Document xzxxbebrp6o57G0Bnqkdq9pjb

CAUSE NO. 00-2721-H GONSaLO CaRILLO, et al., Plaintiffs, V. GaF CORPORATION (successor to RUBEROID CORPORATION), et al., Defendants. IN THE DISTRICT COURT NUECES COUNTY, TEXAS 347"* JUDICIAL DISTRICT DEFENDANT REYNOLDS METALS COMPANV'S RESPONSES TO PLAINTIFFS REQUEST FOR RULE 194 REQUEST FOR DISCLOSURE TO: Plaintiff, LUIS VERA, by and through his attorney o f record, Stephanie Finch, Esq., Baron & Budd, 3102 Oak Lawn Avenue, Suite 1100, pailas, Texas 75219 Defendant Reynolds Metals Company ("Reynolds"), by counsel, pursuant to Rule ] 94 ofthe Texa Rules of Civil Procedure, responds as follows to Plaintiffs Request for Disclosures: A. The correct names of the parties to the lawsuit. Reynolds states that its correct name is Reynolds Metals Company; it is without knowledge ;.s to the correct names ofthe other parties to the lawsuit. B. The name, address, and telephone number of any potential parties. At this lime, Reynolds is aware not aware of any "potential parties." Reynolds reserves the i ight to supplement its response to this request. C. The legal theories and, in general, the factual bases of the responding party's claims. Reynolds refers plaintiffto its Special Exceptions, Original Answer and Affirmative Defens, s to Plaintiffs' Original Asbestos Petition Subjecno Reynolds' Motion to Transfer venue to San Patrick. County and its Motion to Sever or Drop. At this time, Reynold:; expectsthat its defense will be based on documentary and testimonial evidence (including lay and expert testimony) that: Plaintiffs' claims against Reynolds are barred by the statute of limitations; PlaintiffVera was not exposed to harmful levels of airborne asbestos fibers on any premis< owned, operated and/or controlled by Reynolds; PlaintiffVera has no asbestos-related illness or ipjuiy; Reynolds did not owe a legal duty to protect Plainti ffVera against hazards incident to his work; PlaintiffVera and/or his employer - who marketed and sold asbestos-containingproducts i o Reynolds and installed those products - were in a superior position to know about and protect against potential health hazards associated with the inhalation of airborne asbestos fibers; Reynolds was not negligent; and PlaintiffVera was comributorily negligent. IfPlaintiff Vera was exposed to harmful levels ofasbestos while on Reynolds' property, such exposure resulted from the acts of other persons or entities for which Reynolds was 1.01 legally responsible. D. The amount and any method of calculating economic damages. At this time. Plaintiffs have not disclosed the amount of damages they seek nor the method o i calculating such damages. Although Reynolds generally denies that grounds exist for damages, Reynolds cannot respond specificallyto plaintiffs' claimed damages and/or damage calculation. Reynolds therefore reserves the right to supplement its response to this Request until such time as .> plaintiffhas provided this information. . The name, address, and telephone number of persons having knowledge of relevant facis, and a brief statement of each identified person's connection with the case. 2 Investigation and discovery is ongoing in ibis matter, and, at this time, Reynolds does not kn. <w each and every individual who has knowledge of the relevant facts, nor does Reynolds know at thisline whom it may call to testily at the trial ofthis matter. Reynolds therefore reserves the right to supplement its response to this Request in accordance with Rule 193 ofthe Texas Rules of Civ il Procedure. At this time, Reynolds identifies the following individuals who may have knowledge of relevant facts and who Reynolds may call to testify at the triai ofthis matter: 1) Plaintiffs (a) Luis Vera (b) Zulema R. Vera 2) Anv and all Family Members ofthe Plaintiffs. This includes, but is not limited to, Santos Ricio and Rene R. Vera. 3) PlaintiffVera's Treating Physicians. Reynolds may any or all ofPlaintifFVera's treating physicians as trial witnesses to offer testimony, including expen testimony, about their care treatment and diagnosis of PlaintiffVera. At this time, Reynolds names the following physicians identified in Mr. Vera's Answer to interrogatories: (a) Dr. Pete Garcia Medical Tower Corpus Christi, TX (b) Dr. Gilberto Sosa 605 East Caesar Avenue _ Kingsvile.TX (c) Dr. Sergio Tavares 613 Elizabeth