Document gD1qQ8vDQbny16qEyJLDe2nDL

CAUSE NO. 25093 PLAINTIFF'S | EXHIBIT * AL-317 LARRY C. WHATLEY, Individually and as Personal Representative of the Heirs and Estate of GLENN WHATLEY, Deceased, et al VS. ALCOA POWER MARKETING, INC., et al IN THE DISTRICT COURT OF MILAM COUNTY, TEXAS 20TM JUDICIAL DISTRICT PLAINTIFFS' AMENDED NOTICE OF INTENT TO TAKE VIDEOTAPED DEPOSITION TO ALL DEFENDANTS AND THEIR COUNSEL OF RECORD: PLEASE TAKE NOTICE that, pursuant to the Texas Rules of Civil Procedure, Plaintiffs will take the videotaped deposition of Thomas Bonney on Wednesday, February 25, 1998 at 10:00 a.m. at the offices of LeBoeuf, Lamb, Greene & MacRae, 601 Grant Street, Pittsburgh, Pennsylvania 15219, (412) 594-2300 before a certified court reporter provided by Guyton Court Reporting, 262 North Belt East, Suite 200, Houston, Texas 77060, (281)999-4992. Guyton Court Reporting will also provide the videotaped technician. The deposition will continue from day to day until completed. Additionally, notice is further given that the request is made as authorized under Rule 201 of the Texas Rules of Civil Procedure that the witness is required at the time of his deposition to produce the documents listed in the attached Exhibit "A.'1 PLAINTIFFS' AMENDED NOTICE OF INTENT TO TAKE VIDEOTAPED DEPOSITION d:\employcr\v. hat]ey\notices\amended bonney Page 1 Respectfully submitted, LAW OFFICES OF ANDREW WATERS C. ANDREW WATERS State Bar No. 20911450 GEORGE GALT BREADY, JR. State Bar No. 00796246 400 South Zang Boulevard, Suite 500 Dallas, Texas 75208 (214) 941-0532 (214) 941-8855 Fax MARK IOLA State Bar No. 00792294 Stanley, Mandel & Iola 3100 Monticello, Suite 750 (214) 443-4300 (214) 443-0358 Fax CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was sent by facsimile to all counsel of record on this IX ^ day of February, 1998. C. ANDREW WATERS PLAINTIFFS' AMENDED NOTICE OF INTENT TO TAKE VIDEOTAPED DEPOSITION d:\employer\whatley\notices\amended bonney Page 2 EXHIBIT "A" 1. Any and all documents reviewed in preparation for depositions related to asbestoscases. 2. Any and all documents reviewed during the last 6 months regarding asbestos. 3. Any and all prior depositions and exhibits attached thereto, given by the witness. 4. Any and all training manuals and other written materials, articles, textbooks, notes, etc. related to asbestos and/or the hazards thereof and in the witness' possession and/or control. PLAINTIFFS' AMENDED NOTICE OF INTENT TO TAKE VIDEOTAPED DEPOSITION d:'cmploycr\whatley\noticcsumended bonney Page 3