Document opVb8y2ogpv5vJzZk5EjxjXR
SCOTT, HULSE, MARSHALL, FEUILLE, FINGER & THURMOND, P.C.
JEFFREY S'. ALLEY BOARD CERTIFIED - CIVIL APPELLATE LAW . TEXAS BOARD OF LEGAL SPECIALIZATION
ATTORNEYS AT LAW
'JODI JUfl 26IIOO CHASE TOWER
201 EAST MAIN DR1VI POST OFFICE BOX 99123 ELFASO, TEXAS 79999-9123 TELEPHONE (SIS) 533-2-493 _-TELECOPIER (915) 548-3333
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-- June 25, 2001
LOUIS A. SCOTT (1895-1974)
JAMES F. HULSE : (1905-1939)
PLEASE ADDRESS FIRM ATTN: WRITER
Ms. Lou Thompson
Baron & Budd, P.C.
3102 Oak Lawn Avenue, Ste. 1100
Dallas, Texas 75219
III
VIA NEXT DAY AIR
WRITER'S DIRECT TELEPHONE
(915) 54S-S20I
E-MAIL
jall@scotthulse.com
Re: Irma Bustamante, individually and as Personal Representative of the Heirs and Estate ofJose Peralta, deceased v. Owens Corning Corp, et al.; In the County Court at Law Number Three of El Paso County, Texas Cause Number: 9913990
Dear Lou:
Please consider this letter a supplement to Chevron's discovery responses. Attached are drawings 015810 to 015867.which were sent to me from Englehard Corporation. These drawings were originally owned by Houdry, Inc. which apparently went out of business or was acquired by seme other entity many years back. Two ex-Houdry employees, Buck Cross and EdIWhile acquired all of Houdry's HCC drawings for a consulting business they ran. When Buck Cross died last year, his office manager, sold all the drawings to Englehard, who provided copies of the El Paso HCC to me under subpoena.
Also attached are three photos of the HCC that J.E. Hayden had in his position and which he sent to me through Chester Hall, 015868-015870. They copied me on an e-mail, 015871, which may qualify as atwitness statement which is also being produced. Also enclosed is a photo which Mr. Hah has made notes on, 015872.
Sincerely, .
JSA/lp Enclosures
582760.1
Jeffrey S. Alley For the Firm
Ms. Lou Thompson June 25, 2001 Page 2
cc: Mr. Michael T. Bridwell
Strong, Pipkin, Nelson, BIssell & Ledyard, L.L.P.
1400 San Jacinto Building^
595 Orleans
^
Beaumont, Texas 77701-3255
582760.1