Street, M302 Corpus Christ), TX 3 (d) Dr. David Gray 7121 South Padre Island, Drive #102 Corpus, Cbristi, TX (e) Dr, Stephen Turner 613 Elizabeth Street, #302 Corpus Christi, TX 4) Coworkers. Reynolds may call PlaintiffVera's coworkers as trial witnesses. Reynolds reserves the right to supplement its response to this request when Plaintiffhas identified the names and addresses ofhis coworkers. (a) Eduardo Rodriquez (b) Dupe Flores 5) Reynolds Personnel/Witnesses. (a) San Patricio Reduction Plant Personnel. Reynolds may call some or all ol the following individuals who were employed at various times at the San Patricio Reduction Plant to te-.tify as to their personal knowledge concerningplant operations arid plant conditions; the use of asbestos containing products in plant operations; the elimination and abatement ofasbestos; Reynolds' safety procedures, both in general and as they relate to asbestos (including the use of respirators); Plaintiff Vera's potential for asbestos exposure from installing products at Reynolds' plants; and, other matter relevant to plaintiffs claims and/or Reynolds' defenses: Robert Dale Gamble, M.D. S301 St- Andrew Corpus Christi, Texas 78413 4 (512)991-2985 Dr. Gamble was die San Patricio Reduction Pl.int and/or Sherwin Alumina Plant Medical Director from 1975-85. He has knowledge regarding the Respiratory Surveillance Program at the San Patricio Reduction Plant. He also may have knowledge ofReynolds' saf- ty procedures in general, as well as specific safety procedures as they relate to asbestos. He ma have knowledge related to asbestos exposure procedures. Harry R. Bratt, M-D. 2040 Birch Ave. Saint Helena, CA 94574 Dr. Bran was the San Patricio Reduction Plant and/oT Sherwin Alumina Plant Medic.1 Director from 1971-75. He has knowledge regarding the Respiratory Surveillance Program the San Patricio Reduction Plant. He also may have knowledge ofReynolds' safety procedu es in general, as well as specific safety procedures as they relate to asbestos. He may have knowledge related to asbestos exposure procedures. Mr. E- W. Dressen 221 Blanco Portland, Texas 78374 (512)643-2104 Mr. Dressen was the an Engineer and Reduction Superintendentatihe San Patricio Reduction Plant. He also was the acting plant manager ofthe San Patricio Reduction Plant J<om 1974-79 and from 1981 until the plant closed. He may have knowledge regarding plant operations; various applications ofasbestos-comainingproducis throughout the plant; the us-, eliminationand/or substitution ofasbestos-comainingproducts; and Reynolds' attitude towa. d safety and employee health in general- Kenneth E. Mwrpbree 458 Caroline Acres Point Hot Springs, Arkansas 71913 (501)525-3726 Mr. Murphee was the plant manager of the San Patricio Reduction Plant from 1979- * 1. He may have knowledge regarding plant operations; various applications of asbestos-contai. .ing products throughoutthe plant; the use, elimination and/or substitution ofasbestos-containin; products; Reynolds' attitude toward safetyand employee health in general; and other relevant information.. William E- Campbell 7746 East Caguna Azu! 5 Apartment #272 Mesa, Arizona 85208 (602)357-9978 Mr. Campbell was ihe plant manager ofthe San Patricio Reduction Plant from 1972-7 7. He may have knowledge regarding plant operations; various applications ofasbestos-contain. ig productsthroughoutthe plant; the use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information. Mr. Hairy V. Helton 509 Kilmarnock Drive Richmond, Virginia 23229 (804)740-7705 Mr. Helton was employed at the San Patricio Reduction Plant from 1966-72 and held positions as potroam supervisor, general plant supervisorand, from 1971-72, plant manager. He may have knowledge regarding plant operations; various applications of asbestos-containing products throughout the plant; the use, elimination and/or substitution of asbestos-containing products; Reynolds' attitude toward safety and employee health in general; and other relevant information. Mr. Clyde Poyce Hester 546 Evergreen Drive Corpus Christ!, Texas 784)2 Mr. Hester was the chiefchemist at the San Patricio Reduction Plant from 1953-89. He may have general knowledge about the plant processes, environmental issues (including asbestos abatement issues) and other information. Mr. Allen G.HU1 418 Fetick Avenue Taft, Texas 78390-2808 (512)528-2749 Mr. Hill was a chemist at the San Patricio Reduction Plant from 1967-85. He may h.ive general knowledge about the plant processes, environmental issues (including asbestos abatement issues) and other info/rmation. Mr. William D. Pipes P.O. Box 148 Crazier, Virginia 23039 (804)784-1250 6 Mr. Pipes hd4 the following titles at the San Patricio Reduction Plant from 1966-77: process engineer, power plant supervisor; and maintenance superintendent. He also was the plant engineer from 1979-82. He may have knowledge about the use and application of asbestos-containingproducts, elimination and/or substitution ofasbestos-containingproducts general health and safety issues and other relevant information. Mr. Kenneth W. Younger ' 12604 Hardings Trace Court Richmond, Virginia 23233 (804)281-4111 Mr. Younger was a project engineer at the San Patricio Reduction Plant from 1970-7 / and 1980-85. He may have knowledge about the use and application ofasbestos-containing products, elimination and/or substitution of asbestos-containingproducts, general health and safety issues and other relevant information. Mr. Brice C. Nelson 1045 Wilshire Corpus Christi, Texas 78411 (512) 8S2-4S3S Mr. Nelson was involved in the original consuuctionand operation ofthe carbon pla. ,t at the San Patricio Reduction Plant, and he worked at the San Patricio Reduction Plant from approximately 1951-69, and from 1974-76. He may have knowledge regarding the construct .on and processes ofthe San Patricio Reduction Plant in general, the availability and use ofpersonal protective equipment, general health and safety issues and applications of asbestos products .,i the plant Mr. Raymond L. Bennett 414 Reynolds Avenue Taft, Texas 78390 (512)528-3284 Mr. Bennett was the power plant supervisor ai the San Patricio Reduction Plant from approximately 1953-84. He may have knowledge regarding plant operations in general and i he operation ofthe power plant in particular. He also may have knowledge regarding applicati. .as ofasbestos products in the powerplant Mr. John Massey P.O.Box 73 Baysjde, Texas 78340 (512)529-6692 7 I Mr. Massey was a foreman in The San Patricio Reduction Plant maintenance deparmv. from approximately 1952-88. He may have general knowledge regarding plant operations, it; use and application ofasbestos-coniaimngproducis,the availability and use of personal protective equipment, general health and safety issues and other relevant information. Mr. James C. Black 224 Bafanridge Drive Hot Springs, AR 71901 (501)624-7244 Mr. Black was employed at the San Patricio Reduction Plant as a potroom foreman fi >m 1960-63. He may have general knowledge regarding plant operations, the use and application of asbestos-containingproducts, the availability and use ofpersonal protective equipment and general health and safety issues, and other relevant information. Mr. Clyde A. Krueger 131 Granby Portland* Texas 78374 (512)643-2421 Mr. Krueger was a general foreman at the San Patricio Reduction Plam from 1952-8>i He may have general knowledge about the plant processes, the use and applicationofasbest< >*containing products, the availability and use ofpersonal protective equipment and general hr - dth and safety issues. Mr. William E. Shepp 244 Ross Road Kelso, Washington 98626 (360)578-2429 Mr. Shepp was a potroom engineerand casthouse supervisorat the San Patricio Reduction Plant. He may have knowledge about the use and application ofasbestos-contain > ng products, eliminationand/or substitution ofasbestos-containingproducts, general health and safety issues and other relevant information. Mr. Harold L- Bern, dr. 2341 East Lynnwood Drive Longview, Washington 98632 (206)425-8082 Mr. Bern was the Personnel Manager at the San Patricio Reduction Plant from 1979 82 and may have knowledge about informationrelevant to this lawsuit. I8 s Mr. Joel W. Whitlock 6837 SE Cottrell Road Gresham Oregon 97080-8911 (503)663-2096 Mr. Whiilock was employed at the San Patricio Reduction Plant from 1958-71 and, during that rime, held the following titles and positions, potroom general clerk; potroom foreman; anode foreman; pot relining supervisor; maimenance supervisor and plant safety engineer. He may have general knowledge regarding plant operations, the use and applicatioi, of asbestos-containingproducts, the availability and use of personal protective