Document NNagGyYkmYYJNnyDa71npYg6y

PLAINTIFF'S EX11UU1 NO. 2000-2113 PABLO AGUILERA, ET AL. VS. GAF CORPORATION, ET AL. IN THE COUNTY COURT AT LAW NO. 3 EL PASO COUNTY, TEXAS DEFENDANT TEXACO INC.'S EXHIBIT LIST TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW Defendant TEXACO INC. and hereby submits its trial exhibit list. Respectfully submitted, TSB No. 1^838000 1200 Smith Street, Suite 400 Houston, Texas 77002 (713) 654-1111 (713) 655-9212 (Fax) Attorneys for Defendant TEXACO INC. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrumenUiusJbeenTQrwarded to counsel for Plaintiff by certified mad^return receipt requested, and to alPbfiier counsel of record by regular mail, on this to day of _ ^ iqOa ~ 20f DEFENDANTS' TRIAL EXHIBITS IN ASBESTOS CASES 1. Aug. 1938 2. Nov. 1945 3. Jan.-Nov. 1946 4. 1947 5. 1948 6. June25, 1952 7. 1955 8. Dec. 1, 1957 9. June 1958 10. 1959 11. Feb. 15, 1960 12. Apr. 1960 13. Jan. 14, 1961 BSR\409530 Public Health Bulletin No. 241: A Study of Asbestosis in the Asbestos Textile Industry, by Dreessen, Dallavalle, Edwards, Miller, & Sayers "Maximum Allowable Concentrations of Industrial Atmosphere Contaminants", by Warner Cook A "Health Survey of Pipe Covering Operations in Constructing Naval Vessels", in Journal of Industrial Hygiene & Toxicology, Vol. 28, by Walter Fleischer, Frederick Viles, Jr., Robert Gade, & Philip Drinker "Clean Air: Removal of Dusts" issued by the US Dept, of Labor "Industrial Hygiene & Toxicology", Vol. I, by Frank A. Patty West Virginia State Health Department's Report on Industrial Hygiene Survey, Chesapeake & Ohio Railroad Shops, by Paul D. Halley, John Peathas, Harvey J. Roberts, & James Monnison "Mortality from Lung Cancers in Asbestos Workers" by Richard Doll Occupational Health Regulations; Maximum Permissible Concentrations of Atmospheric Contaminants in Places of Employment from the Texas State Dept, of Health "An Epidemiological Study of Lung Cancer in Asbestos Mines" by Braun and Truan "Asbestos, a Materials Survey", by Oliver Bowles from the US Dept, of the Interior Letter from Kenneth M. Lynch to F.W. Wilson on no knowledge of data on pleural mesothelioma being associated with asbestos dust exposure "Diffuse Pleural Mesotheliomas & Asbestos Exposure in the North Western Cape Province", by J.C. Wagner "Diffuse Pleural Mesotheliomas in South Africa", by J.C. Wagner -1 - 14. May 19, 1961 15. ~ 1962 16. 1964 17. 1965 18. Sept. 1965 19. 1966 20. Sept. /Oct. 1966 21. Nov./Dec. 1967 22. Jan. 1968 23. Jan. 1968 24. Apr. 22, 1968 25. May/June 1968 26. July 1968 27. May 20, 1969 "Ad Hoc Meeting to Discuss the Status of Knowledge Concerning the Effects of Exposure to Asbestos Dust on Health", by U.S. Public Health Service Documentation of Threshold Limit Values, by American Conference of Governmental Industrial Hygienists "Occupational Diseases-a Guide to Their Recognition" by W.M. Gafafer Annals of New York Academy of Sciences "Cancer Experiences of Several Occupational Groups Followed Prospectively," by John E. Dunn & John M Weir Documentation of Threshold Limit Values, Revised edition, by American Conference of Governmental Industrial Hygienists "Measurement of Dust Exposures in the Asbestos Textile Industry", by Jeremiah R. Lynch & Howard E. Ayer "Testing Compliance with Threshold Limit Values for Respirable Dusts", by S.A. Roach, E.J. Baier, H.E. Ayer, & R.L. Harris "Measurement of Asbestos Exposure", by Jeremiah Lynch & Howard Ayer from the Journal of Occupational Medicine "Industrial Hygiene for Insulation Workers", by LeRoy Balzer from the Journal of Occupational Medicine "Evaluation & Control of Asbestos Exposure in the Insulating Trade", by W. Clark Cooper & LeRoy Balzer "Work Environment of Insulating Workers", by W. Clark Cooper & LeRoy Balzer "A Prospective Study of Mortality of Several Occupational Groups: Special Emphasis on Lung Cancer," by Dr. John E. Dunn, Jr. & Dr. John M. Wier (from Arch. Environ. Health-Vol. 17) Federal Register: Safety & Health Standards, Part II, from the Department of Labor BSRA409530 -2 28. October, 1969 29. ^ 1969-1970 30. 