Document 0gb8nZdB30gykdpBpw59bK9Bm

> manta and welge By: Joseph M. Cincotta, Esquire Identification No. 31844 37th Floor One Commerce Square 2005 Market Street Philadelphia, PA 19103 (215) 851-6600 MARY ANN MONAGHAN, Executrix of the Estate of Robert Monaghan, Deceased, and MARY ANN MONAGHAN, in her own right Plaintiff, v. ALLIED-SIGNAL, INC., successor-ininterest to ALLIED CORP. and ALLIED CHEMICAL CORP, et al. Defendants Attorneys for Defendant, PPG Industries, Inc. IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA GA No. 93-02928 DEFENDANT, PPG INDUSTRIES, INC'S OBJECTIONS AND ANSWERS TO PLAINTIFFS FIRST SET OF INTERROGATORIES ADDRESSED TO DEFENDANTS Pursuant to the Pennsylvania Rules of Civil Procedure, you are required to file full and complete Answers, under oath, to these Interrogatories within thirty (30) days from the service hereof. DEFINITIONS: As used in this set of Interrogatories, the following terms mean: A The words "you", or "your company" mean the corporate defendant separately answering these Interrogatories, its parent(s), its merged, consolidated, or acquired predecessor, divisions, subsidiaries, and/or affiliates, including present and former officers, directors, agents, employees, and all other persons acting or purporting to act on behalf of AS I 000021583 MR j 51994 I. "Alleged period of exposure" refers to the period of time from September 1952 to March 1981 during which Plaintiffs have alleged that Plaintiff/decedent was exposed to said product. J. These Interrogatories are deemed to be continuing and the Defendant is to supply such information and/or documents as they become aware of and/or as such becomes available. illRUCTIONS: K. If the Interrogatory asks for information which could have at some time been answered by consulting documents which are no longer in existence, then in answer to such Interrogatory: (a) Identify what information was maintained; (b) Identify all the type(s) of documents which contained such information; (c) State the time period during which such documents were maintained; (d) State the circumstances under which such documents ceased to exist; (e) State the date when such documents ceased to exist; (f) Identify all persons having knowledge of the circumstances under which such documents ceased to exist; and (g) Identify all persons who have knowledge or had knowledge of the documents and the contents thereof. L. If Defendant exercised its option to produce business records in lieu of responding to any Interrogatory, the following procedure is to be followed: 1. In response to such Interrogatory, Defendant shall state: (a) The identity of the records containing the answer, (b) Whether other copies of each record are presently in existence, and if _ so, identify (1) the location of other copies by stating the name(s) of the file(s) in which they are kept and (2) the person(s) who received copies thereof; (c) Whether other copies of each record were at any time in existence and 3 AS I 000021584 if so, for each record, identity (1) each file in which a copy was manifested, (2) the dates during which such record was in existence, (3) the circumstances under which such record ceased to exist; (4) aU persons having knowledge of the circumstances under which such record ceased to exist; and (5) all persons receiving copies of such records; and (d) The identity of all persons reviewing such documents. 2. In producing such records, Defendant will produce such records separately and will designate the Interrogatory or Interrogatories to which such record responds, as well as the identification of the file(s) from which the documents were segregated. M. If you object to any Interrogatory based upon an assertion that the Interrogatory is too broad or over inclusive, then state the objection and answer the Interrogatory subject to the limitations you prescribe. N. If you object to any Interrogatory based upon privilege, either the attorney client privilege or attorney work product doctrine, then state the objection and identify any documents, by title, which contain the information to which is being objected. GENERAL OBJECTIONS 1. PPG objects to the "Definitions" and "Instructions" set forth by plaintiff as overly broad, unduly burdensome, oppressive and not reasonably calculated to lead to the discovery of admissible evidence. PPG further objects to plaintiff's interrogatories to the extent that they seek to alter the obligations placed on PPG by the Pennsylvania Rules of Civil Procedure, applicable law or the Rules of Court. PPG will respond pursuant to the Pennsylvania Rules of Civil Procedure, giving each term its commonly understood and used meaning. 2. PPG objects to providing information relating to PPG's "...merged, consolidated, or acquired predecessor, divisions, subsidiaries, and/or affiliates" as being overly broad, unduly burdensome, oppressive, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Accordingly, PPG will respond only on its own behalf. 3. PPG objects to plaintiffs interrogatories to the extent that they seek information which is protected by the attorney-client privilege, the attorney work product doctrine (including the mental impressions, conclusions, opinions or legal theories of PPG's attorneys or other representatives of PPG concerning the litigation), or other trial preparation material protected from disclosure under the Pennsylvania Rules of Civil 4 AS! 000021585 Procedure. 4. PPG objects to any interrogatories to the extent that they seek the disclosure of confidential, proprietary, trade secret, financial or commercially sensitive business information. 5. PPG objects to plaintiffs interrogatories to the extent that they seek information already known to plaintiff or to the extent that they are related to or require the production or identification of documents, writings, records or publications in the public domain, information which is equally available to plaintiff or which is available to plaintiff from sources other than PPG. Such interrogatories are overly broad, unduly burdensome and oppressive. Specifically, without limiting the foregoing, PPG objects to plaintiffs interrogatories to the extent that such interrogatories call for information contained in: a. publicly available scientific or medical journals, books, treatises, textbooks and other compilations; b. publicly available records or files maintained by governmental offices or agencies; and c. documents or records within plaintiffs possession or control. 6. PPG objects to any interrogatories to the extent that they are overly broad, unduly burdensome, oppressive and/or seek information which is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 7. PPG objects to any interrogatories to the extent that they seek information regarding products other than vinyl chloride monomer and/or medical conditions other than those alleged by plaintiff in her Complaint, i.e., other than glioblastoma multiforme. 8. PPG objects to any interrogatories to the extent that they seek information or documents outside of plaintiffs decedent's alleged period of employment and/or outside of plaintiffs decedent's alleged period of exposure to PPG's vinyl chloride monomer. To the extent that plaintiffs interrogatories seek information relative to other time periods, they are overly broad, unduly burdensome, oppressive, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 9. PPG objects to these interrogatories as premature and seeking information which is irrelevant to the subject matter of this lawsuit and not reasonably calculated to lead^ to the discovery of admissible evidence, until it has been shown that plaintiffs decedent was exposed to PPG's vinyl chloride monomer. 10. PPG objects to these interrogatories to the extent that they seek to discover "all" information, documents, identification of individuals or entities or other materials or 5 AS I 000021586 information as overly broad, unduly burdensome, oppressive, unreasonably cumulative and duplicative, not susceptible to reasonable limitation and unduly vague and ambiguous. 11. PPG objects to the overall burdensome nature of plaintiffs interrogatories. Due to the passage of time and the unavailability of records, it would be extremely burdensome and costly for defendant to compile information which spans a time period of nearly thirty (30) years. INTERROGATORIES 1. Prior to answering these Interrogatories, have you made due and diligent search of all books, records, and papers of the Defendant and due and diligent inquiry of all agents employees of the Defendant with a view to eliciting all information available in this action? PPG incorporates by reference its General Objections, particularly Nos. 1, 2, 9, 10 and 11. 