equipment and general health and safety issues, and other relevant information. Mr. Jack H. Norris, Jr. 4318 St. George Corpus Cbristi, Texas 78413 (512)853-1021 Mr. Norris was a purchasing agent at the San Patricio Reduction Plant from 1976-86 ,.nd plant purchasing manager from 1986-88. He may have knowledge about the purchase, use and application of asbestos-containingproducts and/or substitutes for asbestos-containingproduc; >, the purchase and use of safety equipment (including respirators), asbestos abatement and oth r relevant information. Richard C. Easterline 15 Serra Lape Masseqa, New York 13662 (315)769-1996 Mr. Easterline was employed at the San Patricio Reduction Plant from 1968-82 and l.eld positions as an engineer and carbon services supervisor. He may have general knowledge regarding plant operations, the use and applicationof .isbestos-containingproducis, the availability and use of personal protective equipment and general health and safety issues, and other relevant information. John W. Ford c/o Reynolds International P.O.Box 27002 Richmond, Virginia 2i261 (503) 6664)203 Mr. Ford was the plant maintenance supervisorat the San Patricio Reduction Plant f. om 1979-83. He may have genera) knowledge regarding plant operations, the use and applicati. >n of 9 asbestos-containingproducts, the availability and use ofpersonal protective equipment and general health and safety issues, and other relevant information. (b) Reynolds Cnqiorate Personnel. Reynolds may call some or all ofthe following individuals to testify regarding their personal Icnowlc dge on matters of safety, medical and industrial hygiene issues on the corporate level and/or at the Sherwin and/or San Patricio plants specifically;plant operations and conditions; the use, elimination and/or substitution of asbestos- containing products; and, on other matters relevant to plaintiffs claims and/or Reynolds' defenses: Or. Woolsoa W. Doane 14 Runswick Drive Richmond, Virginia 33233-5413 Dr. Doane was Reynolds' Corporate Medical Director from 1993-June 1997. He m-y be called to testify about his knowledge concerning corporate medical issues and the Respiratory Surveillance Program at the Sherwin and San Patricio plants. David Warren, M-D8705 Tarytown Drive Richmond, Virginia 23229 Dr. Warren was the acting Corporate Medical Director from 1992-93. He may be cal led to testify about his knowledge concerning corporate medical issues and the Respiratory SurveillanceProgram at the Sherwin and San Patricio plants. E. Claiborne Irby, M-P. 11-1/2 Tapoan Road Richmond, Virginia 23226 Dr. Irby was an Associate Corporate Medical Director from 1959-77, and Corporate Medical Director for Reynolds from 1977 until his retirement in 1992. He may be called as.. factual witness, but because he also qualifies as an exjiert, he may offer expert testimony in ti fields ofoccupational medicine, state-of-the-art, governmental regulations, and medical issues in general as they may relate to oc,cupational asbestos exposures. James MacMillan, M-D306 Gupby Drive Richmond, Virginia 23229 v 10 Dr. MacMillan was ihe Corporate Medical Director of Reynolds from 1956-77. He ma be called to testily about his knowledge concerning corporate medical issues and the Respiratory Surveillance Program at the Sherwin and San Patricio plants. Mr. Homer Mac Cole Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 (804)281-3506 Mr. Cole is the Corporate Director of Industrial Hygiene and Toxicology at Reynold;. He has been an industrial hygienist at Reynolds since 1972. Mr. Cole performed industrial hygiene surveys at the Sherwin and San Patricio plants and may testify regarding such surw ys as well as other factual matters based on his personal experience and knowledge, including, but not limited to, plant conditions, various uses of asbestos-containing products in plant applications, the elimination and substitution of asbestos-containing products, and general issues related to industrial hygiene and safety. Although Mr. Cole will testify as a factual witness, he qualifies as an expen and may offer expert testimony in the fields of industrial hygiene, occupational health and safety, state-of-the-art, governmental regulations of workplace exposures, threshold limit values, the measurement of occupational asbestos exposures as well as other potential occupational