Document 0gn28G455XOzboO2BdpGMK7GM

1. RtLtlvtu us/to it. nu 133c. mi tnmwin 1 i ----B3'26-'92 1:33 ^ J- f TMOC i srniiutLi rHbL 04 IN RE: ALL ASBESTOS-RELATED PERSONAL INJURY OR DEATH CASES FILED OR TO BE FILED IN DALLAS COUNTY, TEXAS IN THE DISTRICT COURTS OF DALLAS COUNTY * TEXAS 160TH JUDICIAL DISTRICT W.R. GRACE ft CO. - CONN.'S ANSWERS AND OBJECTIONS TO PLAINTIFFS' MASTER INTERROGATORIES AMD REQUESTS FOR PRODUCTION PROPOUNDED TO DEFENDANT GENERAL OBJECTIONS The following answers are based upon facts known or believed by W. R. Grace ft Co. - Conn., formerly known as W.R. Grace ft Co., (^Grace-Conn") at the time of answering these interrogatories and requests. Much of the information is sought from many years ago and is, therefore, difficult or impossible to reconstruct or retrieve. Grace-Conn, therefore, reserves the right to amend these answers as and if new or better information becomes available to it or if errors are discovered. Unless otherwise stated in an answer to a specific interrogatory or request, these answers are limited to products which were manufactured by Grace-Conn and which were used in the commercial construction industry, which had fireproofing, thermal or acoustical insulating properties and contained commercial asbestos, and to products which are used in the commercial construction industry, which have fireproofing, thermal or acoustical insulating properties, .and which do not contain commercial asbestos but do contain vermiculite. Products which contain vermiculite may or may not contain trace amounts of naturally occurring asbestiform tremolite. These answers are further limited to the activities of Grace-Conn's Construction Products Division ("CPD") associated with the manufacture and sale of such products in the United States during the relevant time period. Any reference to the manufacture, sale or distribution of a product by an entity other than Grace-Conn, e.g., by the Zonolite Company, should not be considered an admission that Grace-Conn is liable or responsible for injuries alleged to have resulted from the manufacture, sale or use of such product. Grace-Conn reserves the right to object to the admissibility of all or part of any answer to an interrogatory on this basis. To the extent that these interrogatories call for information beyond the limitations stated above, an objection is made thereto as being irrelevant, immaterial, overly broad, unduly burdensome, and/or not reasonably calculated to lead to the discovery of w.b. auei i co.-cobs. umu ABO DBJBCTXOBS TO fLAZBTXPP'O HA3TSB 1BTBUOOATOBXU ABB mseOBOTS FOB FBOPOCTIOB raOPOUBBBB TO OBF1BOABT l [ RECEIVED 85/26 1*1:90 1992 ft! 21974117/6 S/26'92 1*134 PH6E 5 U-K1MIED FtfbE b/ j 05 1/ admissible evidence and the answers thereto are privileged and/or protected. Grace-Conn further objects to these interrogatories insofar as they seek production of any information constituting a trade secret, confidential financial data or other confidential research, development or commercial information. Grace-Conn further objects to these interrogatories insofar as they seek information which is subject to the attorney-client privilege, which evidences or constitutes attorney work product or which is otherwise not discoverable under the provisions of the Texas Rules of Civil Procedure. INTERROGATORY 1 State the name, address, job title, lenath of time employed by Defendant, and a year-by-year list of all other positions, titles, or jobs held when working for Defendant of each person who has supplied any information used in answering these interrogatories. ANSWER 1 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence and seeks information which is subject to the attorneyclient privilege. Without waiving or in any way limiting this objection or the General Objections interposed above, Grace-Conn states that these answers were prepared with the assistance of many employees and representatives- of Grace-Conn, with the assistance and advice of Grace-Conn counsel, retained counsel and their staffs, who, in the course of preparing for these and other cases have interviewed many individuals and have reviewed voluminous records of Grace-Conn. INTERROGATORY 2 State whether or not you are a corporation. If so, state your correct corporate name, the state of your incorporation, the address of your principal place of business, the name and address of the person or entity authorized to accept service of process on your behalf, and whether or not you have ever held a Certificate of Authority to do business in the State of Texas. ANSWER 2 Yes. w. r. Grace & Co.-Conn; Connecticut; One Town Center Road, Boca Raton, Florida 33486; Prentice - Hall Corporate w.k. mack * co.