1969-1972 31. 1969-1972 32. 1969-1976 33. Aug. 19, 1970 34. Sept./Oct. 1970 35. Dec. 1970 36. 1970-1971 37. 1971 38. 1971 BSR\409530 "Asbestos and Health in 1969" by George W. Wright from the American Review of Respiratory Disease Tables XIII & XIV: Asbestos Concentration by Operation for Insulation Workers from 'Appendix X' of NIOSH Criteria Doc. Several Insulation Hygiene Progress Reports from Insulation Industry Hygiene Research Program: - Spring 1969 Spring 1971 Summer 1971 Fall 1971 - Summer 1972 Various documents copied from the pipefitters & building & construction trades weekly newsletter & other documents (obtained from U.S. Dept, of Labor). See attached index. Compilation of inhalation hygiene progress reports, from the Insulation Industries Hygiene Research Program Deposition of Joseph Ralph Shrode given in Porter v. Fibreboard, C.A. No. 6329, U.S.D.C. E.D. Texas, and trial testimony given in Borel v. Fibreboard, C.A. No. 6449, U.S.D.C. E.D. Tex. Interrelationships of Selected Asbestos Exposure Indices, by Jeremiah Lynch, Howard Ayer & Douglas Johnson A Labor Management Occupational Health Service in a Construction Industry, by Irving R. Tabershaw, Clark Cooper, & LeRoy Blazer NICA Outlook (National Insulation Contractors Association) booklets: * February, 1970 March, 1970 January, 1971 March, 1971 June, 1971 Asbestos: The Need for & Feasibility of Air Pollution Controls, from the National Academy of Sciences "Fundamentals of Industrial Hygiene" by National Safety Council -3- 39. 1971 40. ** Dec. 2, 1971 41. Dec. 7, 1971 42. 1971-1973 43. 1972 44. 1972 45. May 1972 46. May 14, 1972 47. Sept. 1972 48. Apr. 1973 49. Dec. 1976 50. 1979 Documentation of the Threshold Limit Values for Substances in Workroom Air, 3rd edition, by American Conference of Governmental Industrial Hygienists "Effects of Low Concentrations of Asbestos", by Murphy, et al (including Edward Gaensler) "OSHA Program Directive #6: Asbestos Dust, Emergency Standard Implementation"; and Rules and Regulations from the Federal Register and the ETS Various articles from the UA Journal, "Our Troubled Environment" section: Nov. 1971 July 1972 Apr. 1973 "Criteria for a Recommended Standard . . . Occupational Exposure to Asbestos", from the U.S. Department of Health, Education & Welfare Documents from the Exhibit List for the 1972 OSHA Asbestos Hearing. National Geographic Magazine "Dust Exposure in Asbestos Processing", from Transactions of the 34th Annual meeting of the ACGIH, by Robert B. Weidner & Howard E. Ayer "Carcinogenicity of Amosite Asbestos", by Selikoff, Hammond & Churg "Health Hazard Evaluation/Toxicity Determination", by Raymond L. Hervin, et al (with National Institute for Occupational Safety & Health) Revised Recommended Asbestos Standard, from National Institute for Occupational Safety & Health Health Hazards of Asbestos Exposure, Annals of the New York Academy of Sciences, 1979 BSR\409530 -4- 51. 1979 52. 1979 53. 1981 54. Feb. 1982 55. Oct. 8, 1982 56. Dec. 1982 57. 1983 58. June 10, 1983 59. 1985 60. 1985 61. Jan. 1985 62. 1986 63. Mar. 1986 "Asbestos Exposure: Factors Associated with Excess Cancer and Respiratory Disease Mortality" "Historical Background to the Asbestos Problem" by Selikoff & Lee "Quantitative Estimates of Avoidable Risks of Cancer in the US Today" from The Causes of Cancer by Oxford Medical Publications ed. by Richard Doll and Richard Peto "Mortality Study of Petroleum Refinery Workers: Update of Follow-up", prepared by Samuel D. Kaplan for the American Petroleum Institute "The Pathology of Asbestos Associated Diseases of the Lungs & Pleural Cavities: Diagnostic Criteria & Proposed Grading Scheme" (a special issue from the Archives of Pathology & Laboratory Medicine), by John E. Craighead, et al Analysis of fiber release from certain asbestos products--draft final report, prepared by G.C.A. Corp. for U.S. Environmental Protection Agency (contains data on fiber release & concentrations) Chapter 8 on Mesothelioma from Cancer Epidemiology by Edith Deborah Greenwald, M.P.H. and Edward S. Greenwald M.D. "Non-asbestos Related Malignant Mesothelioma", by Theiderson, Greenberg & Buffler "Asbestos Exposure-Quantitative Assessment of Risk", by Janet Hughes & Hans Weill "Asbestos", a chapter from Mineral Facts & Problems, by the Bureau of Mines "Alternatives to Asbestos in Asbestos Products", by A.A. Hodgson "Asbestos as a Public Health Risk: Disease and Policy" from Annual Reviews : Public Health by Hans Weill and Janet M. Hughes "Evaluation of Impairment/Disability Secondary to Respiratory Disorders", from the American Thoracic Society, by Attlilo D. Renzetti, Jr., M.D., et al BSRA409530 -5- 64. Apr. 1986 65. Apr. 1986 66. 1987 67. 1987 68. 1988 69. 1989 70. 1989 71. 1989 72. 1989 73. 1989 74. Apr. 5, 1989 75. May 19, 1989 76. 1990 BSR\409530 Malignant Mesothelioma," by Andrew Churg "The Diagnosis of Non-malignant Diseases Related to Asbestos" report of the Combined Committee of the American College of Chest Physicians & American Thoracic Society "Mortality of Workers Employed in 2 Asbestos Cement Manufacturing Plants", from the British Journal of Industrial Medicine, by Janet Hughes, Hans Weill, & Yehia Hammad "Epidemiology of Malignant Mesothelioma" from Asbestos-Related Malignancy ed. by Karen Antman M.D. and Joseph Aisner, M.D. "Asbestos Health Effects: Resolving the Scientific Uncertainties", from the Post-graduate Medicine Journal, by Janet Hughes & Hans Weill "Critical Review of Cancer Epidemiology in Petroleum Industry Employees, with a Quantitative Meta-analysis by Cancer Site," by Otto Wong & Gerhard Raabe "Job Safety & Health for the Piping Industry" (a manual published by Plumbing Apprentice & Journeyman Training, Inc.) "Progression of Asbestos Effects: A Prospective Longitudinal Study of Chest Radiographs & Lung Function", from the British Journal of Industrial Medicine, by R.N. Jones, J.E. Diem, Janet M. Hughes, Yehia Y. Hammad, H.W. Glindmeyer, & H. Weill "Benign and Malignant Mesothelioma" from Cancer: Principles & Practice of Oncology. Vol. 2 3rd ed. "Development and Use of Asbestos Risk Estimates" by J.M. Hughes and H. Weill; Reprinted from Non-Occupational Exposure to Mineral Fibers Deposition on Written Questions from Russell Allen case of Texas Dept, of Public Health - 1957 Occupational Heath Regulations "Asbestos Lung Disease: Current Controversies Regarding the Control & Prevention of Lung Cancer", by Andrew Churg "The Health Benefits of Smoking Cessation: a Report of the Surgeon General" from the US Dept, of Health and Human Services -6- 77. 1990 78. 1990 79. ~ 1991 80. 1991 81. 1991 82. 1991 83. 1992 84. March, 1992 85. Apr. 1993 86. Mar. 14, 1994 87. Dec. 1995 88. Mar. 15, 1996 "Laryngeal Cancer and Asbestos" by Liddell "U.S. Surgeon General: Health Benefits of Smoking Cessation" "Asbestos in Public & Commercial Buildings: a Literature Review & Synthesis of Current Knowledge", by the Health Effects Institutes "The Discovery of the Association Between Blue Asbestos & Mesotheliomas & the Aftermath", by J.C. Wagner "Asbestosis as a Precursor of Asbestos Related Lung Cancer: Results of Mortality Study", from the British Journal of Industrial Medicine, by Janet Hughes & Hans Weill "Benign and Malignant Mesotheliomas" from Comprehensive Textbook of Oncology 2nd ed Chapter on Mesothelioma from Pathologv of Asbestos-Associated Diseases ed. bv Victor L. Rossli. M.D.. S. Donald Greenbere. M.D., and Phillip C. Pratt, M.D. "The Health Consequences of Smoking" by Polly A. Newcomb, Ph.D, and Paul P. Carbone, M.D. (Hon) U.S. Bureau of Mines annual report on asbestos in 1992 