2. Please identify each person who has supplied information used in answering these Interrogatories and specify the Interrogatories for which he/she is responsible. PPG incorporates by reference its General Objections, particularly No. 1. 3. Identify each person who was questioned or consulted in order to answer these Interrogatories. PPG incorporates by reference its General Objections, particularly No. 1. 4. Identify each document that was examined, reviewed, and/or used in answering each Interrogatory and specify the Interrogatory. 6 AS I 000021587 PPG incorporates by reference its General Objections, particularly No. 1. 5. State your correct name and address as of the following dates: a. September 1952 b. March 1981 Pittsburgh Plate Glass Company Pittsburgh, PA PPG Industries, Inc. Pittsburgh, PA c. The present date; - PPG Industries, Inc. Pittsburgh, PA d. If name or address changed at anytime between September 1952 and the present, state the date of each such change. 1968 6. If you are a corporation, then state: a. Date and place of your incorporation; 1883 - Pennsylvania b. The address of your principal place of business; One PPG Place Pittsburgh, PA c. The correct name, designation of business entity, and details of your relationship with any parent, subsidiary, or affiliate corporation, conglomerate, cartel, partnership, etc. PPG incorporates by reference its General Objections, particularly Nos. 2 and 6. AS I 000021588 If you are either a successor or a predecessor to some other legal entity, then state: 7. a.-b. Not applicable. a. The date on which the transaction by which you became a successor or predecessor was completed; b. The correct name, designation of legal entity, and details of your relationship with any successor or predecessor corporation, partnership, person, cartel, conglomerate, etc. a. List all shipments of the product, (see definition G) which you and/or someone on your behalf supplied, distributed, sold, merchandised or delivered either directly or indirectly to Plaintiff/decedent's employer during Plaintiff/decedent's alleged period of exposure (see definition I). 8. a.-b. PPG incorporates by reference its General Objections, particularly Nos. 2, 4, 5, 6, 7 and 9 and its response to Interrogatory No. 9. Subject to and without waiving the foregoing objections, PPG states that it did not manufacture VCM prior to 1967. By way of further response, PPG does not have records of sales of VCM for years prior to 1978. By way of further response, PPG's records indicate no sales of VCM to Firestone Tire & Rubber Company, Pottstown, PA from 1978 to 1981. b. For each shipment listed in Interrogatory No. 8(a) provide the date and amount, in volume and monetary value, of each transaction; --------------- identify all documents regarding these transactions. 8 AS I 000021589 9. Does this defendant have knowledge from any source whatsoever indicating that, between September 22, 1952 to March 2, 1981, this defendant sold, supplied or delivered any products to Firestone Tire and Rubber Company, Pottstown, Pennsylvania or to any agent or employee of Firestone Tire and Rubber Company, Pottstown, Pennsylvania. PPG incorporates by reference its General Objections, particularly Nos. 3, 5, 6, 7, 8, and 9. PPG further objects to this interrogatoiy in that it is unduly vague, ambiguous, overly broad and unduly burdensome in its request to state whether PPG has "knowledge from any source whatsoever," regarding the sale, supply or delivery of any products to plaintiffs decedent's employer to the extent that it seeks information other than that which is reasonably available through PPG's records and/or upon consultation with representatives of PPG. Subject to and without waiving the foregoing objections, see response to Interrogatory No. 8. 10. In regards to Interrogatory No. 9, if answered in the affirmative, please provide the following: I0a.-i. See responses to Interrogatories Nos. 8 and 9. a. The brand name and manufacturer of the product this defendant delivered, sold or otherwise supplied; b. A description of the product; c. The dates this defendant delivered, sold or otherwise supplied the product; d. The vinyl chloride content of each product; e. To the extent that this defendant has documentation, please estimate the quantity of each type of product delivered, sold or otherwise supplied by this defendant during each time period listed in Interrogatory No. 9(c); f. The name and address of each living individual who delivered, sold or otherwise distributed each product listed in Interrogatories No. 9 or who has direct knowledge of such sale, delivery or distribution; 9 AS! 000021590 g. A detailed description of the manufacturers' intended manner of application of each product; h. The name of each individual or corporation to which each product was delivered, sold, supplied or otherwise conveyed; i. Please list all documents reflecting such sales, supply and/or delivery to Firestone Tire and Rubber Company, Pottstown, Pennsylvania. 11. What was and is the intended use of the product, (see definition G), shipped to Plaintiff/decedent's employer? gee response to Interrogatory No. 8. Subject to and without waiving the foregoing objections, PPG states: Not applicable. 12. For each shipment identified in Interrogatory No. 10(a) state: 12a.-f. See response to Interrogatory No. 10. Subject to and without waiving the foregoing objections, PPG states: Not applicable. a. The generic name; b. The brand name; c. The chemical composition of each shipment, including the amount of each ingredient by weight and/or by volume; 10 ASI 000021591 d. The year of manufacture; e. The address of each plant or facility which produced each of the aforesaid shipments; f. If you did not manufacture the product, identify who did; 13. For each and every shipment listed in answer to Interrogatory No. 10: 13a.-c. ge response to Interrogatory No. 10. Subject to and without waiving the foregoing objections, PPG states: Not applicable. a. Describe how the product was packaged when the product left your possession; include type of container, color, and all external markings; b. If there was/is any writing on the outside of the container, please attach either a copy of the writing or label or state the complete wording of any writing (include type, size and color); c. If any of the foregoing changed during Plaintiff/decedent's alleged period of exposure, please indicate the dates of usage for each container type and the writing on each container. oooo^ 5^ 11 14. With respect to each and every shipment listed in answer to Interrogatory No. 10, did you conduct any test, study, inspection, or quality control examination of the product prior to it leaving your control? 14 and 14a.-d. ee response to Interrogatory No. 10. PPG further objects to these interrogatories on the grounds that they are unduly vague, ambiguous, overly broad and unduly burdensome in that they are not reasonably limited to tests, studies, inspections or quality control examinations relating to any conditions, things or circumstances which are alleged to have caused or contributed to plaintiffs decedent's illness and therefore would require PPG to conduct an unreasonable investigation. Subject to and without waiving the foregoing objections, PPG states: Not applicable. If your answer is in the affirmative, then: a. Identify all individuals who participated in any tests, studies or inspections; b. State the dates(s) of all tests, studies or inspections and all locations where tests, studies or inspections were conducted; c. Identify each and every document or writing, by whatever name called, that related to or reflected the conduct of or the conclusion of any such investigation, study or test, specifically including, but not limited to photographs or statements; d. State the results of each test, study or inspection. 15.