Robert Ray v. Armstrong World Industries

Please put this in our database
----- Forwarded by Richard B Sanders/HOU/ECT on 03/19/2001 02:47 PM -----

Bonnie White/ENRON@enronXgate
03/19/2001 02:17 PM

To: Rob Cole/HOU/ECT@ECT
cc: Lisa Robichaux/ENRON@enronXgate, Andrew Edison/NA/Enron@Enron, Richard B
Sanders/HOU/ECT@ECT
Subject: Robert Ray v. Armstrong World Industries

This is the asbestos case in which HPL was recently added as a defendant. I
spoke with Scott Wert, the plaintiff's counsel today. HPL was sued as to
only one plaintiff, Larry Don Williams. I called to get info on why HPL was
sued and alleged dates of exposure. Wert advised me that HPL was added as a
plaintiff because Larry Don Williams was allegedly exposed to asbestos while
working for Thomas Construction Company at an HPL facility in Berkclair,
Texas, during 1963 and 1964. He also told me that Williams was allegedly
exposed at a Houston Natural Gas Pipeline facility in Victoria, Texas, during
1970-72. (We have not yet been served as to Houston Natural Gas Pipeline.)
Wert did not have information in his database as to Williams' employer during
that time period.

Rob, as we have previously discussed, I assume that you will check to
determine what policies of insurance might cover claims for those time
periods.

Our answer date on this matter is next Monday, March 26, but plaintiffs'
counsel has said that we can have a couple of extra weeks if we would like.
I will send him a Rule 11 agreement to secure the extra time, so that we can
investigate insurance coverage further.