Document qdmz2M8Oq6njeEop3aX1Q5jXj

NO. 26,166 GWENDOLYN GRAY LUCE, Individually and as Personal Representative of the Heirs and Estate of ROBERT THOMAS LUCE, Deceased vs. AC&S, INC., et al. IN THE DISTRICT COURT OF MILAM COUNTY, TEXAS 20,h JUDICIAL DISTRICT DEFENDANT SUNOCO. INC. (R&MVS SECOND AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR DISCLOSURE TO: Plaintiff, Gwendolyn Gray Luce, Individually and as Personal Representative of the Heirs and Estate of Robert Thomas Luce, Deceased, by and through her attorney of record, C. Andrew Waters, Attorney at Law, 4807 West Lovers Lane, Dallas, Texas 75209. COMES NOW, Defendant, Sunoco, Inc.(R&M), and serves the following Second Amended Responses to Plaintiffs Request for Disclosure, pursuant to Rule 194 of the Texas Rules of Civil Procedure: (a) The correct name of each party to this lawsuit; RESPONSE: The correct name of this Defendant is Sunoco, Inc. (R&M). Defendant does not have knowledge regarding the correct names of the Plaintiff or other Defendants in this lawsuit. (b) The name, address and telephone number of each potential party; RESPONSE: At this time, Defendant is unaware of any potential parties to this suit. (c) RESPONSE: The Plaintiff has provided little or no factual information regarding her claim against th-is-D-ef-en-dant th- eref-ore i-t|f||j tjme plaintiff has provided no information that Decedent ever worked at premises owned by tlus^^^^^Eve^^D^^ent did There is no evidence that Decedent was ever exposed to G:\5015-14\MilamVDiscovery\2nd am ans to req for disci.wpd Page asbestos at this Defendant's facility, nor is there any evidence that exposure to asbestos or asbestos containing materials while working at the Defendant's premises was the proximate cause of the Plaintiffs alleged injuries or damages. Further, Plaintiffs claims are barred by the statute of limitations in that Plaintiff failed to bring this suit within two years after they knew or should have known of the alleged connection between the alleged symptom and the alleged exposure. ^ .......... Also, should be reduced accbrdihglyt Defendant will supplement this disclosure as discovery progresses, if necessary. (d) For economic damages you seek to recover in this suit, state the amount sought and the method by which such damages were calculated; RESPONSE: N/A. (e) The name, address and telephone number of each individual having knowledge of facts relevant to this lawsuit and a brief statement as to how each such individual is connected to this case; RESPONSE: Edith F. Coen Manager-Health, Environmental and Safety Sun Pipe Line Company P.O. Box 2039 Tulsa, OK 74102-2039 918-586-6000 Sun Manager Wilbur "Bucky" Crisp Sun Pipe Line company Nederland, Terminal P.O. Box 758 Highway 347 Nederland, TX 77627 409-727-2301 Nederland Terminal Manager J. Ronald Ficke, M.D. Sun Company, Inc. (Current address and phone number unknown) Former Medical Director of Sun G:\5015-14\Milam\Discovery\2nd am ans to req for disci,wpd Page 2 Charles Ryan, M.D. (Deceased) Sun Company, Inc. Former Medical Director of Sun Jack Stein, M.D. Sun Company, Inc. Ten Penn Center 1801 Market Street Philadelphia, PA 19103 Current Medical Director of Sun Wayne Stewart, M.D. Sim Company, Inc. (Current address and phone number unknown) Former Medical Director of Sun Lajaunda Williams Sun Pipe Line company Nederland, Terminal P. O. Box 758 Highway 347 Nederland, TX 77627 409-727-2301 Sun employee at the Nederland Terminal Rus Barnes Rural Route 8, Box 1825 Beaumont, Texas 77705-9808 (409) 794-1567 Defendant also identifies any and all physicians who have examined Plaintiff or have reviewed medical records on Plaintiff and who have been designated by any Co defendant as expert witnesses in this case, including, but not limited to the following: Dr. Robert Hebler Baylor Medical Center 3535 Worth, Sammons, #720 Dallas, TX 75246 Dr. Robert G. Mennel Baylor Medical Center 3535 Worth Dallas, TX 75246 G:\50l5-l4\Milam\DiscoveryV2nd am ans to req for disci wpd Page 3 Dr. Carl Noe Baylor Medical Center 3600 Gaston - Wadley #360 Dallas, TX 