--Have you at anytime manufactured, blended, marketed, supplied or distributed the product as defined at definition G? 15 and 15a. and b. PPG incorporates by reference its General Objections, 12 AS I 000021593 particularly Nos. 2, 4, 6, 7, 8 and 9. PPG further objects to these Interrogatories to the extent that plaintiff seeks information relative to sales to other facilities, as this information is irrelevant to the issues in this action. By way of further objection, in the absence of any evidence indicating that PPG sold VCM to Firestone's Pottstown, Pennsylvania, facility at any time, PPG objects to providing any information regarding the manufacture and sale of VCM. In the absence of any such evidence, there is no method under which PPG can limit its search to any applicable time frame, which makes these Interrogatories overly broad and unduly burdensome. Subject to and without waiving the foregoing objections, PPG states that it has been manufacturing VCM since 1967. By way of further response, se& response to Interrogatory No. 8. If yes, then state: a. The inclusive dates which you have manufactured, blended, packaged, marketed, supplied or distributed the product; b. For each year, the annual volume of sales. Do you own, or have you been granted the license to use, any patent or patent right with respect to the product, the component ingredients of said product, and/or the manufacturing process used to make said product? 16 and 16a.-c. PPG incorporates by reference its General Objections, particularly Nos. 2, 4, 6, 7, 8 and 9. Subject to and without waiving the foregoing objections, PPG states, no. If yes, then identify: a. The title of each patent; b. The number of each patent; c. The holder of each patent. 13 AS I 000021594 17. With respect to Plaintiff/decedent's alleged period of exposure, for each and every chemical ingredient which you purchased in order to make the product, identify: 17a.-d. PPG incorporates by reference its General Objections, particularly Nos. 2, 4, 6, 7, 8 and 9. By way of further objection, in the absence of any evidence indicating that PPG sold VCM to Firestone's Pottstown, Pennsylvania, facility at any time, PPG objects to providing any information regarding the manufacture and sale of VCM. In the absence of any such evidence, there is no method under which PPG can limit its search to any applicable time frame, which makes these Interrogatories overly broad and unduly burdensome. a. The name of the chemical, both generic and brand name; b. The name of the chemical supplier; c. The years during which the supplier provided the product; d. Each and every document provided to you regarding any potential health hazard or risk of injury caused by potential exposure to the chemical ingredient, including but not limited to material safety data sheets. 18. Have any tests been conducted by you or on your behalf on the product uforder to determine potential health hazards involved in the use, handling or exposure to the product or the materials contained therein? 18 and 18a.-e. PPG incorporates by reference its General Objections, 14 000021^95 AS I particularly Nos. 2, 4, 6, 7, 8 and 9 and its response to Interrogatory No. 14. By way of further objection, in the absence of any evidence indicating that PPG sold VCM to Firestone's Pottstown, Pennsylvania, facility, any information relating to PPG's participation in sponsored testing is irrelevant. Furthermore, requiring PPG to perform a search of documents and other investigation without any reference to any applicable or limited time frame is burdensome and overly broad. If yes, state for each product: a. The identity of each individual or firm who conducted such tests; b. The date, purpose and result of each such test; c. Identify and produce all documents relating to such tests. d. Whether such tests are conducted on all products manufactured, processed or developed by defendant; and e. The criteria used by defendant to determine which products are to be tested. Have you made any changes in your product(s), the component ingredients selected to be used in said product, the packaging of said product and/or any warnings or instructions accompanying said product as a result of such test? 19 and 19a.-e. PPG incorporates by reference its General Objections, particularly Nos. 2, 4, 6, 7, 8 and 9. By way of further objection, in_the_ absence of any evidence indicating that PPG sold VCM to Firestone's Pottstown, Pennsylvania, facility at any time, PPG objects to providing any information regarding the manufacture and sale of VCM. In the absence of any such evidence, there is no method under which PPG can limit its search to any applicable time frame, which makes these Interrogatories overly broad 15 AS I 000021596 and unduly burdensome. If so, state: a. The product change(s); b. The nature of the change(s) made; c. The purpose(s) of the change(s); d. The date of such change(s); e. The identity of each person or firm responsible for making the change(s). 20. Is it now, or has it ever been, the policy of your company to take every reasonable step to reduce or eliminate the risk of injury or disease which might be associated with the use, handling, and/or exposure to your product? PPG incorporates by reference its General Objections, particularly Nos. 2, 6, 7, 8 and 9. This Interrogatory is further objected to in that it is unduly vague and ambiguous as plaintiff nowhere defines what she means by the phrase "every reasonable step." This Interrogatory is further objected to in that it calls for a legal conclusion. Subject to and without waiving the foregoing objections, PPG states, yes. 21. list each and every potential injury or illness which may be caused by or contributed to as the result of use, handling, storage and/or exposure to your product. PPG incorporates by reference its General Objections,^-- particularly Nos. 2, 5, 6, 7, 8 and 9 and its responses to Interrogatories Nos. 8, 18 and 19. PPG further objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome and irrelevant to the issues in this action in that it 16 AS I 000021597 is not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. This Interrogatory is further objected to in that it seeks a medical opinion and expert discovery exceeding the scope of expert discovery permitted under the Pennsylvania Rules of Civil Procedure. This Interrogatory is further objected to in that it improperly calls for a legal conclusion as to what uses or misuses are foreseeable. Have you or your predecessors or successors ever recalled said product? 22 and 22a.-d. PPG incorporates by reference its General Objections, particularly Nos. 2, 6, 7, 8 and 9. These Interrogatories are further objected to on the grounds that they are overly broad in that they are not limited to recalls for any reasons relating to hazards or risks of contraction of the type of illness allegedly contracted by plaintiffs decedent arising from exposure of the nature and extent allegedly experienced by plaintiff's decedent. Subject to and without waiving the foregoing objections, PPG states that to the best of its knowledge and belief no. If yes, state: a. The date of such recall; b. The reason for such recall; c. The specific product recalled; d. The method of recall. During the period of time of Plaintiffrdecedenfs alleged period of exposure, has any written material of any kind been prepared or used by you indicating how the product should be used, stored, applied or handled by purchasers; and/or has any written 17 ASI 000021598 material or instruction of any kind, been prepared or used by you indicating the type of personal protective equipment to be worn while working with and/or in the area of use of the product? 23 and 23a.-f. PPG incorporates by reference its General Objections, particularly Nos. 2, 3, 6, 7, 8 and 9 and its response to Interrogatory No. 8. Subject to and without waiving the foregoing objections, PPG states that it did not begin to manufacture VCM until 1967. While PPG has written materials related to VCM, PPG objects to producing those materials in the complete absence of any evidence indicating that PPG sold VCM to Firestone at its Pottstown, Pennsylvania, facility. By way of further response, the absence of any such evidence would require PPG to conduct a search of documents over a fourteen-year time period. In light of the absence of evidence, PPG objects to Interrogatory No. 23 as overbroad and burdensome. If so, please identify: a. Each person or firm who prepared same; b. Each person or firm who presently has possession of same; c. The date(s) and manner in which said material was distributed to purchasers or users of your product(s); d. All documents provided to Plaintiff/decedent's employer including the date and manner in which they were provided. e. The person or persons who were in charge of safety, product review, or industrial hygiene for the Defendant. f. The person or persons who were in charge of preparing material safety data sheets, product labels, injury prevention systems, and written material regarding potential health hazards for the Defendant. 