Hart and Wedgeworth v. Armstrong Cork, Motion to Compel, Defendants' Supplemental Answers and Expert Witness CVs (1981)

Court papers from the consolidated Mississippi shipyard cases of Roy Latharn Hart and Lelos Wedgeworth against Armstrong Cork Company and others in federal court at Biloxi, May to July 1981. The plaintiffs moved to compel Johns-Manville Sales Corporation, Celotex, Owens-Illinois, Raybestos-Manhattan, Unarco and other makers to answer supplemental interrogatories, calling their answers "vague and general conclusions of counsel" that did not "recite one single specific fact." The file also holds J-M Sales Corporation's verifying affidavit, the defendants' fuller answers of June 1981, a magistrate's order of June 8 and a district judge's order of July 1, 1981, requiring the defendants to answer "fully and without evasion" questions about polls of potential jurors, and résumés of the defense's medical experts.

What it shows

The defendants' answers show how the makers meant to defend the cases. They said the shipyard workers failed to use respirators and exhaust fans made available to them, ignored warning labels that appeared "from and after at least 1964," kept smoking, and misused products: some would "wrap up in such cloth" to shield themselves from welding, and others "used asbestos cloth and other products as pillows or blankets." They blamed the unions, the Navy, the Maritime Commission, the Coast Guard, Ingalls Shipbuilding and its owner Litton, and the yard's insurer, American Mutual. Their list of 29 expert witnesses included Dr. Paul Kotin, Dr. Paul Gross, Dr. George W. Wright and Dr. Hans Weill. The plaintiffs said the defense had named more than 1,000 witnesses and believed some defendants had polled potential jurors before seeking a change of venue. The plaintiffs' earlier interrogatories are on a separate page; Kotin's testimony in other cases is in his 1979 videotaped deposition.

About this copy

Three résumé pages that give private home addresses (pages 51, 52 and 62 of the file, for Drs. William Weiss, David Thorning and George Wright) are left out.