various activities compared to then existing threshold limit values at relevant times; employer's responsibility for employee/worker work site conditions and safety; and the reasonableness ofpetrochemical premises owner's conduct during relevant periods oftime. Dr. Dyson may offer opinions relating to the levels of asbestos exposure necessary to attribute the development of mesothelioma to any particular occupational exposure. Dr. Dyson may also testify regarding matters in response to testimony ofPlaintiffs' experts. The basis for Dr. Dyson's mental impressions and opinions are his education, training, and experience, his review ofpertinent literature, and his review of additional information pertinent to Plaintiffs' and/or this case. 9. Dr. Patrick N. Conoley, M.D. Kelsey Seybold Clinic 6624 Fannin, Suite 1800 Houston, TX 77030 Dr. Conoley is an M.D. and a "B" reader, who may testify concerning his review ofofthe radiographs and CT scans ofPlaintiffs in this case and the significance ofvarious x-ray findings on the radiographs of Plaintiffs. 10. Dr. Peter J. Barrett, M.D. 10 Martin's Lane Hingham, MA 24043 (617) 749-5876 Dr. Barrett is an M.D., is board certified in diagnostic radiology and nuclear medicine and has been a "B" reader from NIOSH since 1984. Dr. Barrett may testify concerning the significance ofasbestos related abnormalities and neoplastic disease based upon his review ofthe radiographs ofPlaintiffs as to the presence or absence ofradiographic abnormalities related to asbestos and the significance of same. 11. Dr. Gail D. Stockman 703 East Marshall Avenue, Suite 4002 Longview, Texas 75601 (903) 753-0787 K:\Solutia\Organ\Pleadings\DEW.wpd 6 Dr. Stockman may testify regarding the pulmonary and respiratory diseases and illnesses alleged by Plaintiffs. More specifically, Dr. Stockman may testify regarding specific medical complaints and history ofPlaintiffs' and whether those alleged diseases or illnesses could be or were caused by any alleged exposure to materials from the premises of Defendants. Dr. Stockman may address issues regarding alleged medical risks to Plaintiffs in the future due to Plaintiffs' alleged exposure to materials from the premises of Defendants and the effects ofthe alleged illnesses and diseases on Plaintiffs in the past and in the future. Dr. Stockman may testify as to all matters pertaining to examination of Plaintiffs and/or review ofPlaintiffs' medical records, x-rays, and reports and supplemental reports ofPlaintiffs' experts; any communications with Plaintiffs or Plaintiffs' family members; the diagnostic criteria used to diagnose asbestos-related diseases; her opinions as to whether Plaintiffs suffer from asbestos-related disease and the basis ofsuch opinions; the Plaintiffs' current medical condition and her prognosis thereof, the anatomy and function of the respiratory and circulatory systems; the natures of asbestos; the symptomatology, disease process and diagnosis ofasbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity, the nature and extent ofmedical and scientific knowledge regarding any association ofpulmonary disease with asbestos exposure; the effect ofexposure to substances other than asbestos on the development and manifestation ofobstructive and restrictive conditions and diseases ofthe respiratory system; methods ofdiagnosis ofvarious diseases, especially the means ofestablishing the differential diagnosis ofalleged asbestos-related diseases with other non-asbestos-related diseases; incidence oflung cancer among individuals with asbestosis as compared to nonasbestotic asbestos workers and to the general public. She may also testify as to smoking and its relation to cancer of the lung and cancers ofother body parts with reference to epidemiology studies and physiologic effect; the difference between impairment and disability; the effect of asbestosis on disability and life expectancy; and the lack of relationship between the presence ofpleural plaques and a later development ofany form ofcancer. Dr. Stockman may offer testimony in response to any reports or testimony offered by Plaintiffs' experts. 