--com. uinu hf* a MID OBS1CTIOM TO lUlRirr'S Mini nnroMooATOSZM jum ngvmi m MODIICTIOe HOTOMDID TO OMCTPAST L RECEIVED 0S/2b Hi *in/*t*u//to 05/26/92 14*34 rHtic a \tt\inicu rtuc. a t j 06 System, Inc., the address of which is a matter of public record equally available to plaintiffs as to Grace-Conn; Grace-Conn is authorized to do business in every state. INTERROGATORY 3 L Has Defendant or any of its predecessor or subsidiary companies at any time engaged in the mining and subsequent sale of material containing asbestos fibers? If so, identify the location of the mine(s), the years of its operation, the type of asbestos mined and whether you sold any asbestos to any Defendants in the Dallas County asbestos litigation. ANSWER 3 See the General Objections interposed above. Without waiving or in any way limiting its objections, Grace-Conn states it has never mined or milled commercial asbestos. The Superior Asbestos Company was formed by the Zonolite Company to conduct a pilot project in 1962, prior to Grace-Conn's acquisition of Zonolite, to evaluate the possibility of commercial use of the tremolite in the Libby vermiculite deposits. The Superior Asbestos Company made no sales of raw asbestos and was dissolved in 1964 or 1965. Further answering, Grace-Conn states that it has in the past, and continues in the present, to mine vermiculite which may or may not contain trace amounts of naturally occurring asbestiform tremolite. Vermiculite is subjected to processes which leave only trace amounts of tremolite, if any amount at all, in finished products that contain vermiculite. Grace-Conn states that, to the best of its knowledge, it did not sell asbestos to any co-defendants in the Dallas County asbestos litigation. INTERROGATORY 4 Identify by name each product containing asbestos fibers that Defendant or any of its predecessor or subsidiary companies at any time manufactured or sold. ANSWER 4 Subject to the General Objections interposed above, GraceConn states see Product Appendix Nos. l-35(a}. INTERROGATORY 5 Identify by name each product containing asbestos fibers that Defendant or any of its predecessor or subsidiary companies at any time marketed or sold. ANSWER 5 Subject to the General Objections interposed above, GraceConn states see Product Appendix nob. l-35(a). .* osacs t co.-cm.j uimu emeiion to ruinirr'i mmt xwrsaitoeMouia mmv asevssn roa FSOOBCTIOS MlOTOOSBKB TO BSrSSWUlT [ RECEIVED 05/26 14:42 1992 AT 2147441776 05^26^92 1**35 HA6E 7 (PHI Hi ED PA6E n 0' INTERROGATORY 6 If the answer to one or more of the last three interrogatories is in the affirmative or lists any products, state as to each named product the following: i A. As to each product* state whether sueh product was mined, manufactured, marketed, and/or sold. B. The names of the companies mining, manufacturing, marketing, and/or selling each product and mined, manufactured, marketed, and/or sold. C. The trade or brand name of each of those products mined, manufactured, marketed and/or sold. D. The date each of the named products was placed on the market. e. A description of the physical (chemical) composition of each of the named products, including the type of asbestos contained in the produet and the percentage of asbestos put in each product. P. The date each of the products was removed from the market and no longer sold or distributed and the reason or reasons therefor. G. The date asbestos was removed from such products, if ever, and the reasons therefor. H. A description of the physical appearance of each of the named products. I. A detailed description of the intended uses of the named products. J. Identify the last year that you sold each asbestoscontaining product. ANSWER 6 a. Subject to the General Objections interposed above, Grace-Conn states that all of the products in the Product Appendix were manufactured, marketed, and sold. b. See the Product Appendix Nos. l-35(b). c. See the Product Appendix Nos. l-35(a). d. See the Product Appendix Nos. l-35(c). *. UCI I CD.-COMB.'0 JUMWBM ftft 4 ABO OBJBCTIOBB TO VIAIBTXPr' NADYM lanuounuu abo abqubbt* box PMOPUCTlOB MPFOOBPKQ TO BCW1MPT L HCiVD US/b L't.'UL L?*c hi iiimir/o 13/26/92 14135 rnoc. a \rninnu rnoc a i j e. See the Product Appendix Nos. l-35(d). f. See the Product Appendix Nos. l-35(e S f). 9- See the Product Appendix Nox. l-35(k). h. See the Product Appendix Nos. 1-35(9) i. See the Product Appendix Nos. 1--35(h). j- See the Product Appendix Nos. l-35(e). INTERROGATORY 7 Do any documents, including but not limited to written memoranda, specifications, recommendations, blueprints, or other written materials of any kind or character, relating to the design, preparation, or introduction into the market of the products listed in Interrogatory No. 6 still exist? Xf so, state: A. A description of each such document. 