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