NEW YORK - A widow successfully rebutted any prima facie showing by Union Carbide Corp. that its asbestos-containing phenolic resin product could not have led to a man's injuries, a New York appellate court held April 15 (In re New York City Asbestos Litigation Alice Kestenbaum, etc. v. Durez Corp., Union Carbide Corp., No. 12223, N.Y. Sup., App. Div., 1st Dept.).