3more than 8,000 cases.
ACandS, Inc. v. Godwin
, 340 Md. 334, 402 (1995); the “ConsolidationII”
consolidation and cross-claim consolidation that involved nearly 10,000 cases.
See ACandS, Inc. v. Abate
, 121 Md. App. 590 (1998),
, 350 Md. 487 (1998),
,525 U.S. 1171, 119 S.Ct. 1096 (1999), and hundreds of cases resolved via consolidated trial and“damages mini-trial” groupings that involved up to 25 cases each.7.The proposed trial plan is described more fully in Plaintiffs’ SupportingMemorandum.8.Consistent with the practice of “Consolidation II”, in order to illustrate diseaseprocesses, exposure, causation and damages, Plaintiffs’ counsel proposes that fifteen illustrative,trial Plaintiff cases be selected by Plaintiffs’ counsel from among the group of more than 13,000cases that will be tried to verdict and final judgments on questions of asbestos exposure, defendantliability, damages and punitive damages.9.Exhaustive discovery has been undertaken and completed in numerous asbestos casesinvolving asbestos products, asbestos state-of-the-art, the asbestos-exposed trades and jobsiteasbestos exposures. Plaintiffs propose adoption of discovery in the consolidated cases that willrelieve the parties of the substantial burden of repetitive continuing discovery of common issues inasbestos cases. Plaintiffs’ discovery proposal is described more fully in Plaintiffs’ SupportingMemorandum.10.Consistent with the practice of “Consolidation II”, Plaintiff-specific discovery shouldbe limited to non-duplicative discovery of the fifteen illustrative, trial Plaintiff cases. All otherPlaintiff-specific discovery should be reserved for “mini-trial” phases of the trial.11.“Consolidation III” will include cases that, if litigated and tried separately or in