Document yENJ5J5Lmp0V6QpvGqy64QQd

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION JOHN T. EDWARDS and BETTY A. EDWARDS, Plaintiffs, vs NATIONAL GYPSUM COMPANY, Defendant. CASE NO. 81-51-CW-FTMK / DEFENDANT'S AMENDED SECOND SUPPLEMENTAL ANSWERS TO PLAINTIFFS' FIRST RULE 33 INTERROGATORIES The Defendant, National Gypsum Company, submits its amended second supplemental answers to Plaintiff's First Rule 33 Interrogatories and as its response to question 28 attaches hereto as Exhibit "A" pursuant to a prior stipulation of counsel a listing of all workers' compensation cases of which the Defendant has knowledge from its corporate records by name of claimant, jurisdiction, and date of filing of claim filed prior to January 1, 1973. Each of these cases involves a claim by the worker alleging inter alia an asbestos-related disease. I HEREBY CERTIFY that a true copy hereof has been furnished by hand delivery this 14th day of February, 1983, to Russell W. Budd, Esquire, 1050 Dallas Federal Savings Tower, Dallas, Texas 75225, Attorney for Plaintiffs. TMB:db #1955 2/14/83 Thomas M. Burke, of, RUMBERGER, KIRK, CALDWELL, CABANISS & BURKE, A Professional Association Post Office Box 1873 Orlando, Florida 32802 Telephone No. (305) 425-1802 Attorneys for Defendant. 2- - WORKER'S COMPENSATION CLAIMS AGAINST NATIONAL GYPSUM COMPANY BEFORE JANUARY 1, 1973 ALLEGING AN ASBESTOS-RELATED DISEASE* CASE TITLE JURISDICTION Peter Paul Armenti vs. NGC Louis D. Cavinato vs. NGC Alton E. Bass vs. NGC et al. Louis Gremillion vs. NGC et al. Royal A. Ellis vs. NGC William P. Bums vs. NGC John Weber vs. NGC Joseph Schoenig vs. NGC Frank Ansede vs. NGC John Kocisko vs. NGC Jerry M. DeCaro vs. NGC Jerry Wells vs. NGC et al. Timothy Gaylord vs. NGC Alexander C. Parr vs. NGC Morris County, NJ Morristown, NJ Orleans Parish, LA Orleans Parish, LA New Orleans, LA Morristown, NJ Trenton, NJ Trenton, NJ Trenton, NJ Trenton, NJ Trenton, NJ Orleans Parish, LA Trenton, NJ Trenton, NJ *The information provided above was extracted from corporate records and is believed to be accurate. No guarantee or warranty is made in connection with this answer that no other workers nay have filed worker's compensation claims in seme jurisdictions alleging an asbestos-related disease of which this defendant would not have any knowledge. The records of various insurance carriers or self-insured servicing agents were not reviewed in the preparation of this answer in that this defendant has no control over such records or their possible retention periods. DATE 1/27/59 4/19/65 2/28/68 5/3/68 5/27/69 9/12/69 10/10/69 8/18/70 1/25/71 5/24/71 10/4/71 9/8/72 11/29/72 12/15/72 EXHIBIT "A"