On August 17, 2018 a
Letter,Correspondence
was filed
involving a dispute between
Cole, Stanley,
and
3M Company,
Clemco Industries Corporation,
Empire Abrasive Equipment Company L P,
Exxon Mobil Corporation,
Specialty Sand Company,
The Quikrete Companies,
for Product Liability - Asbestos/Silica
in the District Court of Harris County.
Preview
CAUSE NO. 2018
BEFORE THE SILICA MDL COURT
STANLEY COLE IN THE DISTRICT COURT OF
Plaintiff,
CLEMCO INDUSTRIES
CORPORATION f/k/a CLEMCO HARRIS COUNTY, TEXAS
SERVICES CORP.; EMPIRE ABRASIVE
EQUIPMENT COMPANY, L.P.;
THE QUIKRETE COMPANIES, LLC;
SPECIALTY SAND COMPANY;
3M COMPANY, AS SUCCESSOR BY
MERGER TO MINNESOTA MINING
& MANUFACTURING COMPANY
AND/OR ITS PREDECESSORS/
SUCCESSORS IN INTEREST;
d EXXON MOBIL CORPORATION
Defendants. JUDICIAL DISTRICT
Transferred from
CAUSE NO. A
STANLEY COLE IN THE DISTRICT COURT OF
Plaintiff,
CLEMCO INDUSTRIES
CORPORATION f/k/a CLEMCO JEFFERSON COUNTY, TEXAS
SERVICES CORP.; EMPIRE ABRASIVE
EQUIPMENT COMPANY, L.P.;
THE QUIKRETE COMPANIES, LLC;
SPECIALTY SAND COMPANY;
3M COMPANY, AS SUCCESSOR BY
MERGER TO MINNESOTA MINI
& MANUFACTURING COMPANY
AND/OR ITS PREDECESSORS/
SUCCESSORS IN INTEREST;
and EXXON MOBIL CORPORATION §
§
Defendants. § 58th JUDICIAL DISTRICT
PLAINTIFF’S NOTICE OF JOINDER TO THE
MOTION FOR ISSUANCE OF LETTER ROGATORY FILED
BY DEFENDANT THE QUIKRETE COMPANIES, INC.
COMES NOW Plaintiff, Stanley Cole, in the above-entitled and numbered cause of action,
and files this Notice of Joinder to the Motion for Issuance of Letter Rogatory Filed by Defendant
The Quikrete Companies, LLC, (“Quikrete” herein) with this Court on September 9, 2019.
By joining in the Motion, Plaintiff adopts and incorporates all arguments asserted by
Quikrete, as if set forth fully herein, and respectfully requests that the Court grant Quikrete’s
Motion for Issuance of Letter Rogatory allowing the oral and videotaped deposition of Lee
Schreve, as President of Prokar, the Plaintiff’s former employer in this suit.
Plaintiff requests that this Court grant Quikrete’s Letter Rogatory as requested.
Respectfully submitted,
MARTIN WALTON LAW FIRM
/s/ Mike Martin
Michael B. Martin
State Bar No. 13094400
1335 Space Park Drive, Suite C
Houston, TX 77058
(713) 773-2035
(832) 559-0878 (facsimile)
mmartin@martinwaltonlaw.com
ATTORNEYS FOR PLAINTIFF
2
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing instrument has been forwarded to all
counsel of record via electronic filing, certified mail-return receipt requested, hand delivery and/or
facsimile on this the 12th day of September, 2019.
/s/ Mike Martin
Michael B. Martin
3
Document Filed Date
September 12, 2019
Case Filing Date
August 17, 2018
Category
Product Liability - Asbestos/Silica
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CAUSE NO. 2018 BEFORE THE SILICA MDL COURT STANLEY COLE IN THE DISTRICT COURT OF Plaintiff, CLEMCO INDUSTRIES CORPORATION f/k/a CLEMCO HARRIS COUNTY, TEXAS SERVICES CORP.; EMPIRE ABRASIVE EQUIPMENT COMPANY, L.P.; THE QUIKRETE COMPANIES, LLC; SPECIALTY SAND COMPANY; 3M COMPANY, AS SUCCESSOR BY MERGER TO MINNESOTA MINING & MANUFACTURING COMPANY AND/OR ITS PREDECESSORS/ SUCCESSORS IN INTEREST; d EXXON MOBIL CORPORATION Defendants. JUDICIAL DISTRICT Transferred from CAUSE NO. A STANLEY COLE IN THE DISTRICT COURT OF Plaintiff, CLEMCO INDUSTRIES CORPORATION f/k/a CLEMCO JEFFERSON COUNTY, TEXAS SERVICES CORP.; EMPIRE ABRASIVE EQUIPMENT COMPANY, L.P.; THE QUIKRETE COMPANIES, LLC; SPECIALTY SAND COMPANY; 3M COMPANY, AS SUCCESSOR BY MERGER TO MINNESOTA MINI & MANUFACTURING COMPANY AND/OR ITS PREDECESSORS/ SUCCESSORS IN INTEREST; and EXXON MOBIL CORPORATION § § Defendants. § 58th JUDICIAL DISTRICT PLAINTIFF’S NOTICE OF JOINDER TO THE MOTION FOR ISSUANCE OF LETTER ROGATORY FILED BY DEFENDANT THE QUIKRETE COMPANIES, INC. COMES NOW Plaintiff, Stanley Cole, in the above-entitled and numbered cause of action, and files this Notice of Joinder to the Motion for Issuance of Letter Rogatory Filed by Defendant The Quikrete Companies, LLC, (“Quikrete” herein) with this Court on September 9, 2019. By joining in the Motion, Plaintiff adopts and incorporates all arguments asserted by Quikrete, as if set forth fully herein, and respectfully requests that the Court grant Quikrete’s Motion for Issuance of Letter Rogatory allowing the oral and videotaped deposition of Lee Schreve, as President of Prokar, the Plaintiff’s former employer in this suit. Plaintiff requests that this Court grant Quikrete’s Letter Rogatory as requested. Respectfully submitted, MARTIN WALTON LAW FIRM /s/ Mike Martin Michael B. Martin State Bar No. 13094400 1335 Space Park Drive, Suite C Houston, TX 77058 (713) 773-2035 (832) 559-0878 (facsimile) mmartin@martinwaltonlaw.com ATTORNEYS FOR PLAINTIFF 2 CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing instrument has been forwarded to all counsel of record via electronic filing, certified mail-return receipt requested, hand delivery and/or facsimile on this the 12th day of September, 2019. /s/ Mike Martin Michael B. Martin 3