hazards, respiratory protection, and prope, work practices. Mr. Ronald . Benton Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 Mr. Benton is Manager of Industrial Hygiene and Safety Services at Reynolds. He :ias been at Reynolds since 1974. He performed industrial hygiene surveys at Sherwin and Sai: Patricio and may testify regarding such surveys as well as other factual matters based on hi; personal experience and knowledge. Mr. Benton may testify as a factual witness, but because he qualifies as an expert, he may offer expert testimony in the fields of industrial hygiene, occupational and environmental health and safety, state-of-the-art, governmental regulations of workplace exposures, threshold limit values, the measurement of occupational asbestos exposures as well as other potential occupational hazards, respiratory protection, and proper work practices. Ms. Linda Maiilet Reynolds Metals Company 6601 West Broad Street Richmond, Virginia 23230 11 Ms. Maillet was the Regional Industrial Hygienist at the Corporate Headquarters of Reynolds for the Eastern Region. She is currently the Principal Health, Safety and Regulatory Affairs Scientist at the Corporate Headquarters. Ms. Laurie Shelby Reynolds Metals Company 6^01 West Broad Street Richmond, Virginia 23230 Ms. Shelby was the Manager ofIndustrial Hygiene Programs at the Corporate Headquarters of Reynolds. She is currently the Manager of Health and Safety Programs. Mr. Richard Mansur 1416 Coronet Prive Richmond, Virginia 23229-4806 (804)282-4438 Mr. Mansur was the Manager ofthe Industrial Hygiene Department at the Corporal. Headquarters of Reynolds from 1969-75. Mr. James P. Pavidsoq Mr. Davidson was a StaffIndustrial Hygienist at the Corporate Headquarters of Reynolds from 1976-82. Ms. Stacey Hansen 12701 Mirror Pond Way Midlothian, Virginia 23113 (804) 794-1736 Ms. Hansen was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1990-93. Mr. Pale Prokopcbak 2704 Empress Court Richmond, Virginia 23233 (804) 360-3301 Mr. Prokopcbak was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds from 1988-89. Ms. Deborah R. Budgjns 12 Ms. Hudgins was a Staff Industrial Hygienist auhe Corporate Headquarters of Reynolds from 1984-88. Mr. Harry L. Skalsky 6910 West Grace Street Richmond, Virginia 23261 Mr. Skalsky was a Medical Corporate Toxicologist at the Corporate Headquarters oi Reynolds 1979-85. Ms. Karen Kestle 1336 Merrymeade Avenue Glen Allen, Virginia 23060 (806) 264-1789 Ms. Kestle was the Senior Insurance Administrator at the Corporate Headquarters oi Reynolds. Mr. Bobby J. Sasser Mr. Sasser was the Corporate Safety Director for Reynolds from 1973-95. Mr. Joseph Nichols 2300 Cedarfield Parkway Apartment 161 Richmond, Virginia 23233 (804)282-8245 Mr. Nichols was the Corporate Safety Director for Reynolds from 1945-73. (c) Other Reynolds* Witnesses Alex Baca Baca Safety Consulting 6214 Battery Lane San Antonio, Texas 78233 (210)657-0705 Mr. Baca is a retired inspector for the United States Department of Labor Mine Sat ny Health Administration. He was a Federal Mine Safety and Health Inspector from 1975 until January, 1998 with duties to enforce the Safety and Health Regulations on Mining Operations and to gain compliance with such regulations. Pursuant to this position, Mr. Baca inspected 13 the Sherwin Alumina Plant. Mr. Baca may testify reg;irding such inspections as well as to other factual matters based on his personal experience and knowledge. Robert E. Ruckstubl Proactive Safety Consultants Company, Inc. Post Office box 260955 Corpus Chrisri, Texas 78426-0955 (512) 767-J663 Mr. Ruckstuhl is a consultant who specializes in the area of asbestos safety and training. He has performed consulting functions and i raining seminars related to asbestos safety and asbestos abatement issues at the Sherwin Alumina Plant and may testify regarding such consulting services and training seminars as well as other factual matters based on his personal experience and knowledge. 6) Records Custodian*. Reynolds may call, live or by depositionor affidavit, various records custodians to authenticate relevant records, including, but not limited to, the records of Mr. Vera's medical care providers and the records ofhis employers. These individuals may include the following institutions: (a) Spobn Health Systems 605 East Caesar Avenue Kingsville, TX (b) Kingsville Medical Center 227 West Kleberg Avenue Kingsville, TX 7) Otfier Parries' Witnesses. Reynolds reserves the right to call and/or elicit tesrimonj from any individual identified by plaintiffand any other party to this lawsuit and, accordingly, will supplement its response to this request when those individuals have been identified. 