18 ASI 000021599 24. Before marketing and/or selling your product, did you or anyone on your behalf conduct a search or review of the medical or scientific literature concerning potential health hazards associated with such product or the polymerization processes, in which your product in used. If your answer is in the affirmative, please state: 24 and 24a.-d. Sg response to Interrogatory No. 23. a. the particular activities performed; b. when such activities were performed; c. by whom such activities were performed; d. to whom the results of such activities were reported or communicated. 25. When did you first become aware of the relationship between exposure to your product and the development of the following medical conditions in any individual so exposed: 25 and 25a.-d. See response to Interrogatory No. 23. These Interrogatories are further objected to on the grounds that they are misleading in that they assume that there is a "relationship" between "exposure" to VCM and the stated medical conditions, none of which specifically describe the particular medical condition allegedly sustained by plaintiffs decedent. These interrogatories are further objected to in that they are not reasonably limited to the exposure situation applicable to this case. a. brain cancer; b. liver abnormalities; c. sclerosis of the skin; and/or d. central nervous system abnormalities. 19 000021600 AS I State whether this defendant at any time caused to be performed any air samples, tests or other activities to determine the amount of product vapor released into the air, if any, during the handling, fabrication or any other activity involving the use, as distinguished from the manufacture of your products. If your answer is in the affirmative, please state: 26 and 26a.-d. ee response to Interrogatory No. 23. These interrogatories are further objected to in that they are overly broad, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence in that they are not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. a. the date of any such air samples, tests, or activities; b. by whom such activities were performed; c. where such activities were performed; d. the results of any such activities. State when, if at all, this defendant became aware of publications concerning any health hazards associated with this defendant's product and for each such publication identify who received such knowledge and all documents relating to such acquisition of information, including the publications themselves. See response to Interrogatory No. 23. This interrogatory is further objected to in that it is not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. 20 AS* 000021601 State what action, if any, you have taken since 1930 to minimize or eliminate any risk of occupational disease or cancer to those engaged in the manufacture or production of defendants' product. Ses response to Interrogatory No. 23. PPG further objects to this Interrogatory on the grounds that it is overly broad and unduly burdensome in that information as to PPG's practices in its plants is clearly irrelevant to the issues in this action and not reasonably calculated to lead to the discovery of admissible evidence. This Interrogatory is further objected to in that it is not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. State what action, if any, you have ever taken since 1930 to minimize or eliminate any risk of occupational disease or cancer to those engaged in the use, as distinguished from the manufacture, of your product or who were otherwise exposed to your product. See response to Interrogatory No. 23. This Interrogatory is further objected to in that it is not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. Did this defendant at anytime between 1930 and the present, consult, employ, or correspond with an industrial hygienist concerning exposure of individuals to defendant's product. If your answer is in the affirmative, state the names, addresses and title or position of each such person who at anytime between 1930 and the present was employed in any of the above roles for this defendant. See response to Interrogatory No. 23. This Interrogatory is further objected to in that it is not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. 21 ASl 000021602 31. Did this defendant at anytime between 1930 and the present consult, employ, or correspond with a physician or licensed medical practitioner concerning exposure of individuals to defendant's product If your answer is in the affirmative, state the names, addresses and title or position of each such person who at anytime between 1930 and the present was employed in any of the above roles for this defendant. See response to Interrogatory No. 23. This Interrogatory is further objected to in that it is not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. 32. Did this defendant at anytime between 1930 and the present, compile a library of medical literature and research or conduct a search of medical literature and research concerning exposure of individuals to defendant's product. If your answer is in the affirmative, state the names, addresses and title or position of each such person who at any time between 1930 and the present was responsible for such library, medical literature and research. See response to Interrogatory No. 23. This interrogatory is further objected to in that it is not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. 33. During the Plaintiff/decedent's alleged period of exposure, identify each and every document, if any, provided to Plaintiff/decedent's employer which advised or warned of any potential health hazards of the use, handling and storage of Defendant's product. For each such document identified, describe the manner in which that document was provided to Plaintiff/decedent's employer. See response to Interrogatory No. 23. 22 oooon603 asi Have you at any time published and/or distributed to anyone any document containing any warnings, advice and/or discussion concerning the possibility of illness, disease, or injury resulting from the use of or exposure to said products? 34 and 34a.-j. See response to Interrogatory No. 23. These Interrogatories are further objected to in that they are not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. If so, please state: a. The wording of each such warning; b. A description of each such document, including size, color and type of print; c. The method used to distribute the warnings to persons who are likely to use, handle or be exposed to your products(s); d. The date(s) such warning was issued; e. The identity of each person who presently has possession of the above-described documents; f. The identity of and list of all documents mentioned in parts (a) through (e) of this question; g. In particular, was any warning ever given, either in writing or in any other manner, concerning the possibility of pulmonary, neurologic, carcinogenic or immunological damage caused by physical exposure to the product? h. If any recommendations were made to limit the possibility of these 23 AS I 000021604 health hazards either through production design or personal protective equipment, please list those recommendations. i. List and identify all warnings provided to Plaintiff/decedent or Plaintiff/decedent's employer. j. List and describe any testing, performed by you or on your behalf, to determine if any warning sign, label, or placard was effective in advising foreseeable uses as to any potential risk or hazard. 35. Have you either specifically forbidden, warned against or suggested any kind of restriction or limitation of the use of said product? 35 and 35a.-c. Sgg response to Interrogatory No. 23. If so, please state: a. The name, address and relationship of the person or persons who determined said restriction or limitation; b. The name, address and relationship to you of the person who wrote the document restricting or limiting the use of said product; c. The identity and description of any document or publication in which any and each such restriction or limitation on the use of said product was published. 