Document vVn9XYDOvnO2xDqb3xnj7dmX9
FILE NAME: National Gypsum (NG) DATE: 1988 NG076 DOC#: NG076 DOCUMENT DESCRIPTION: Legal - Response of Defendant National Gypsum to Plaintiffs' Request for Production
MARGARET ANN ROSE
D e H ay & B lanchard
ATTORNEYS AND COUNSELORS PLAZA OF THE AM ERICAS
2 5 0 0 SO UTH TO W ER LB 201 DALLAS TEXAS 75201-2880
1214) 3 5 3 -1 3 1 3
September 9, 1988
T E LE X -510 10021 09 ANSW ER BACK-DEHAY DAL U T E L E C O P IE R (2141 2 2 0 - 0 4 3 9
Ms. Lisa Blue Baron & Budd Tenth Floor, Dallas Federal
Savings Tower 8333 Douglas Avenue Dallas, Texas 75225
Re: Cause No. 87-16079-D; Georgiann Rowell, et al. v. Armstrong World Industries, Inc, et al.
Dear Lisa:
Enclosed please find Response of Defendant National Gypsum Company To Plaintiffs' Request For Production filed in the above-referenced matter*
Sincerely
MAR/lkt Enclosure
cc: Mr. C. Edward Fowler, Jr. Mr. Joe Michael Russell Mr. Joe Riddles Mr. James T. Foley Mr. Herbert Boyland
Margaret Ann Rose
No. 87-16079-D
GEORGIA:;:*; ROWELL, et al.,
Plaintiffs,
V.
ARMSTRONG WORLD INDUSTRIES,
INC., et a l .
Defendants.
IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 95TH JUDICIAL DISTRICT
RESPONSE OF DEFENDANT NATIONAL GYPSUM COMPANY TO PLAINTIFFS1 REQUEST FOR PRODUCTION
Defendant, NATIONAL GYPSUM COMPANY ("National Gypsum") re
sponds to Plaintiffs' Request for Production submitted by
Plaintiffs, GEORGIANN ROWELL, Individually and as Personal
Representative of the Estate and Heirs of WINFORD ROWELL; BESSIE
S. SHEPHERD, Individually and as Personal Representative of the Estate and Heirs of THOMAS P. SHEPHERD; LARRY D. HAYS and DONNA
HAYS; VER: N URBAN and EMO JEAN URBAN; OLIVER J. MORGAN and
MARGUERITE MORGAN ("Plaintiffs") as follows:
GENERAL OBJECTIONS
Defendant National Gypsum objects to any request or instruc
tion that purports to impose upon Defendant any obligation not
expressly set forth in the Texas Rules of Civil Procedure.
RESPONSE
1. The last known address of the following individuals:
(a) Jack E. Jones (b) F.R. Griffin (c) J.C. Ouinly (d) C.D. Harless (e) R. Beitz (f) W. Withrock
RESPONSE: National Gypsum objects to this interrogatory on
RESPONSE OF DEFENDANT NATIONAL GYPSUM COMPANY TO PLAINTIFFS' REQUEST FOR PRODUCTION - Page One
the basis that the requested information is not relevant to this action, in the absence of some explanation from Plaintiffs' counsel which establishes relevance. National Gypsum objects to this interrogatory because it is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving these objections, National Gypsum states that Hr. Quinley is scheduled to be deposed on August 30, 1988, that National Gypsum has agreed to consider producing Mr. Withrock following Mr. Quinley's deposition, and that National Gypsum provided Mr. Jones' address to Plaintiffs' counsel in another case. Jack E. Jones' address is 12 Summertree Lane, P.O. Box 1271, Shallotte, North Carolina 28459.
2. Complete and legible copies of the three letters which are attached hereto and marked Exhibits A, B and C.
RESPONSE : More legible copies of the three letters are attached to these responses.
Respectfully submitted, DeHAY & BLANCHARD
SBN (76584700 J. CARLISLE DeHAY SBN 05644000 Plaza of the Americas 2500 South Tower, LB 201 Dallas, TX 75201 (214) 953-1313 ATTORNEYS FOR NATIONAL GYPSUM COMPANY
HOYLE, MORRIS & KERR One Liberty Place, Ste. 1650 Market Street Philadelphia, PA 19103 OF COUNSEL
4900
RESPONSE OF DEFENDANT NATIONAL GYPSUM COMPANY TO PLAINTIFFS' REQUEST FOR PRODUCTION - Page Two
CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the fore going document was sent to Lisa Blue, Baron & Budd, 8333 Douglas Avenu e, 10th Floor/ Dallas, TX 75225 by U.S. Certified Hail, Re tur n Receipt Requested and by regular U.S. Mail, postage prepaid to all other counsel of record in the above-referenced matte r on the 9th day of September, 1988.
RESPONSE OF DEFENDANT NATIONAL GYPSUfl COMPANY TO PLAINTIFFS' REQUEST FOR PRODUCTION - Page Three