12. Kim Bloom, M.D. 6550 Fannin, Suite 2403 Houston, Texas 77030 (713) 790-6250 Dr. Bloom is a specialist in pulmonary and respiratory diseases and a certified B-reader. He may testify regarding specific medical complaints and history ofPlaintiffs and whether those complaints could be or were caused by any alleged exposure to materials from the premises of Defendants. Dr. Bloom may also testify regarding alleged medical risks to Plaintiffs in the future due to Plaintiffs' alleged exposure to materials from the premises of Defendants and the effects ofthe alleged illnesses and diseases on Plaintiffs in the past and K:\Solutia\Organ\Pleadings\DEW.wpd 7 in the future. Dr. Bloom may testify as to all matters pertaining to examination ofPlaintiffs and/or review ofPlaintiffs' medical records, x-rays, and reports and supplemental reports ofPlaintiffs' experts; any communications with Plaintiffs or Plaintiffs' family members; the diagnostic criteria used to diagnose asbestos-related diseases; his opinions as to whether Plaintiffs suffer from asbestos-related disease and the basis ofsuch opinions; the Plaintiffs' current medical condition and his prognosis thereof, the anatomy and function ofthe respiratory and circulatory systems; the natures ofasbestos; the symptomatology, disease process and diagnosi s o fasbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent ofmedical and scientific knowledge regarding any association ofpulmonary disease with asbestos exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases ofthe respiratory system; methods of diagnosis ofvarious diseases, especiallythe means ofestablishing the differential diagnosis ofalleged asbestos-related diseases with other non-asbestos-related diseases; incidence oflung cancer among individuals with asbestosis as compared to non-asbestotic asbestos workers and to the general public. He may also testify as to smoking and its relation to cancer ofthe lung and cancers ofother body parts with reference to epidemiology studies and physiologic effect; the difference between impairment and disability; the effect of asbestosis on disability and life expectancy; and the lack ofrelationship between the presence ofpleural plaques and a later development ofany form ofcancer. Dr. Bloom may offer testimony in response to any reports or testimony offered by Plaintiffs' experts. 13. Robert M. Ross, M.D. 6550 Fannin Street, Suite 2403 Houston, Texas 77030 (713) 383-6100 (phone) (713) 383-6103 (fax) Dr. Ross is a specialist in pulmonary and respiratory diseases and a certified B-reader. He may testify regarding specific medical complaints and history ofPlaintiffs and whether those complaints could be or were caused by any alleged exposure to materials from the premises of Defendants. Dr. Ross may also testify regarding alleged medical risks to Plaintiffs in the future due to Plaintiffs' alleged exposure to materials from the premises of Defendants and the effects ofthe alleged illnesses and diseases on Plaintiffs in the past and in the future. Dr. Ross may testify as to all matters pertaining to examination ofPlaintiffs and/or review ofPlaintiffs' medical records, x-rays, and reports and supplemental reports ofPlaintiffs' experts; any communications with Plaintiffs or Plaintiffs' family members; the diagnostic criteria used to diagnose asbestos-related diseases; his opinions as to whether Plaintiffs suffer from asbestos-related disease and the basis ofsuch opinions; the Plaintiffs' current medical condition and his prognosis thereof, the anatomy and function ofthe respiratory and circulatory systems; the natures ofasbestos; the symptomatology, disease K:\Solutia\Organ\Pleadings\DEW.wpd 8 process and diagnosis ofasbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent ofmedical and scientific knowledge regarding any association of pulmonary disease with asbestos exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases ofthe respiratory system; methods of diagnosis ofvarious diseases, especially the means ofestablishing the differential diagnosis ofalleged asbestos-related diseases with other non-asbestos-related diseases; incidence oflung cancer among individuals with asbestosis as compared to non-asbestotic asbestos workers and to the general public. He may also testify as to smoking and its relation to cancer ofthe lung and cancers ofother bodyparts with reference to epidemiology studies and physiologic effect; the difference between impairment and disability; the effect of asbestosis on disability and life expectancy; and the lack of relationship between the presence ofpleural plaques and a later development ofany form ofcancer. Dr. Ross may offer testimony in response to any reports or testimony offered by Plaintiffs' experts 14. Venessa Ann Holland, M.D., MPH, P.A. Environmental Pulmonary Consultants 7515 S. Main Street, Suite 670 Houston, Texas 77030 (713) 799-2224 (Telephone) (713) 799-2225 (Facsimile) Dr. Holland may testify regarding the pulmonary and respiratory diseases and illnesses alleged byPlaintiffs. More specifically. Dr. Holland maytestifyregarding specific medical complaints and history ofPlaintiffs' and whether those alleged diseases or illnesses could be or were caused by any alleged exposure to materials