Biles v. Exxon Mobil Corp.

Ronald Biles (plaintiff) sued Exxon Mobil (defendant) for asbestos exposure at an oil refinery. When Exxon asked Biles by interrogatory to identify anyone with knowledge of his exposure, Biles said he had none but reserved the right to supplement his answer later. He later learned, through a related case, that a witness named Bellamy could support his claim, and tried to use Bellamy's testimony to oppose Exxon's summary judgment motion. The trial court excluded Bellamy's evidence because Biles never formally updated his interrogatory answer, and then granted summary judgment for Exxon. Biles appealed.