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NO. 00-8305 DARWELL GENE BUSH, ET AL. VS. GAF CORPORATION (f/k/a NEWCO HOLDINGS, INC.), ET AL. IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS M-298TH JUDICIAL DISTRICT DEFENDANT SHELL OIL COMPANY'S 10/29/01 SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE CONCERNING EXPERTS SUBJECT TO MOTION TO TRANSFER VENUE TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW Defendant SHELL OIL COMPANY and in supplementation to the Defendant's response to Request for Disclosure concerning experts, designates the following additional expert: Richard C. Hebert, MD. Pulmonary Disease Clinic 5000 Hennessy Blvd. Baton Rouge, LA 70808 504-769-5864 Dr. Hebert is a pulmonologist residing in Baton Rouge, Louisiana. He is a specialist in the area of respiratory disease. Dr. Hebert may testify as to all matters pertaining to his examination of plaintiff JAMES A. GUILLORY and/or review of plaintiff's medical records, x-rays, and reports and supplemental reports of plaintiff's experts; any communications with plaintiff or plaintiffs family members; the diagnostic criteria used to diagnose asbestos-related diseases; his opinions as to whether plaintiff suffers from asbestos-related disease and the basis of such opinions; the plaintiffs current medical condition and his prognosis thereof, the anatomy and function of the respiratory and circulatory systems; the effect of exposure to substances other than asbestos on the development and manifestation of obstructive and restrictive conditions and diseases of the respiratory system; and the effect of smoking on the lungs. Dr. Hebert's C.V. is attached. BSRV521189 -1- Respectfully submitted, 1200 Smith Street, Suite 400 Houston, Texas 77002 Telephone: (713) 654-1111 Facsimile: (713)650-0027 Attorney for Defendant, SHELL OIL COMPANY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrumentMsbeen fo to counsel for Plaintiffs by certified mail, re; by regular mail, on this<s2j^-day of eceipt requester arded BSRA521189 -2- 10726/2001 15:07 7661375 PULMONARV DISEASE CL PAGE 02 Curriculum Vitae RICHARD C HEBERT, M.D. Cum i 'ositioas Private Group Practice Pulmonary and Critical Care Medicine Pulmonary Disease Clinic 5000 Hennessy Blvd. Baton Rouge, LA 70808 1977-Present Persa information ;te of birth: e ofbirth me address 12/5/40 Morgarusa, Louisiana 6267 Sevenoaks Ave. Baton Rouge, La. 70806 (504) 924-4372 Profc I Address 7777 Hennessy BJvtL, Ste 701 Baton Rouge, La. 70808 (504) 769-5864 Socii rityNo. Available on request Pmel Ltademic Rank L.S.U. School ofMedicine Pulmonary Medicine Associate Clinical Professor of Medicine Educ Louisiana State University Baton Rouge B.S. Chemistry 1963 L.S.U. School ofMedicine M.D. 1966 L.S.U. School of Medicine New Orleans Charity Hospital Rotating Internship 7/66-6/67 L.S.U. School of Medicine Lafayette Charity Hospital General Practice Residency 7/67-6/68 William Beaumont General Hospital, U.S. Army El Paso, Texas Cvrcii is S- (o li 10726/2001 15:07 76B1375 PULMONARY DISEASE CL PAGE 03 Boar* ! itification Medi Hon jKCDM wards Militi ri Service Internal Medicine Residency 10/68-9/71 ABIM Internal Medicine 1972 ABIM Pulmonary Medicine 1976 ABIM Critical Care Medicine 1987 Louisiana 10300 Alpha Omega Alpha Phi Kappa Pin Undergraduate Medical Society U.S. Army 1968-1973 Rank: Major Previi Positions Medical Director ofMedical Services Our Lady of the Lake Regional Medical Center 7777 Hennessy Blvd., Suite 701 Baton Rouge, LA 70808 1992-1997 LSU School of Medicine Earl K. Long Memorial Hospital Associate Clinical Professor 1974-77 Private Practice, Crowley, La. 1973-1974 Profejl i aal Memberships Louisiana State Medical Association East Baton Rouge Parish Medical Association American College of Physicians Fellow American College of Chest Physicians American Thoracic Society Louisiana Thoracic Society American Association for Respiratory Care Louisiana Society for Respiratory Care Instil Cvrchl S-<0- Positions Medical Advisor Louisiana Society for Respiratory Care 1995-1997 Chiefs Medical Intensive Care Unit 10/26/2001 15:07 7661375 PULMONARV DISEASE CL PAGE 04 Cvrcb !l i S-m 1 Our Lady ofthe Lake Regional Medical Center 1990-94 President, Baton Rouge Academy of Internal Medicine 1988-89 Chiefof Staff Earl K. Long Memorial Hospital 1982-83 ChiefInternal Medicine Service Our Lady oftire Lake Regional Medical Center 1981-82 Medical Director Respiratory Care Baton Rouge General Medical Center 1980-1993 Medical Director Southeastern University School ofRespiratory Therapy 1979-1993 Medical Director Respiratory Care Earl K. Long Memorial Hospital 1974-78 Medical Director School ofRespiratory Therapy Earl K. Long Memorial Hospital 1974-1977 Medical Advisor Louisiana Society for Respiratory Care 1979-81 OBSTRUCTION OF AN ENDO-TRACHEAL 1UBE BY ITS HIGH PRESSURE CUFF: RESPIRATORY CARE, 1981. AIR QUALITY AND RESPIRATORY FUNCT] ONING IN CHILDREN WITH PULMONARY DISORE ERS. JOURNAL OF THE LOUISIANA STATEMEDICAL SOCIETY 1994; 455-461. NO. 00-8305 DARWELL GENE BUSH, ET AL. VS. GAF CORPORATION (f/k/a NEWCO HOLDINGS, INC.), ET AL. IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS M-298TH JUDICIAL DISTRICT DEFENDANT SHELL OIL COMPANY'S CERTIFICATE OF WRITTEN DISCOVERY TO THE HONORABLE JUDGE OF SAID COURT: The undersigned counsel for Defendant SHELL OIL COMPANY certifies pursuant to Local Rules that the following has been served upon all counsel of record but has not been filed with the Clerk's office: 1) Defendant Shell Oil Company's 10/29/01 Supplemental Response to Plaintiffs Request for Disclosure Concerning Experts Subject to Motion to Transfer Venue. Respectfully submitted, HAYS,MCCONN, B. STEPHEN RICE State Bar No. 16838000 1200 Smith Street, Suite 400 Houston, Texas 77002 (713) 654-1111/(713) 655-9212-FAX Attorneys for Defendant, shell oil company CERTIFICATE OF SERVICE I hereby certify that the foregoing instrument was forwarded to counsel for-Rldintiffs by certified mail, returKTeceipt requested, and to all other counsel of {eccfltH?y5sgular mail, on this the ^j^-day of 2001. _\ B. STEPHEN RICE BSR7517693.1