Deposition of Michael W. Cunningham, Local 22, re deaths of certain individuals - taken in Rita Schmidt v. AC&S "The Lack of Causality Between Asbestos and Colorectal Cancer" from JOEM by William Weiss, M.D. Articles on the medical aspects of asbestos cases, particularly on cancer risk and attribution of lung cancer: - "The Diagnosis of Nonmalignant Diseases Related to Asbestos" "Evaluation of Impairment/Disability Secondary to Respiratory Disorders" (American Thoracic Society, March 1986) "Asbestos, Asbestosis, and Lung Cancer", an Editorial, Modern Pathology, Vol. 6, No. 5, September 1993 "Carcinoma of the Lung" from Pathology of AsbestosAssociated Diseases by Roggli, Greenberg and Pratt, 1992 - "Pulmonary Fibrosis as a Determinant of Asbestos-Induced BSRA409530 -7- fc*. 89. undated 90. undated 91. undated 92. undated 93. undated 94. undated BSRA409530 Lung Cancer in a Population of Asbestos Cement Workers" by Janet Hughes and Has Weill - "Is Asbestos or Asbestosis the Cause of the Increased Risk of Lung Cancer in Asbestos Workers?", an Editorial from British Journal of Industrial Medicine, 1986, by Kevin Browne Medical Progress - Asbestos-Related Diseases" by Mossman and Gee, from the New England Journal of Medicine, June 29, 1989 "Exposure to Asbestos and the Risk of Gastrointestinal Cancer: a Reassessment" by Edelman, British Journal of Industrial Medicine, 1988 - "Asbestos and Colon Cancer: Lack of Association in a Large Case-Control Study" by Garabrant, et al., 1992 - "Fiber Toxicology," edited by David Warheit, DuPont U.S. Navy film entitled "Insulating Hot & Cold Pipes" "Asbestos-Related Disease in the Workplace and the Environment: Controversial Issues" from The Lung-Current Concepts, ed. by Andrew Churg, M. D. "Asbestos, Asbestosis, and Lung Cancer" Editorial from Modern Pathology by Andrew Churg, M.D. Articles on colon and other gastro cancers: - Ehrlich, Gordon & Dikman, 1991, "Carcinoma of the Colon in Asbestos-Exposed Workers: Analysis of Asbestos Content in Colon Tissue" - Seidman and Selikoff, 1986, "Decline in Death Rates Among Insulation Workers 1967-1986 Associated With Diminution of Work Exposure to Asbestos" Edelman, 1988, "Exposure to Asbestos and the Risk of Gastrointestinal Cancer: a Reassessment" Weiss, "Lack of Causality Between Asbestos and Colon Cancer" Garabrant, 1992, "Asbestos and Colon Cancer: Lack of Association in a Large Case-Control Study" Donham, et al, "The Effects of Long-Term Ingestion of Asbestos on the Colon of F344 Rats" Frumkin, 1988, "Asbestos Exposure and Gastrointestinal Malignancy Review and Meta-Analysis" "Asbestos and Disease" by Selikoff Charts of Plaintiffs work history -8- 95. 1943 96. December 1999 97. undated 98. undated 99. undated 100. undated 101. 102. undated "Safeguarding Petroleum Refineries and Their Workers" by Roy S. Bonsib "A Case Control Study of Lung Cancer Among Refinery Workers" by Rosamilia, Long, and Raabe "What ? No Asbestos ?" A magazine advertisement for Asbestos Limited Inc. Advertisement for Johns-Manville products referring to "asbestos the magic mineral" Advertisement entitled "Asbestos in Action" from Keasbey & Mattison Company U.S. Fuel Administration tag on "hints on saving coal" Documents from Brown & Root Inc. as follows: (a) office memo dated 4/27/71 re: safety and health regulations for construction; (b) office memo of 11/7/72 re: asbestos (c) 11/16/72 office memo pertaining to asbestos (d) 1/9/73 office memo concerning record keeping for asbestos (e) 6/23/75 office memo regarding asbestos and fiberglass sampling (f) 11/15/77 office memo, subject: asbestos (g) 4/1/76 office memo re: asbestos record keeping requirements (h) asbestos program - Brown & Root Inc. (undated) (i) 1/14/76 office memo concerning respiratory protection and attached respiratory protection program Mundy Industrial Maintenance's Procedures for Working Asbestos Insulation BSR\409530 -9-