Union Carbide Corporation's Responses to Bobby Lloyd Gilmore's Requests for Disclosure, with Witness and Exhibit Lists, Gillum v. GAF Corp. (2001)

Union Carbide Corporation's responses to a plaintiff's requests for disclosure in a Dallas County, Texas asbestos case. It states the company's general defenses (disputed causation, smoking, state of the art, no duty-to-warn breach) and incorporates Exhibits A-D: Union Carbide's witness list, a list of prior deposition and trial testimony with line and page designations, a general list of medical and state-of-the-art experts, and the CCR Defendants' exhibit list (1994). The copy sent contains pages 1-40 and 109-113 only.

What the document holds

• Pages 1-2: Union Carbide's responses to Bobby Lloyd Gilmore's requests for disclosure, signature block and certificate of service (March 2001)
• Pages 3-5: Responses on defenses, damages, persons with knowledge, experts, insurance, witness statements, medical records
• Pages 6-7: Exhibit A: Union Carbide potential fact/expert witnesses (Bakelite resin and labeling witnesses, outside experts)
• Pages 8-23: Exhibit B: Defendants' list of potential deposition and trial testimony, with line and page designations
• Pages 24-40: Exhibit C: CCR Defendants' general list of medical, state-of-the-art, economic, liability and damage experts (items 1-34 shown)
• Pages 41-108: Not sent: remainder of Exhibit C and the start of Exhibit D
• Pages 109-113: Exhibit D: CCR Defendants' Exhibit List dated November 22, 1994, entries 698-726 (published literature, W-Z authors)

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 Union Carbide Corporation) to Russell Budd (counsel of record for Plaintiff, Baron & Budd, P.C.).

• 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)
• GAF Corporation (named)
• Harvard University (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.

About this copy

This is document UC-2003 of the Union Carbide documents, documents produced and used as evidence in asbestos lawsuits against Union Carbide, 113 pages. The same document is also document UC-2001, UC-2002, UC-2035, UC-2044.