from the premises of Defendants. Dr. Holland may address issues regarding alleged medical risks to Plaintiffs in the future due to Plaintiffs' alleged exposure to materials from the premises ofDefendants and the effects ofthe alleged illnesses and diseases on Plaintiffs in the past and in the future. Dr. Holland may testify as to all matters pertaining to examination ofPlaintiffs and/or review ofPlaintiffs' medical records, x-rays, and reports and supplemental reports ofPlaintiffs' experts; any communications with Plaintiffs or Plaintiffs' family members; the diagnostic criteria used to diagnose asbestos-related diseases; her opinions as to whether Plaintiffs suffer from asbestos-related disease and the basis ofsuch opinions; the Plaintiffs' current medical condition and her prognosis thereof, the anatomy and function ofthe respiratory and circulatory systems; the natures ofasbestos; the symptomatology, disease process and diagnosis ofasbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent ofmedical and scientific knowledge regarding any association of pulmonary disease with asbestos exposure; the effect of exposure to substances other than asbestos on the development and manifestation ofobstructive and restrictive conditions and diseases ofthe respiratory system; methods ofdiagnosis of K:\Solutia\Organ\Pleadings\DEW.wpd 9 various diseases, especially the means ofestablishing the differential diagnosis ofalleged asbestos-related diseases with other non-asbestos-related diseases; incidence of lung cancer among individuals with asbestosis as compared to non-asbestotic asbestos workers and to the general public. She may also testify as to smoking and its relation to cancer of the lung and cancers of other body parts with reference to epidemiology studies and physiologic effect; the difference between impairment and disability; the effect ofasbestosis on disability and life expectancy; and the lack ofrelationship between the presence of pleural plaques and a later development ofany form ofcancer. Dr. Holland may offer testimony in response to any reports or testimony offered by Plaintiffs' experts. 15. Scott G. Donaldson, M.D., F.C.C.P Pulmonary/Critical Care 375 Municipal Drive, Suite 218 Richardson, Texas 75080 (972) 680-0666 (972) 680-2499 (fax) Dr. Donaldson is a specialist in pulmonary and respiratory diseases. He may testify regarding specific medical complaints and history ofPlaintiffs and whether those complaints could be or were caused by any alleged exposure to materials from the premises of Defendants. Dr. Donaldson may also testify regarding alleged medical risks to Plaintiffs in the future due to Plaintiffs' alleged exposure to materials from the premises of Defendants and the effects ofthe alleged illnesses and diseases on Plaintiffs in the past and in the future. Dr. Donaldson may testify as to all matters pertaining to examination of Plaintiffs and/or review ofPlaintiffs' medical records, x-rays, and reports and supplemental reports ofPlaintiffs' experts; any communications with Plaintiffs or Plaintiffs' family members; the diagnostic criteria used to diagnose asbestos-related diseases; his opinions as to whether Plaintiffs suffer from asbestos-related disease and the basis ofsuch opinions; the Plaintiffs' current medical condition and his prognosis thereof, the anatomy and function ofthe respiratory and circulatory systems; the natures ofasbestos; the symptomatology, disease process and diagnosis ofasbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent ofmedical and scientific knowledge regarding any association ofpulmonary disease with asbestos exposure; the effect ofexposure to substances other than asbestos on the development and manifestation ofobstructive and restrictive conditions and diseases ofthe respiratory system; methods ofdiagnosis of various diseases, especially the means of establishing the differential diagnosis ofalleged asbestos-related diseases with other non-asbestos-related diseases; incidence oflung cancer among individuals with asbestosis as compared to non-asbestotic asbestos workers and to the general public. He may also testify as to smoking and its relation to cancer of the lung and cancers of other body parts with reference to epidemiology studies and physiologic effect; the difference between impairment and K:\Solutia\Organ\Pleadings\DEW.wpd 10 disability; the effect of asbestosis on disability and life expectancy; and the lack of relationship between the presence ofpleural plaques and a later development ofany form ofcancer. Dr. Donaldson may offer testimony in response to any reports or testimony offered by Plaintiffs' experts. 