36. Have you ever given any warnings to your employees as to the potential risk of illness, injury and/or disease by reason of their use, handling, or exposure to these 24 AS I 000021605 products or their component ingredients? If so, state: 36 and 36a.-d. ge response to Interrogatory No. 23. These Interrogatories are further objected to in that they are not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. PPG further objects to these Interrogatories on the grounds that they are overly broad, unduly burdensome, irrelevant and are not reasonably calculated to lead to the discovery of admissible evidence in that information as to PPG's practices in its plants is clearly irrelevant to the facts and issues in this action and is not reasonably calculated to lead to the discovery of admissible evidence. a. The date of each such warning; b. How such warnings were given; c. If such warnings were written, state: 1. The date(s) of such waming(s); 2. The present location of such waming(s); 3. The names and addresses of individuals who prepared such waming(s); 4. Where and/or how such waming(s) were posted; 5. The reasons for such waming(s); 25 AS I 000021606 d. Describe in detail what personal protective equipment you provide and/or recommend to your employees who work with the product or work in an area where there is a potential of exposure to said product. To your knowledge, has any governmental or private agency, or other entity, issued guidelines suggesting (a) personal protective equipment to be worn while working with or in the area of the product and/or (b) safe industrial hygiene practices to be followed while working with or in the area of the product? 37 and 37a.-c. PPG incorporates by reference its General Objections, particularly Nos. 2, 3, 5, 6, 7, 8 and 9. Without waiving said objections, PPG states: yes. If so: a. Identify the agency or entity issuing the guideline; b. State the content of the guideline(s) verbatim; c. State the date issued and the date you first knew the purpose of the guideline(s). Please describe the substance and content of all claims or representations made by you, to Plaintiff/decedent's and/or to Plaintiff/decedent's employer either orally or in writing, as to the quality, safety, or fitness of the products preceding March 2, 1981. PPG incorporates by reference its General Objections,"' particularly Nos. 2, 6, 7, 8 and 9. This Interrogatory is further objected to in that it is unduly vague and ambiguous in that plaintiff nowhere defines the meaning of the phrase "claims or representations." Subject to and without waiving the foregoing 26 AS I 000021607 objections, sg response to Interrogatory No. 8. 39. State whether defendant has ever advertised the product in any publication, periodical, trade brochure or other printed material. See response to Interrogatory No. 23. PPG further objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, unduly vague and ambiguous in that plaintiff nowhere defines the term "advertised." 40. If the answer to Interrogatory No. 39 is affirmative, state the name and address of each such publication, periodical, brochure or printed material and the exact wording of each such advertisement so published. $ee response to Interrogatory No. 39. 41. Have you, at any time, been a member of any "trade association" or association composed of other manufacturers, suppliers, distributors, producers, processors, compounders, converters, sellers, merchandisers, and/or anyone otherwise placing in the stream of commerce the product as defined in definition G? 41 and 41a.-g. PPG incorporates by reference its General Objections, particularly Nos. 2, 5, 6, 7, 8 and 9. By way of further objection, in the absence of any evidence indicating that PPG sold VCM to Firestone at its Pottstown, Pennsylvania, facility, PPG objects to Interrogatory No. 41 as irrelevant. If so, state: a. The identity of each such association or organization; 27 ASI 000021608 b. The dates during which you were a member; c. The name of any publication published or written by such association or oiganization; d. The dates and addresses of all other members; e. The dates of meetings you attended and the identity of those in attendance; f. Any speaker at such meetings; g. Were transcripts or summaries or minutes or notes or any other type of recording made of such meetings. If so, tell specifically what recording was made and give the name, title and address of the person or persons who have custody of the transcripts and/or summaries and/or minutes and/or notes mentioned above. Have you been contacted by or learned of any person(s) who allege that she/he has suffered any adverse health effect as the result of the use, handling, storage and/or exposure to your product? 42 and 42a.-e. PPG incorporates by reference its General Objections, particularly Nos. 2, 3, 5, 6, 7, 8 and 9. These interrogatories are further objected to in that they are not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. PPG further objects to these interrogatories to the extent that they request information protected by the physician-patient privilege which PPG legally 28 000021609 xsi cannot waive. In addition, in the absence of any evidence indicating that PPG sold VCM to Firestone at its Pottstown, Pennsylvania, facility, PPG objects to Interrogatory No. 42 as irrelevant and overbroad. Moreover, the search for any such evidence would be unduly burdensome. If yes, then state: a. The name of such person(s); b. The date you first learned of their allegation or inquiry, c. The name of your product to which such person(s) was exposed; d. The types of symptoms allegedly suffered by such person(s); e. Any investigation performed by you or on your behalf regarding said allegation or inquiry. Has a suit of law or equity ever been instituted against you where it has been alleged that physical injury, illness, disease or death has resulted from use of and/or exposure to the product(s)? 43 and 43a.-h. PPG incorporates by reference its General Objections, particularly Nos. 2, 3, 5, 6, 7, 8 and 9.__..These interrogatories are further objected to in that they are not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. PPG further objects to these interrogatories to the extent that they request information protected by the physician-patient 29 AS! 000021610 privilege which PPG legally cannot waive. In addition, in the absence of any evidence indicating that PPG sold VCM to Firestone at its Pottstown, Pennsylvania, facility, PPG objects to Interrogatory No. 43 as irrelevant and overbroad. Moreover, the search for any such evidence would be unduly burdensome. If yes, then state with complete detail: a. The date of this alleged injury, b. The name and address of the party so injured; c. The caption of said lawsuit, including the name of all parties and the court term and number; d. The name, location, and address of the court where the claim or suit was filed; e. The name and address of Plaintiffs legal counsel; f. The type of injury allegedly suffered; g. The name of your product which is the subject of said suit; h. If the matter has been resolved through judgment, settlement or release, please indicate outcome. ~ 30 AS I 000021611 44. Has the defendant ever had a safety or industrial hygiene department or employees whose jobs or functions include availability for consultation in, and/or the making of recommendations regarding the design, manufacture, marketing, labeling or packaging of the product and/or product literature? 44 and 44a,-b. PPG incorporates by reference its General Objections, particularly Nos. 6, 7, 8 and 9. Subject to and without waiving the foregoing objections, see response to Interrogatory No. 30. If so, then state: a. The name, address, job titles, and division and/or department of any such person or persons; b. Which of these persons were consulted during the design, manufacture, labeling, packaging, or information provided on packaging regarding the products? 45. Do you contend that the Plaintiff/decedent either was using the product, or was exposed to a use of said product, in a manner which was not intended, not recommended or was outside the scope of the uses for which you anticipated said product? 