8. The name, address, and job title of eaeh person who currently has possession of each document, and where the documents are currently located. ANSWER 7 Grace-Conn objects to this interrogatory on the grounds that it is vague and ambiguous in that the phrase "design, preparation, or introduction into the market" is undefined and subject to various interpretations. Subject to this objection and to the General Objections interposed above, Grace-Conn states that relevant, non-privileged, non-trade secret documents containing information responsive to this interrogatory will be made available to the plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 8 Before distributing, selling, or placing the products listed in your responses to interrogatory Nos. 3-6 into the streams of commerce, were any tests conducted to determine potential health hazards involved in the use of, or exposure to, the materials such as asbestos, contained in those products? If the answer is affirmative, state: A. The names of the products tested and the date of each test. w.a. aiAcx i co.-con.'a umu osjictxom tv nunirra wum unuMAMkiu a>d iigwm roa rnoppcTioa kmomoanan to norm*" s 1 HtLfcJVLO US/CD n. tj 11. HI tmiiirio 05/26'92 14136 mac. J m at j , 99 B. The name, address, and job title of each person conducting the tests or involved with conducting the te6ts. C. The results of the tests. ANSWER 8 Grace-Conn objects to the interrogatory on the grounds that it is vague and ambiguous in that the phrase "potential health hazards" is undefined and subject to various interpretations. Without waiving this objection or the General Objections interposed above, Grace-Conn states not to its knowledge. INTERROGATORY 9 Do any documents, including but not limited to written memoranda, specifications, recommendations, blueprints, or other written materials of any kind or character, relating to the testing of the products referred to in Interrogatory No. 6 now exist? If so, state: A. A description of each such document. B. The name, address, and job title of each person who currently has possession of each document, and where it is presently located. ANSWER 9 Subject to the General Objections interposed above, GraceConn states that relevant, non-privileged, non-trade secret documents responsive to this interrogatory will be made available to the plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 10 Did Defendant or any of its predecessor or subsidiary companies make any design changes or modifications as a result of those tests described in responses to interrogatory No. 8? If the answer is affirmative, state: A. The trade names of the products changed. B. The nature of the changes made and the date of such changes or modifications. C. The name, address, and job title of each person responsible for having caused a change to be made, or having made a change or modification. w.ft. uci t co.-com. in suicrion to rumirr'* triummouii amp BkgoKara rom T0OPPCTIOO MtOrOCTPSP TO 0HaDMT 6 I RECEIVED 05/26 14:43 1992 AT 2147441776 09^26^92 14136 f-Hbt. lid IhhlNIt-U t'Hbt lb/ j ANSWER 10 Grace-Conn objects to this interrogatory on the grounds that it is vague and ambiguous in that the term "design changes" is undefined and subject to various interpretations and the phrase "those tests" lacks a referent. INTERROGATORY 11 After releasing the products listed in interrogatory No. 6 to the public, were any tests conducted on them to determine potential health hazards resulting from the use of or exposure to the materials, such as asbestos, contained in those products? If the answer is affirmative, statei A. The names of the products tested and the dates of such tests. B. The name, address, and job title of each person who conducted those tests. C. The results of those tests. D. Whether, as a result of the tests, any products were removed from the market. E. The names of all products removed from the market as a result of these tests. ANSWER 11 Grace-Conn objects to the interrogatory on the grounds that it is vague and ambiguous in that the phrase "potential health hazards" is undefined and subject to various interpretations. Without waiving this objection or the General Objections interposed above, Grace-Conn states not to its knowledge. INTERROGATORY 12 Do any documents, including written memoranda, specifications, recommendations, blueprints, or other written materials of any kind or character, relating to the potential health hazards of the products listed in Interrogatory No. 6 now exist? If so, state: A. The name of each product. B. A description of each document and how it relates to each product. C. The name, address, and job title of each person who currently has possession of each document, and where it is presently located. .* (ues t co.-com.