16. Kathryn A. Hale, M.D. 6550 Fannin Street Smith Tower, Suite 1236 Houston, Texas 77030 (713) 790-2076 (Telephone) (713) 790-3648 (Facsimile) Dr. Hale may testify regarding the pulmonary and respiratory diseases and illnesses alleged by Plaintiffs. More specifically, Dr. Hale may testify regarding specific medical complaints and history ofPlaintiffs' and whether those alleged diseases or illnesses could be or were caused by any alleged exposure to materials from the premises of Defendants. Dr. Hale may address issues regarding alleged medical risks to Plaintiffs in the future due to Plaintiffs' alleged exposure to materials from the premises ofDefendants and the effects ofthe alleged illnesses and diseases on Plaintiffs in the past and in the future. Dr. Hale may testify as to all matters pertaining to examination ofPlaintiffs and/or review ofPlaintiffs' medical records, x-rays, and reports and supplemental reports ofPlaintiffs' experts; any communications with Plaintiffs or Plaintiffs' family members; the diagnostic criteria used to diagnose asbestos-related diseases; her opinions as to whether Plaintiffs suffer from asbestos-related disease and the basis ofsuch opinions; the Plaintiffs' current medical condition and her prognosis thereof, the anatomy and function ofthe respiratory and circulatory systems; the natures ofasbestos; the symptomatology, disease process and diagnosis ofasbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity; the nature and extent ofmedical and scientific knowledge regarding any association of pulmonary disease with asbestos exposure; the effect of exposure to substances other than asbestos on the development and manifestation ofobstructive and restrictive conditions and diseases ofthe respiratory system; methods ofdiagnosis of various diseases, especially the means ofestablishing the differential diagnosis ofalleged asbestos-related diseases with other non-asbestos-related diseases; incidence oflung cancer among individuals with asbestosis as compared to non-asbestotic asbestos workers and to the general public. She may also testify as to smoking and its relation to cancer of the lung and cancers of other body parts with reference to epidemiology studies and physiologic effect; the difference between impairment and disability; the effect ofasbestosis on disability and life expectancy; and the lack ofrelationship between the presence of pleural plaques and a later development of any form of cancer. Dr. Hale may offer testimony in response to any reports or testimony offered by Plaintiffs' experts. K:\Solutia\Organ\Pleadings\DEW.wpd 11 17. John R. Holcomb, M.D. 4410 Memorial Drive, Suite 440 San Antonio, Texas 78229 (210) 692-9400 Dr. Holcomb is a specialist in pulmonary and respiratory diseases. He may testify regarding specific medical complaints and history ofPlaintiffs and whether those complaints could be or were caused by any alleged exposure to materials from the premises of Defendants. Dr. Holcomb may also testify regarding alleged medical risks to Plaintiffs in the future due to Plaintiffs' alleged exposure to materials from the premises ofDefendants and the effects ofthe alleged illnesses and diseases on Plaintiffs in the past and in the future. Dr. Holcomb may testify as to all matters pertaining to examination ofPlaintiffs and/or review ofPlaintiffs' medical records, x-rays, and reports and supplemental reports of Plaintiffs' experts; any communications with Plaintiffs or Plaintiffs' family members; the diagnostic criteria used to diagnose asbestos-related diseases; his opinions as to whether Plaintiffs suffer from asbestos-related disease and the basis ofsuch opinions; the Plaintiffs' current medical condition and his prognosis thereof, the anatomy and function ofthe respiratoiy and circulatory systems; the natures ofasbestos; the symptomatology, disease process and diagnosis ofasbestosis and cancer associated with the respiratory system, peritoneum and peritoneal cavity, the nature and extent ofmedical and scientific knowledge regarding any association ofpulmonary disease with asbestos exposure; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases ofthe respiratory system; methods of diagnosis ofvarious diseases, especially the means ofestablishing the differential diagnosis ofalleged asbestos-related diseases with other non-asbestos-related diseases; incidence oflung cancer among individuals with asbestosis as compared to non-asbestotic asbestos workers and to the general public. He may also testify as to smoking and its relation to cancer ofthe lung and cancers ofother body parts with reference to epidemiology studies and physiologic effect; the difference between impairment and disability; the effect of asbestosis on disability and life expectancy; and the lack of relationship between the presence ofpleural plaques and a later development ofany form ofcancer. Dr. Holcomb may offer testimony in response to any reports or testimony offered by Plaintiffs' experts. 