45 and 45a.-b. PPG incorporates by reference its General Objections, particularly Nos. 2, 3, 7 and 9. PPG further objects to these Interrogatories on the ground that they seek disclosure of attorney work product and/or the mental impressions, conclusions, strategy, opinions or legal theories of PPG's counsel or other representatives of PPG concerning this lawsuit, which is privileged and protected from discovery. Subject to and without waiving the foregoing objections, PPG's discovery and investigation are ongoing and PPG does not have information sufficient to prepare a response to these Interrogatories at this time. See also response to Interrogatory No. 8. If so, then: a. Describe in detail how or in what specific manner said product was being misused; 31 AS I 0021612 b. Describe and identify each and every writing or oral statement regarding the proper intended use of said product which you say were violated by the use of said product on the occasion of said incident. Do you contend that the condition of the product sold was changed or altered in any way after said product left your possession, control, or custody and before Plaintiff/decedent's exposure occurred so as to affect your liability? 46 and 46a.-f. See response to Interrogatory No. 45. If so, then: a. Summarize the substance of your contention in this regard; b. Describe in detail what you contend was changed, altered or modified; c. State when said change, alteration, or modification occurred and where said product was when it occurred; d. State who caused or permitted any change, alteration or modification to occur; 32 AS! 000021613 State the facts and evidence upon which this contention is based; f. State the name and address of the person who has in their custody any note, record, or other document or thing which would reflect or relate to any such change, alteration, or modification. 47. Specify with particularity every precaution which you allege the Plaintiff/decedent or Plaintiff/decedent's employer could have and/or should have taken in order to reduce or eliminate the risk of injury or disease which Plaintiff/decedent allegedly suffered from. See response to Interrogatory No. 45. 48. Do you contend that the Plaintiff /decedent assumed the risk of Plaintiff/decedent's injury? 48 and 48a.-b. See response to Interrogatory No. 45. If so, state: a. Bach and every fact which you allege supports that contention; b. The name and address of each and every witness whom you reserve the right to call as a witness to support that contention at the time of trial. 33 000021614 AS I 49. Do you contend that the Plaintiff/decedent was negligent and/or contributorily negligent? 49 and 49a.-b. See response to Interrogatory No. 45. If yes, then state: a. Each and every aspect of Plaintiff/decedent's conduct that was either negligent or contributorily negligent; b. The name of each person who has personal knowledge regarding the conduct of the Plaintiff which the Defendant contends was negligent or contributorily negligent. 50. Do you contend that the Plaintiff/decedent's injuries were caused by person(s) over whom the Defendant had no control or relationship? 50 and 50a.-b. See response to Interrogatory No. 45. If yes, then state: a. The identity of such person(s); b. How and in what manner such other person or persons caused or contributed to Plaintiff/decedent's injuries. 34 AS I 000021615 51. Was the use, storage, or application of the product demonstrated by you to Plaintiff/decedent's employer? 51 and 51a.-c. PPG incorporates by reference its General Objections, particularly Nos. 2, 6, 7, 8 and 9. Subject to and without waiving the foregoing objections, see response to Interrogatory No. 8. If so, state: a. The dates on which such demonstrations took place and the places at which such demonstrations were held; b. The name and title of the representatives who so demonstrated; c. The person's name, address and position held with Plaintiff/decedent's employer for whom the use and operation was demonstrated. 52. Have you or any representatives ever visited the work facility of Plaintiff/decedent's employer? If yes, please state: 52 and 52a.-c. PPG incorporates by reference its General Objections, particularly Nos. 2, 6, 7, 8 and 9. Subject to and without waiving the foregoing objections, see response to Interrogatory No. 8. a. The dates on which such visits took place; 35 AS I 000021616 b. Name and title of the representatives; c. Subject matter of visit. List each and every action taken by you or on your behalf to ensure that Plaintiff/decedent was advised as to the potential health hazards of your product. PPG incorporates by reference its General Objections, particularly Nos. 2, 6, 7, 8 and 9. This Interrogatory is further objected to in that it is not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. Moreover, as Robert Monaghan's employer, it was Firestone's responsibility to provide training, instructions, warnings and other safety recommendations to him directly. eg also response to Interrogatory No. 8. List each and every action taken by you prior to the filing of this lawsuit to determine if the Plaintiff/decedent's employer had advised Plaintiff/decedent of the potential health hazards of the product. See response to Interrogatory No. 53. List each and every action taken by you prior to the filing of this lawsuit to determine if the Plaintiff/decedent's employer had provided Plaintiff/decedent with a safe place in which to use, handle, and be exposed to your product. See response to Inten-ogatory No. 53. Have you provided any type of training for your dealers or distributors of your products? 36 AS I 000021617 56 and 56a.-h. PPG incorporates by reference its General Objections, particularly Nos. 2, 6, 7, 8 and 9. These Interrogatories are further objected to in that they are not reasonably limited as to time frame, the health effects alleged in this case and the exposure situation applicable to this case. Subject to and without waiving the foregoing objections, see response to Interrogatory No. 8. If yes, then state: a. The type of training provided; b. The length of training provided; c. The place of training; d. The subject matter of training; e. Whether said training involved or included instruction regarding the safe use, storage and/or handling of Defendant's products; f. Whether said training involved instructions as to the proper safety devices which should be used with Defendant's products; g. Whether said training included the recognition of hazards and/or risks of injury or disease associated with the use of Defendant's products; h. The name of Defendant's employee(s) in charge of said training program(s). Did you provide any type of training to Plaintiff/decedent's employer on the product in question? 57 and 57a.-g. See responses to Interrogatories Nos. 51 37 ASI 000021618 through 55. If yes, then state: a. The type of training provided; b. The length of training provided; c. The place of training; d. The subject matter of training; e. Whether said training involved or included information regarding the safe use, storage, and/or handling of Defendant's products; f. Whether said training involved instructions as to the proper safety devices which should be used with Defendant's products; g. Whether said training included the recognition of hazards and/or risks of injury associated with the use of Defendant's products. Have you conducted, or had conducted on your behalf, or do you plan to conduct, or have conducted on your behalf any investigation for the purpose of this lawsuit; that is, either to provide direct evidence or for the purpose of providing information upon which other witnesses would testify? If your Answer to this Interrogatory is in the affirmative, then state: --------- 58 and 58a.