** umu juro oajtcrioia to ruxurirr >* iumi XSTISKOeSTOSIlt AID BIQVMT9 rox Howicnoi MOWWIMII TO MfUMW i l htLtiVtLI kJb/b 11.11 HI tnmiuo 05/26^92 1137 rnnt n rnbt iii j ANSWER 12 Subject to the General Objections interposed above, GraceConn states that relevant, non-privileged, non-trade secret documents containing information responsive to this interrogatory will be made available to plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 13 Did Defendant or any of its subsidiary companies make any design changes as a result of the tests discussed in your response to Interrogatories No. 10 or 13? If the answer is affirmative, state: A. The names of the products changed or modified. B. The name, address, and job title of each person responsible for having made a change or modification. C. The nature of the hazard or defect which resulted in such change or modification. ANSWER 13 Grace-Conn is unable to answer this interrogatory because it does not understand the reference to interrogatories 10 and 13. INTERROGATORY 14 Has Defendant or any of its predecessor or subsidiary companies at any time published or distributed any printed material, including brochures, pamphlets, catalogs, packaging or other written material or any kind or character containing any warnings concerning the possibility of injury resulting from the use of the asbestos-containing products listed in Interrogatory No. 6? if so, state: A. The names of each relevant product. B. The exact wording of each warning statement on each printed material. C. A description of the printed material other than the warning statement. D. The method used to distribute the warning to persons likely to use the product. E. The date each warning was first issued, distributed, or placed on packaging. w.m. tun i co.-cobb. >i abiwikj AM OBJECTION TO TULIBTIPr' RASTER XRTEXROOATORIEf MS BBQVSET0 FOR FEOBPCTIOW FEOFOOMIO TO OBFEBOAOT i [ RECEIVED 05/2b 11:14 1992 fil 5'26s92 14137 rntec. ic irtuflici; rnoc. 12 F. The name, address, and job title of each person responsible for having drafted or issued the warning. G. The current location of any such printed material and the custodian thereof. B. The form in which such literature or printed material can be accessed, 1. e , the manner in which such literature is indexed or stored. ANSWER 14 Grace-Conn objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence as it is not limited as to caution, time periods, locations, etc. Grace-Conn further objects to this interrogatory on the grounds that it is vague and ambiguous in that terms such as "warning" are undefined and subject to various interpretations. Grace-Conn further objects to this interrogatory on the grounds that it improperly implies that Grace-Conn's products presented a hazard to users. Subject to these objections and to the General Objections interposed above, Grace-Conn states that no warnings were placed on the packaging of its products that contained commercial asbestos. Grace-Conn further states that no warnings were placed directly on any of its products. Grace-Conn had sales brochures for most of its products. Further answering, Grace-Conn states that the 1970 Grace-Conn brochure published in Sweet's Catalog of 1971 contained the following paragraphs: "POLLUTION AND HEALTH: Because of the constantly changing conditions involving fireproofing and its relation to pollution and'health, we recommend that you contact your Zonolite sales office for the latest data on these subjects. Recent tests at Underwriters Laboratories, Znc. have provided some fire-ratings on an asbestos-free formula Mono-Kote. Other tests and ratings will follow." "Existing formulations of Hono-Xote contain minimal amounts of asbestos which are locked in during the mixing process. Nono-Kote is wet mixed, pumped and sprayed, and hardens to a cementitious mass. Jobsite tests show air fiber counts well below occupational Threshold Limit values proposed by government bodies." in addition, Grace-Conn states with regard to its vermiculite products that beginning in 1976, in the form of Material Safety Data Sheets it notified customers of the need to wear NXOSH/MESAapproved respirators when threshold limit values were exceeded. .*. MtKci i co.-com.'I Mwmi >,. amd oMicnon o ruinzrr'i mii unuoMnuu jure bquzsti foi HflOOCTIW mOKWlBIP TO BITfBMT L RECEIVED 8b/Eb 1*4:16 1S3E rtl Ei1/11i<Wb 05/26/92 14138 rUtaC. 