75246 Dr. Mai Baylor Medical Center 3600 Gaston Dallas, TX 75246 Defendant also identifies any person identified by any other party to this case as having knowledge of relevant fats, whether or not such party is still a party at the time of trial. All witnesses deposed in this case. Discovery has not been completed in this case and this response may be supplemented, if required by the rules, as additional persons with knowledge of relevant facts are revealed. (0 The following information regarding testifying experts: 1. name, address and telephone number; 2. the subject matter of the expert's testimony; RESPONSE: Jonathan M. Haas 1765 Preserve Point Terrace Orange Park, Florida 32073 904-264-7939 Mr. Haas may testify regarding Sun's corporate industrial hygiene and safety rules and procedures. Further, he may also offer opinions and/or rebuttal testimony as necessary to Plaintiffs experts' claims and related topics. Alan Gillie Industrial Hygienist Sun Pipe Line Company Ten Penn Center 1801 Market Street Philadelphia, PA 19103 Mr. Gillie may testify regarding Sun's industrial hygiene and safety rules and procedures. Further, he may also offer opinions and/or rebuttal testimony as necessary to Plaintiffs G \5015-14\Milam\Discovery\2nd am ans to req for disci.wpd Page 4 experts' claims and related topics. Gus Ruggiero Industrial Hygienist Sun Company, Inc. Ten Penn Center 1801 Market Street Philadelphia, PA 19103 Mr. Ruggiero may testify regarding Sun's industrial hygiene and safety rules and procedures. Further, he may also offer opinions and/or rebuttal testimony as necessary to Plaintiffs experts' claims and related topics. Jack Stein, M.D. Medical Director Sunoco, Inc. (R&M) Ten Penn Center 1801 Market Street Philadelphia, PA 19103 Dr. Stein may testify regarding the policies and procedures implemented by the Medical Department of Sun. Further, he may also offer opinions and/or rebuttal testimony as necessary to Plaintiffs experts' claims and related topics. Edith F. Coen Manager-Health, Environmental and Safety Sun Pipe Line Company P. O. Box 2039 Tulsa, OK 74102-2039 918-586-6000 Ms. Coen may testify regarding industrial hygiene, health and safety issues. Further, she may also offer opinions and/or rebuttal testimony as necessary to Plaintiffs experts' claims and related topics. Wilbur "Bucky" Crisp Sun Pipe Line company Nederland, Terminal P.O. Box 758 Highway 347 Nederland, TX 77627 409-727-2301 Mr. Crisp may testify regarding operation of Sun's Nederland Terminal. Further, he may also offer opinions and/or rebuttal testimony as necessary to Plaintiffs experts' claims and related topics. G.\50l5-l4\Milam\Discovery\2nd am ans to req for disci.wpd Page 5 Lajaunda Williams Sun Pipe Line Company Nederland, Terminal P. O. Box 758 Highway 347 Nederland, TX 77627 409-727-2301 Ms. Williams may testify regarding operation of Sun's Nederland Terminal. Further, she may also offer opinions and/or rebuttal testimony as necessary to Plaintiffs experts' claims and related topics. Sam Cade, M.D. Texas Diagnostic Imaging 3535 Worth Street #110 Dallas, TX 75246 214-820-3219 Dr. Cade is a "B" reader and may testify regarding the radiographs of the Plaintiffs. Further, he may also offer opinions and/or rebuttal testimony as necessary to Plaintiffs experts' claims and related topics. Dr. Robert Shephard University of Texas Medical Branch at Tyler 11937 U.S. Hwy 271 Tyler, TX 903-877-7100 Dr. Shephard is a "B" reader and may testify regarding the radiographs of the Plaintiff. Further, he may also offer opinions and/or rebuttal testimony as necessary to Plaintiffs experts' claims and related topics. Dr. Patrick Connelly 2727 West Holcomb Houston, TX 77024 713-442-0000 Dr. Connelly is a "B" reader and may testify regarding the radiographs of the Plaintiff. Further, he may also offer opinions and/or rebuttal testimony as necessary to Plaintiffs experts' claims and related topics. Kathryn Hale, M.D. 6550 Fannin, #1215 Houston, TX 77030 713-790-6492 Robert Ross, M.D. 17030 Manes, #214 G:\5Q15M4\Mtlam\Discovery\2nd am ans to req for disci wpd Page 6