Union Carbide Corporation's Responses to Plaintiff's Requests for Disclosure in Garcia v. Owens-Corning, with Witness and Exhibit Lists (2001)

Union Carbide Corporation's responses to the plaintiff's Requests for Disclosure in Cause No. 97CI-15498 (Garcia v. Owens-Corning, et al., Bexar County, Texas). The responses state the company's general defenses and incorporate attached Exhibits A-D: its own witness list, a list of deposition and trial testimony with line and page designations, the CCR Defendants' list of medical and state-of-the-art experts, and the CCR Defendants' exhibit list. The 114-page exhibit was only partly provided (pages 41-109 not sent).

What the document holds

• Pages 1-2: Union Carbide's responses to Requests for Disclosure, signature block and certificate of service (July 2001)
• Pages 3-5: Responses to specific disclosure items: potential parties, defenses, damages, persons with knowledge, experts, insurance, witness statements, medical records
• Pages 6-7: Exhibit A: Union Carbide potential fact/expert witnesses (Bakelite resin, labeling committee, outside experts)
• Pages 8-24: Exhibit B: Defendants' list of potential deposition and trial testimony, with line and page designations
• Pages 25-40: Exhibit C (beginning): CCR Defendants' general list of medical, state-of-the-art, economic, liability and damage experts, with addresses and summaries of expected testimony (pages 41-109 not sent)
• Pages 110-114: Exhibit D (end): CCR Defendants' Exhibit List dated November 22, 1994, items 698-726 (Weill through Ziskind), mostly published medical articles

People and organizations

From Brent M. Karren (Dehay & Elliston, L.L.P., counsel for Defendant Union Carbide Corporation); Misti D. Mosteller (Dehay & Elliston, L.L.P., counsel for Defendant; signed certificate of service) to Russell Budd (Baron & Budd, P.C., counsel of record for Plaintiff).

• Brent M. Karren (author)
• Misti D. Mosteller (author)
• Russell W. Budd (recipient)
• Union Carbide Corporation (its organization)
• Baron & Budd (named)
• DeHay & Elliston, L.L.P (named)
• District Court (named)
• Owens-Corning Fiberglas (named)

Related pages

Pages on our site about what this document covers: Asbestos-Reinforced Plastics: Circuit Breakers, Switchgear, and Resin Pipe · New Jersey Asbestos Exposure Sites: Worksites, Industries, and Trust Coverage · Owens-Corning Fiberglas.

About this copy

This is document UC-2044 of the Union Carbide documents, documents produced and used as evidence in asbestos lawsuits against Union Carbide, 114 pages. Production numbers UC-2044. The same document is also document UC-2002, UC-2003, UC-2035.