ATOFINA Petrochemicals' Certificate of Written Discovery and Related Transmittal Letters, Short v. A.C. & S. (2001)

Court filings and letters in Joe K. Short, Jr. v. A.C. & S., et al. (Orange County, Texas), submitted for defendant ATOFINA Petrochemicals. They include a certificate that written discovery was sent to plaintiff's counsel on March 8, 2001, a March 12, 2001 letter enclosing the affidavit of Pat Avery-King, the notarized affidavit, and a March 12, 2001 letter to the district clerk enclosing the Notice of Written Discovery. No Union Carbide or Calidria content appears.

What the document holds

• Pages 1-2: Defendant ATOFINA Petrochemicals, Inc.'s Certificate of Written Discovery with Certificate of Service, March 8, 2001
• Page 3: Letter, Kirk E. Martin to Holly Huart and Stephanie Finch (Baron & Budd), March 12, 2001, enclosing Pat Avery-King affidavit
• Page 4: Affidavit of Pat Avery-King, Administrative Manager, ATOFINA Port Arthur refinery, sworn March 2001
• Page 5: Letter, Kirk E. Martin to Vickie Edgerly, Orange County District Clerk, March 12, 2001, enclosing Notice of Written Discovery

People and organizations

From Kirk E. Martin (Attorney for Defendant ATOFINA Petrochemicals, Inc., Jenkins & Martin, L.L.P.); Pat Avery-King (Administrative Manager, ATOFINA Petrochemicals, Inc. Port Arthur refinery (affiant)) to Holly J. Huart (Baron & Budd, Dallas); Stephanie Finch (Baron & Budd, Dallas); Vickie Edgerly (District Clerk, Orange County, Texas).

• Kirk E. Martin (author)
• Stephanie Finch (recipient)
• Holly J. W. Huart (recipient)
• ACandS, Inc (named)
• Baron & Budd (named)

Related pages

Pages on our site about what this document covers: Calidria · Texas Asbestos Exposure Sites: Worksites, Industries, and Trust Coverage.

About this copy

This is document UC-1895 of the Union Carbide documents, documents produced and used as evidence in asbestos lawsuits against Union Carbide, 5 pages.