Ind. Marion Cnty. Mass Tort Local Rule LR49-TR12 Rule 705

Each plaintiff shall file a separate Verified Initial Disclosure Statement (“VIDS”) that shall

contain the following information correlated for each alleged exposure:

A. “Who”:

1. The identity of the Plaintiff/Worker, including his or her full name, all other names by

which he or she has been known, his or her trade or craft, current or last address, and, if applicable,

place and date of death. The SSN and birth date shall be verified and mailed under separate cover to

the joint defense records gathering service. Plaintiff shall state in his VIDS that he has transmitted this

information to the joint defense records gathering service and the joint defense records gathering

service shall release this information upon request to defense counsel who appear in the case.

2. The identity of the Plaintiff/Worker’s employer at the time of each and every exposure to

asbestos, or period of exposure to asbestos, setting forth the name and last known address for each

employer, as well as the beginning and ending dates for each employment (e.g., “for the alleged

exposure of April 14-18, 1956: ABC General Contractors, 1234 Main Street, Connersville, Indiana

46703, Employed from November 1, 1952 to July 15, 1961.”).

3. The identities of those working with the products of asbestos-containing materials as

described in 2, below, at the time of each such alleged exposure. State the identity of these persons,

their trade, and their employer(s) (e.g., “Joe Smith, insulator, employee of XYZ Corporation.”).

B. “What”: The name or type of the asbestos-containing product or item the

Plaintiff/Worker used or to which he or she was allegedly exposed, stating the manufacturer’s

company name (e.g., “Allbrand 85% magnesia pipe covering”), being as particular as possible. If

Plaintiff cannot remember the name of the product he alleges he used or to which he alleges he was

exposed, he shall provide a detailed description of the product.

C. “When”: The dates during which the Plaintiff/Worker was allegedly exposed to asbestos

at each jobsite, setting forth the beginning and ending dates for each exposure period, including date,

month and year.

D. “Where”: The location of each alleged exposure to asbestos, setting forth the address of

the premises as well as the specific area on each premises where the claimed exposure occurred (e.g.,

“boiler room #3 of Generic plant on East Ohio Street in Indianapolis”), and;

E. “How”: The circumstances of the alleged exposure to asbestos, including a description of

what the Plaintiff/Worker was doing on the premises, and what, if anything, was occurring in the

specific area on each premises where and when the claimed exposure occurred, including a description

of work performed by both the Plaintiff/Worker at that time and by any third-party working with

asbestos or asbestos-containing materials.

F. Foreign law. To the extent known at the time of filing, Plaintiff shall reference all foreign

law plaintiff alleges applies in the case, and the specific defendants to which plaintiff alleges the

foreign law applies.

G. Required Medical Information.

1. A description or name of all illnesses or injuries from which the Plaintiff/Worker allegedly

suffers as a result of exposure to asbestos;

2. The date each such illness or injury was diagnosed;

3. The name and address of each person who made such diagnosis;

4. A list of all symptoms experienced by Plaintiff/Worker which were allegedly asbestos-

related, including a description of each symptom;

5. If Plaintiff/Worker uses or has used tobacco products, the quantity and duration of tobacco

usage during his or her lifetime, and the brand name of the products or a description of the items used;

and,

6. A list of all health care providers who have treated Plaintiff/Worker for each illness or

injury allegedly caused by exposure to asbestos or any other airborne contaminants along with their

current or last known addresses.

7. Any medical or employment records of the plaintiff in the possession of Plaintiff or his

counsel.

If Plaintiff is not able to provide the information provided above, Plaintiff shall specify the

unsuccessful efforts to obtain the information and a date when the information will be provided to

defendants.