Document rpgboqLx7MjpkVg0NjLwD12mv

JOEK. SHORT, JR. VS. A.C. & S., ETAL CAUSE NO.A-980030-C IN THE DISTRICT COURT OF ORANGE COUNTY, TEXAS 128TM JUDICIAL DISTRICT DEFENDANT, ATOFINA PETROCHEMICALS, INC.'S CERTIFICATE OF WRITTEN DISCOVERY ATOFINA Petrochemicals, Inc., a defendant in this matter, files this Certificate of Written Discovery and certifies that the following was sent to Plaintiffs counsel via certified mail, return receipt requested, on March 8,2001: Defendant, ATOFINA Petrochemicals, Inc.'s Interrogatories, First Requests for Production, and First Request for Admissions. Respectfully submitted, JENKINS & MARTIN, L.L.P. P. O. BOX 26008 ATTORNEY FOR DEFENDANT, BEAUMONT, TEXAS 77720-6008 ATOFINA PETROCHEMICALS, INC. (409) 832-4100 TELEPHONE (409) 832-4242 TELECOPIER CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been forwarded to Plaintiffs' counsel by certified mail, return receipt requested and to all other counsel of record by regular U.S. mail, on this 8th day of March, 2001. P:\word\ftu\680-371\Diseovery\Notice of Written Discovery GAIL C JENKINS, RC BOARD CERTIFIED PERSONAL INJUR? ftCIVIL TRIAL LAW TEXAS BOARD OF LEGAL SPECIALIZATION KIRK E. MARTIN LOUIS H. KNABBSCHUH, JR. CLAUDE R. LeMASTORS Jenkins & Martin, l.l.p ATTORNEYS AT LAW ecu. BOX ISOM BEAUMONT TEXAS 77720-8008 TELEPHONE- (400> UE-4100 TELECOPIER; (AOS) 8St-4MX STREET ADDBESSi MIS CALDEH, SUITE S00 BEAUMONT TEXAS 77702 March 12, 2001 In Re: Cause No. A-980030-C; Joe K. Short, Jr. v. A.C.&S., et al; In The 128th Judicial District Court of Orange County, Texas; Our File No. 680.371 Ms. Holly J. Huart Ms. Stephanie Finch Baron & Budd 3102 Oak Lawn Avenue Suite 1100 Dallas, Texas 75219 CERTIFIED MAIL. RRR 7000 0520 0024 1951 3667 Dear Holly and Stephanie: Enclosed please find the Affidavit of Pat Avery-King, which should be attached to ATOFINA Petrochemicals, Inc.'s Responses to Plaintiff's Interrogatories, First Request for Production and First Request for Admissions which were filed on March 8, 2001. If you have any questions, please do not hesitate to contact me. KEM:srr Enclosures c: Mr. Don Carona All Known Counsel of Record (w/o enclosure) (w/o enclosure) f:\Word\Fina\680-371\Letters\PlawiffUr 4 AFFIDAVIT STATE OF TEXAS COUNTY OF JEFFERSON 3 3 3 BEFORE ME, the undersigned authority, a Notary Public in and for said State and County, personally appeared PAT AVERY-KING, who being duly sworn deposes and says that she is over the age of twenty-one (21) years of age, and that she is not disqualified for any reason from making this affidavit, and that she is Administrative Manager for ATOFINA Petrochemicals, Inc. Port Arthur refinery, and is authorized to make this Affidavit. She further states that because of the number of years and issues involved, that no one person has, or could have, personal knowledge of all the matters set out in this discovery request, that the responses set forth have been compiled with the advice and assistance of counsel, that she has read the above answers to interrogatories and that the responses are true and correct." SWORN TO AND SUBSCRIBED BEFORE ME on this QTh_______________ day of fftarcA, 2001, to certify which witness my hand and seal of office. MARTHA J KILE NOTARY PUBLIC STATE OF TEXAS |^CimisionEiplr1(H)5-2002 yui ARY PUBLIC IN AND FOR THE STATE OF 'ftAQS Print Name: df\0rfha^ 1. MY COMMISSION EXPIRES: ) ojS / DSt___________ GAIL C. JENKINS, PC, BOARD CERTIFIED PERSONAL numtX * CtVU. TRIAL LAW TEXAS BOARD Of LEGAL SPZdAUZATXON KIRK E. MARTIN LOUIS a KNABESCHUH, JR. CLAUDE R LMA9TEJt8 Jenkins & Martin, l.l.p ATTORNEYS AT LAW pa BOX 19006 BEAUMONT TEXAS 777104008 TELEPHONE* (4001 Olt-MOO TELECOPIER; 1400) SU-4141 0TSEIT ADDRESS. 7010 CALDER, SUITE 500 BEAUMONT TEXAS 77702 March 12, 2001 In Re: Cause No. A-980030-C; Joe K. Short, Jr. v. A.C.&S., et al; In The 128th Judicial District Court of Orange County, Texas; Our File No. 680.371 Ms. Vickie Edgerly District Clerk Orange County P.O. Box 427 Orange, TX 77630 Dear Ms. Edgerly: Enclosed please find Defendant, ATOFINA Petrochemicals, Inc.'s Notice of Written Discovery in the above-referenced matter. Please stamp your filing date on the enclosed copy of this letter and return to my attention in the enclosed, self-addressed and stamped envelope. By copy of this letter, this document has been forwarded to all known counsel of record. Thank you for your assistance in this regard. KEM:srr Enclosure cc: Ms. Holly J. W. Huart/Ms. Stephanie Finch J. Donald Carona, Jr. All Other Known Counsel of Record f:\WoittFlM\680-37Uetiers\Clerk A