Document e74XNJGLjKKagYN96O7YNXyxG

NO. 96-3062 BRUCE D. DAVIS and JAMES R. DAVIS, Individually and as Personal Representatives of (he Heirs and Estate f FRANKIE GENT, DAVIS, Deceased, claL Plaintiffs, VS. OWENS-CORNING FIBERGLASS CORPORATION, et al, Defendants. I S IN THE COUNTY COURT AT LAWNUMBER 3 EL PASO COUNTY, TEXAS SOUTHWESTERN BELL TELEPHONE COMPANY'S it at response to PLAINTIFFS* REOUESTS FOR ! COMES NOW, Defendant Southwestern Bell Telephone Company CSWB'l'") and pursuant to TEX. R. CIV. PRO, 193,194, and 193, files these Supplemental Responses Plaintiff? Requests for Disclosure as follows: (e) the name, address, and telephone x umber ofpersons having knowledge ofrelevant facts, and a briefstatement ofeach identified person's connection with the case; AMSWER: Ken Treuter (Address and Telephone Number unknown at this time), Mr. Treuter is a former investigator for Baron & Budd He may testify thathi^ job duties included finding witnesses who could support claims ofasbestos exposure by B&B plaintiffs. He will testify about B&B's methods for locating witnesses, specifically that ads are placed in newspapers asking former employees to call ifthey worked for a particular company or at a specific job site between the early 1940s and late 1970s. He may also testify regarding witness preparation methods used by BAB, specifically that witnesses are coached to name 20 or 30 different asbestos-containing products that are manufactured by companies B&B typically sues, and testify that those products were used at job sites were the plaintiffworked. He may SOUTHWESTERN BELL TEIIPHONE COMPANY'S SUPPLEMENTAL RESPONSE TO FLAPmrrs* REQUESTS tor disclosure - * DifctltMIMvl.4113S.000M