-i. PPG incorporates by reference its General Objections, particularly Nos. 2, 3, 6 and 9. These interrogatories are further objected to, to the extent they request information which is privileged and protected from disclosure as the work product of answering defendant's attorneys and/or because the information contains and/or represents the mental impressions, 38 AS I 000021619 conclusions and/or opinions respecting the value or merit of a claim or defense and/or respecting strategy or tactics of the representatives of answering defendant, or the conclusions, opinions, memoranda, notes, summaries, legal research or legal theories of answering defendant's attorneys. These interrogatories are further objected to, to the extent that they are beyond the scope of expert discovery permitted under the Pennsylvania Rules of Civil Procedure. PPG further objects to these Interrogatories as improperly seeking information as to what answering defendant plans to do, but has not done, as premature and exceeding the scope of answering defendant's obligations under the Rules of Civil Procedure to supplement its discovery responses. a. The purpose of each such test, study, calculation, or inspection; b. The results of each test, study, calculation, or inspection; c. The name and address of the person who has in his custody or control any document or thing relating to any such test, study, calculation or inspection; d. State the names and addresses and relationship to you of each and every person who participated in each such investigation; e. State the dates on which or during which each and every such investigation took place; 39 ASI 00021620 f. State the address (corresponding with the dates provided above) of the places or locations at which each such investigation took place; g. Describe fully and in detail each and every finding or observation made in the course of each and every such investigation; h. Summarize the recommendations, if any, of each and every such investigation; i. Describe and identify each and every document or writing, by whatever name called, which relates to or reflects the nature of or the conclusions of any such investigation (specifically including, but not limited to photographs and statements). State the name and present address of each and every person you know or have reason to believe might have knowledge of discoverable matter relevant to the issues (whether claims or defenses) presented in the present cause. PPG incorporates by reference its General Objections, particularly Nos. 2, 3, 6 and 9. This Interrogatory is further objected to, to the extent it requests information which is privileged and protected from disclosure as the work ~ product of answering defendant's attorneys and/or because the information contains and/or represents the mental impressions, conclusions and/or opinions respecting the value or merit of a claim or defense and/or respecting strategy or tactics of the representatives of answering defendant, or the conclusions, opinions, memoranda, notes, summaries, legal research or legal theories of 40 AS I 000021621 answering defendant's attorneys. This Interrogatory is further objected to, to the extent that it is beyond the scope of expert discovery permitted under the Pennsylvania Rules of Civil Procedure. PPG further objects to plaintiffs request for the identity of every person who "might have knowledge of discoverable matter relevant to the issues" in so far as said inquiry is overly broad and unduly vague. This Interrogatory is further objected to on the grounds that it is overly broad, unduly vague and ambiguous in that it fails to specifically set forth the particular "discoverable matter" as to which information is sought by plaintiff. Subject to and without waiving the foregoing objections, PPG states that the identity of all such persons is unknown at this time. However, discovery is ongoing and should further information be discovered, PPG will supplement its response to this Interrogatory. See, generally, PPG's Responses to Plaintiffs First Set of Interrogatories and Request for Production of Documents. 60. Do you have knowledge of, or the description of, any other person(s) who may possess knowledge or information related to any of the issues presented by the pleadings in the above-styled cause in addition to or other than the names of the witnesses actually known to you and listed above? 60 and 60a.-b. See response to Interrogatory No. 59. If so, then: a. State the number of such other persons; b. Describe any identifying circumstances which give you cause to suspect there may be other as yet unidentified witnesses. 61. Has any person who may have facts or information relative to any of the issues, whether claims or defenses, in the present proceedings, given any statement, whether 41 ASI 000021622 written or oral, whether ndw in your possession or not? 61 and 61a.-e. See response to Interrogatory No. 59. PPG further objects to these Interrogatories on the grounds that they are overly broad, unduly vague and ambiguous. Subject to and without waiving the foregoing objections, PPG states that it has no discoverable statements. If so, then state: a. The names and addresses of each and every such person; b. Which of these persons gave statements that are not now in your possession or control; c. The name and address and relationship to you of the person or persons who have in their control or custody copies of any and all statements; d. The name, address, and relationship to you of any person who took any such statement, when it was taken, and where it was taken; e. The verbatim content of said statement. With regard to a document or other tangible thing which either in itself contains or constitutes evidence or which may relate to or lead to discoverable matter, please state: 42 ASl 000021623 62 and 62a.-c. PPG incorporates its General Objections, particularly Nos* 2, 3, 6 and 9. These interrogatories are further objected to, to the extent they request information which is privileged and protected from disclosure as the work product of answering defendant's attorneys and/or because the information contains and/or represents the mental impressions, conclusions and/or opinions respecting the value or merit of a claim or defense and/or respecting strategy or tactics of the representatives of answering defendant, or the conclusions, opinions, memoranda, notes, summaries, legal research or legal theories of answering defendant's attorneys. These interrogatories are further objected to, to the extent that they are beyond the scope of expert discovery permitted under the Pennsylvania Rules of Civil Procedure. PPG further objects to these Interrogatories as being unduly vague and ambiguous and PPG is unable to determine what plaintiff considers a document or thing which "constitutes evidence or which may relate to or lead to discoverable matter." a. The description of each such item; b. Its present location; c. The name and address and relationship to this defendant of the person or persons who have custody of each such item. Do you or anyone acting on your behalf know of the existence of any photographs, motion pictures, video recordings, maps, diagrams or models of either the site of Plaintiff/decedent's exposure, the parties, Defendant's product. Defendant's product containers, or any other subject matter involved in this action? If the Answer in the affirmative, identify: 63 and 63a.-d. PPG incorporates General Objections, particularly Nos. 2, 3, 6,7, 8 and 9. These interrogatories are further objected to, to the extent they request information which is privileged and protected from disclosure as the work product of answering defendant's attorneys and/or because the information contains and/or represents the mental impressions, conclusions and/or opinions respecting the value or merit of a claim or defense and/or respecting strategy or tactics of the representatives of answering defendant, or 43 000021&24 AS I the conclusions, opinions, memoranda, notes, summaries, legal research or legal theories of answering defendant's attorneys. These interrogatories are further objected to, to the extent that they are beyond the scope of expert discovery permitted under the Pennsylvania Rules of Civil Procedure. These Interrogatories are further objected to in that they are overly broad, unduly vague and ambiguous in that plaintiff nowhere defines what she means by the term "other subject matter involved in this action." Subject to and without waiving said objections, PPG states that it has no such photographs, motion pictures, video recordings, maps, diagrams or models. a. The date or dates when such items were made and what they are; b. The name and address of the person making them; c. The subject that each represents or portrays; d. The name and address of the person who presently has custody of said items. For each and every witness you intend to call at trial, state: 64a.