18. 1. A. Feingold, M.D. Chief, Division of Pulmonary Medicine South Miami Hospital 6200 Southwest 73rd Street Miami, FL33143 305-661-4611, Ext. 5229 K:\Solutia\Organ\PleadingsVDEW.wpd 12 Dr. Feingold is a specialist in pulmonary medicine and aNIOSH certified "B-reader". Dr. Feingold may testify as to his examination ofa plaintiffand/or decedent and/or review of their medical records and x-rays and may offer opinions regarding whether or not the plaintiff/decedent has an asbestos-related disease. Dr. Feingold may also testify concerning the diagnostic criteria used to diagnose asbestos-related diseases and prognosis regarding any medical conditions. Dr. Feingold may also testify about general medical issues and the effects that asbestos and other substances have on human health generally and with respect to plaintiff/decedent specifically. Dr. Feingold will also testify as to the idiopathic nature of mesothelioma in some individuals. He will also testify that certain other cancers are not in reasonable medical probability related to asbestos exposure based upon the scientific evidence. These will include laryngeal and colon rectal cancers, among others. Dr. Feingold may also testify concerning the nature and extent ofmedical and scientific knowledge as it has existed from time to time regarding the association ofpulmonary disease with asbestos exposure based upon the medical and scientific literature, and based on that literature, he will testify as to the population and workers perceived to be at risk ofasbestos disease as literature has developed over time. He will also testify concerning the methods ofdiagnosis, the incidence oflung cancer among individuals with asbestosis as compared to non-asbestotic workers and to the general public. He will also testify to smoking and its relation to cancer ofthe lung and cancer ofother parts ofthe body. He will further testify concerning the lack ofrelationship between the presence ofpleural plaques and later development ofany form ofcancer and the necessity for an underlying diagnosis for pulmonary asbestosis in order to attribute lung cancer to asbestos exposure. Dr. Feingold may offer testimony in response to any reports or testimony offered by Plaintiffs' experts. Dr. Feingold's C.V. has previously been provided to Plaintiffs' counsel. Ifanother copy is desired. Defendant will, on request, provide one. Defendant also designates the following witnesses to testify through their deposition and/or trial testimony from other cases: 1. Dr. Emmett Kelly testified by deposition, and at trial, in the case ofRita Mae Schmidt, et al. v. A.C. &S.,et al.;No. D-145,280; In the District Court ofJefferson County, Texas; 136th Judicial District. Dr. Kelly's testimony, both at trial, and on deposition, is designated here only to the extent that he gave expert or opinion type testimony in that deposition. 2. Mr. Jack T. Garrett in the case of Rita Mae Schmidt, et al. v. A.C. & S., et al.; No. D145,280; In the District Court ofJefferson County, Texas; 136th Judicial District. Mr. K:\Solutia\Organ\PleadingsVDEW.wpd 13 Garrett's deposition testimony is designated here only to the extent that he gave expert or opinion type testimony in that deposition. 3. Joe Shrode in the case of Claude J. Tomplait v. Combustion Engineering, et al.; U.S. District Court for the Eastern District ofTexas, Beaumont Division; and/or in Samuel R. Porter v. Fibreboard Corporation, et al., also in the U.S. District Court for the Eastern District ofTexas, Beaumont Division, and/or Mr. Shrode's deposition testimony in the Clarence Borel trial, also in the U.S. District Court for the Eastern District of Texas. 4. Dr. Corwin Hinshaw, expert regarding state ofthe medical art, in the cases ofJimmie L. Vaughan v. Johns-Manville, CA-3-01-0070-F, USDA, N.D. Tex; Antonio Mendoza, et al v. Fibreboard Corporation, et al., CA.-2-80-006, USDC, N.D. Tex; In Re: Related Asbestos Cases, C-83-6251-RFP, USDC, N.D. Calif. Defendant also designates any and all expert witnesses designated herein by Plaintiffs. Defendant also designates any and all expert witnesses designated herein by other Defendants. Defendant would also refer to and incorporate herein by reference each ofthe reports submitted, or to be submitted by Defendant's experts, copies ofwhich have been or will be provided to Plaintiffs' counsel by Defendant or other Defendants herein. K:\Solutia\Organ\Pleadings\DEW.wpd 14