8) Rebunal/ItppeachmentWitnesses. Reynolds reserves the right to call rebuttal and/or impeachmeni witnesses and will supplement its response to this request if and when it has sufficiem information to determine the need for such testimony. 14 F. For any testifying expert: (1) The expen's name, address, and telephone number, (2) The subject matter on which the expert will testify; (3) The general substance of the expert's mental impressions and opinions and a briefsummary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to tbe control of tbe responding party, documents reflectingsuch information; (4) Iftbe expert is retained by, employed by, or otherwisesubject to the control the responding party: (A) All documents, tangible things, reports, models, or data compilation.-, that have been provided to, reviewed by, or prepared by or for the expert in anticipation oftbe expert's testimony; and (B) The expert's current resume and bibliography. Pursuantio Rule 195 of the Texas Rules ofCivil Procedure, Reynolds refers plaintiffsto its designation of Expen Witnesses that will be filed in accordance with the scheduling order ofthis co.n and the Texas Rules of Civil Procedure. G. Any discoverable indemnity and insuring agreements. Reynolds has insurance coverage sufficient to cover plaintiffs' claims with the following insurance companies: Reynolds has insurance coverage sufficients cover plaintiffs claims with the following insurance companies: Travelers Insurance (9/30/53 through 9/30/66) Liberty Mutual Group (9/30/66 through 9/30/78) 15 I. Any discoverable witness statements. None. K. All medical records and bills obtained by tbe responding party by virtue of an authorization furnished by the requesting party. Subject to plaintiffs agreement to pay Reynolds one-halfof its cost in retrieving these recon is, Reynolds will produce these records ax $.15 per page or will make them available to plaintiffscoun el for inspection and copying at a mutually convenienttime and place. REYNOLDS METALS COMPANY, WWtUt V. tWAWilOt. (1U. UI/fTUU/^; Eric G. Reeves (Texas Bar No. 24026170 J Lori Elliott Guzman (Texas Bar No 24011471) HUNTON & WILLIAMS 951 East Byrd Street Riverfront Plaza, East Tower Richmond, Virginia 23219 (804)788-8200 (804) 788-8218 (facsimile) R. Clay Hoblit (Texas Bar No. 09743100) Adam C. Cortez (Texas Bar No. 04844650) CHAVES, GONZALES & HOBLIT, L.L.P. 2000 Frost Bank Plaza 202 North Carancahua Corpus Christi, Texas 78470 (512)888-9392 (512) 888-9187 (facsimile) 16 CERTIFICATE of service 1 hereby certify that on March 1, a true and correct copy ofthe above and foregoing instrument is being served by certified mail, return receipt requested, on the following Plaintiffs' counsel: Stephanie Finch Baron & Budd, P.C. The Centrum, Suite J100 3102 Oak Lawn Avenue Dallas, Texas 75219 All other known counsel ofrecord are given notice ofihis pleading by regular United States mail onh HUNTQN& WILLIAMS March 29,2001 RIVERFRONT PLaZa. EaST TCWBR 951 EAST BVRD STREET RICHMOND, VIRGINIA 23219-4071 TEL 804 788 8200 FAX 804 - 788 - 8218 I'UKiSER A BKUUC.nTON DlKtCl' DIAL 04 - 7ss 8632 Email tbruugliiuuM'tuinwii wm VIA TELECOPY W. Hugh Bartlett Legal Assistant Baron & Budd 3102 Oak Lawn Avenue, Suite 1100 Dallas, Texas 75219-4281 _____.... ....... Re: Gonzalo Carillo, et al v. GAF Corporation, ei al. Dear Hugh: Thank you for your letter of March 28,2001. However, I am confident you already are in receipt of our discovery responses. These documents were enclosed with the lettepsent via certified mail, receipt no. 7000 0600 0022 0904 2037. Becaucc Stephanie's name appeared in duplicate on our service list she, along with all other counsel of record, was also sent a copy of the letter without enclosures. It is the second lener to which i believe your correspondence refers. However, I am attaching a copy of the discovery we served previously. I hope all is well and please call me if you have any questions or concerns. Attachments cc: Stephanie A Finch, Esq