-c. PPG incorporates by reference its General Objections, particularly Nos. T, 2, 3, 6 and 9. These Interrogatories are further objected to7 tcTthe extent that they request information which is privileged and protected from disclosure as the work product of answering defendant's attorneys and/or because the information contains and/or represents the mental impressions, conclusions and/or opinions respecting the value or merit of a claim or 44 AS I 000021625 defense and/or respecting strategy or tactics of the representatives of answering defendant, the conclusions, opinions, memoranda, notes, summaries, legal research or legal theories of answering defendant's attorneys. These Interrogatories are further objected to, to the extent that they are beyond the scope of expert discovery permitted under the Pennsylvania Rules of Civil Procedure. Subject to and without waiving the foregoing objections, PPG states that it has not yet determined what witnesses it will call at the trial of this matter. a. Name, age, business and home address; b. The subject(s) on which he/she is expected to testify; c. Summary of the fact(s) to which he/she will testify. 65. Identify fully all documents intended to be offered at the trial for any use including, but not limited to medical and scientific text to be relied upon and business records of the Defendant. See response to Interrogatory No. 64. Subject to and without waiving the foregoing objections, PPG states that it has not yet determined which documents it will offer at trial. 66. Are you covered by any type of insurance for the injuries alleged in Plaintiff/decedent's Complaint, including any excess or umbrella insurance, in connection with the accident? Yes. ______ _ If the Answer is affirmative, state the following with respect to each policy: 66 and 66a.-f. PPG incorporates by reference its General Objections, 45 AS I 000021626 particularly Nos. 1, 2, 6 and 9. Without waiving said objections, PPG states that it has sufficient insurance. The name of the insurance carrier which issued each policy of insurance; The named insured under each policy and the policy number; The type of each policy and the effective date; The amount of coverage provided for injury or death to each person, for each occurrence, and in the aggregate for each policy; If the policy has an aggregate limit, list: i. The aggregate for each policy; ii. The number of claims, and the amount of money for each claim, which has been paid under the aggregate; iii. The number of claims, and the amount of money reserved for each claim which has been made but not paid under the aggregate. " "" 46 AS I 000021627 f. Each exclusion, if any, in the policy which is applicable to any claim thereunder and the reasons why you or the company claims the exclusion is applicable. 67. State the name, address, occupation and field of specialization, if any, of each person whom you expect to call as an expert witness at trial. PPG has not yet decided which, if any, experts it will call at trial. Expert reports or answers to expert interrogatories will be submitted in accordance with the Pennsylvania Rules of Civil Procedure. 68. Set forth the qualifications of all those persons listed in Answer to the preceding Interrogatory, and in doing so as to each expert, list: Formal education; the schools attended, including years of attendance and degrees or certifications received; experience in particular fields, including names and addresses of employers with inclusive years of employment and positions hold; teaching positions or other affiliations; all professional societies, academies, associations, or other organized professional group of which said persons are member, including when and where said persons were enrolled in each; and a list of all publications authorized by said persons, including the title of the work, nature of the periodical or book in which it was printed, and the date of its printing. (In lieu of answering this Interrogatory, please attach a copy of each expert's curriculum vitae or resume.) PPG objects to this Interrogatory to the extent that it is beyond the scope of expert discovery permitted under the Pennsylvania Rules of Civil Procedure. Without waiving said objections, seg response to Interrogatory No. 67. 69. With respect to each person identified in your Answer to Interrogatory No. 66, state: 47 ASI 000021628 69a.-f. See response to Interrogatory No. 68. a. The subject matter on which each expert is expected to testify; b. The substance of the facts and opinions to which the expert is expected to testify; c. A summary of the grounds for each opinion; d. Any scientific rule or principle upon which the opinion of such expert is based; e. Any code or regulation, governmental or otherwise, upon which the opinion of this expert is based, with specific identification of the section relied upon; f. The identify of all tests, if any, performed by said expert, the results of said test, and any documents generated in connection with said test. 48 OOOO^629 ASi State in detail the factual information supplied to each expert which was used as a basis for forming his/her opinion(s) including all documents, reports or records furnished, all testimony, statements and reference material reviewed, all physical evidence, objects, test results, inspection reports, photographs, plans or other tangible things provided to each expert for review and inspection. See response to Interrogatory No. 68. With respect to each person identified in your answer to Interrogatory No. 66 [sic 67], state whether the expert has examined any object in connection with the request that the expert give an opinion and, if so, state type, place, and date of each such examination. See response to Intenogatory No. 68. As to all persons listed in Answer to Interrogatory No. 66, state the full caption, Court Term and Number of all cases in which that person has testified in the past five (5) years. If this information is unavailable, give the name of the cases involved and state the Court where each matter was tried, as well as the approximate date of trial. See response to Interrogatory No. 68. Has any person by reason of training or experience, who might be considered an expert, whether or not hired by the Defendant, his attorneys, or other representatives, made any investigations to determine the cause of the occurrence, and if so, for each such person state: 49 AS I 000021630 73 and 73a.-h. PPG objects to this interrogatory because it is beyond the scope of expert discovery permitted under the Pennsylvania Rules of Civil Procedure. a. The full name, address and telephone number of such persons; b. The business or profession of said persons; c. The education, experience and other qualifications of said persons; d. Name and address of the person or firm who hired him or her; e. The date or dates on which said investigation was made and the conclusion reached by each such person; f. The grounds for the conclusions reached by each such person; g. The date of each oral or written report made by each such person; 50 ASI 000021631 h. Whether Defendant will produce a copy of each report without requiring an order to do so. If the Answer is in the affirmative, please attach copies to your Answers to these Interrogatories. 74. State the name and address of every person who has been retained, consulted or specially employed by you as an expert in anticipation of litigation or preparation for trial but who is not expected to be called as a witness at trial. See response to Interrogatory No. 73. 75. Each person listed in Answer to Interrogatory No. 2 will sign an Affidavit, and by doing so he verifies that the information found in his Answer to these Interrogatories is true and correct to the best of his knowledge, information and belief, that the opinions expressed in the Answers to these Interrogatories are those he will express at trial, and that he will express no others unless this Interrogatory is supplemented within a reasonable time before trial, to allow Plaintiff to evaluate any such changes. PPG incorporates by reference its General Objections, particularly No. 1. Subject to and without waiving the foregoing objections, PPG states that this is not an Interrogatory. Respectfully submitted, GOLDBERG, PERSKY, JENNINGS & WHITE, P.C. By:, Peter T. Paladino, Esquire Attorney for Plaintiffs 51 AS I 000021632 MANTA AND WELGE Attorney for Defendant, PPG Industries, Inc. 52 AS I 000021633