1J {tniniLU fHbt Ui J Also starting in 1976 or 1977, Grace-Conn affixed a caution regarding nuisance dust to the packaging of its vermieulite products. This caution read: CAUTION AVOID CREATING DUST BREATHING DUST MAY BE HARMFUL TO YOUR HEALTH USE WITH ADEQUATE VENTILATION OR WITH RESPIRATORY PROTECTION Relevant, non-privileged and non-trade secret documents containing information responsive to this interrogatory will be made available to the plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 15 Before 1970, had you received notice that any individual or individuals, other than those Plaintiffs who have filed personal injury actions in Dallas County, Texas, is or are claiming or has or have claimed an injury as a result of using asbestos products manufactured and/or sold by your company or any of its predecessors or subsidiaries before 19707 If so, state: A. The name and address of each claimant. B. The date of notice of each claim. C. a description of the claim. D. The type of injuries allegedly sustained. E. The name and address of each attorney whorepresents each individual making a claim. F. The style and court number of each claim. G. The disposition of each claim that has been settled or taken to judgment. ANSWER 15 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to this objection and the General Objections interposed above. Grace-conn states no. INTERROGATORY 16 Were your asbestos products distributed, market, packaged, labeled and/or sold by companies other than your own? If the v.a. macs Co.-con. * mikiii tif, 10 md objectxos* to ruiRirr'i njuibs inmoauoizu ud mqucit* ro* TSOPOCTXDS nOfOOSPBB TO QSrsSOAST C RECEIVED 05/Zb It: IS 155Z Hi ^nminii 03/26/92 14138 rna. it ifhiditii t-Mtot. it i i answer is affirmative, list the names and addresses of each of those companies, and the products in question. ANSWER 16 Grace-Conn states the products in the Product Appendix were generally sold directly to end users by sales personnel based in offices at manufacturing plant locations. Further answering, Grace-Conn states that once it sold its product to a customer, it did not monitor whether or not the customer resold the product, while Grace-Conn generally marketed its products for sale to "end use" customers, it did not have a policy forbidding the sale of its products to customers who might resell the products. INTERROGATORY 17 Did you or any of your predecessors, successors, or subsidiaries have any distributors or sales representatives of asbestos products in the States of Alabama, Florida, Mississippi, Oregon, Washington, Georgia, Tennessee, Texas and Virginia? If so, state: A. The name and address of each such distributor or sales representatives. B. The years in which such company or person distributed, marketed, or sold your products. C. What products were distributed, marketed, or sold and in what years. ANSWER 17 Subject to the General Objections interposed above, GraceConn states that it had licensing/distribution agreements with the Texa6 Vermiculite Company; Southwest Vermiculite Co.; Southern Zonolite Company; Vermiculite-Northwest, Inc.; and Vermiculite Products, Inc.; covering, at least in part, the listed states. The Southern Zonolite Company merged into the Zonolite Company in 1956. Grace-Conn states that it acquired a majority of the shares of Texas Vermiculite Company and a minority of the shares of Vermiculite-Northwest, Inc. as a result of its acquisition of the assets of the Zonolite Company in 1963. in 1966, Grace-Conn acquired the remainder of the shares of Vermiculite-Northwest, Inc. and that company was dissolved by December 31, 1969. in 1975, Grace-Conn acquired the remainder of the shares of Texas Vermiculite Company and that company was dissolved. .*. un * co.-com. juhwibs !> 11 MB OBJBCTXOM M tUIRlrr'i KMW 19 H RiuoMmiii mb ueesan bob BOBPCTIOW MOfBWWIB TO WMWMf r [ RECEIVED 05/Zb 14:46 1992 AT 214744177b 3S26/92 1 4 J 39 HHbt ib (HKiNltU KHbt 13; J 5 INTERROGATORY 16 List each employee (including only physicians and/or hygienists) who has acted in a medical advisory capacity to your company at any time during the past 40 years, including, but not limited to, physicians and industrial hygienists, and the current address, telephone number and job title o each of those individuals and who has, had or may have had any knowledge regarding the hazards of asbestos. ANSWER 16 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to this objection and to the General Objections interposed above, Grace-Conn states that since 1982 it has employed Jerry H. Berks, K.D., who reports to Harry A. sschenbach. Director of Health, Safety and Toxicology. Prior to that, Grace-Conn had no physicians in its employ and had always used outside physicians on a fee-for-service basis with a minimum of one physician being used at each plant, although some plants used many more. Grace-Conn also states that from 1977 to 1982 it employed Dr. Harold H. Borgstedt, University of Rochester Medical School, Rochester, New York, as a consultant relating to toxicology and related medical matters. Further responding, Grace-Conn states that in the office of Health, Safety & Toxicology of the Grace Specialty Chemicals at 55 Hayden Avenue, Lexington, Massachusetts 02173, Harry A. Eschenbach was employed as a safety engineer in 1971. .in 1977, he was made director of the office, in 1986, Larry Park was hired as an industrial hygienist. He left Grace-Conn in December 1988. in 1975, Thomas E. Hamilton was made a safety engineer and in 1977, he became an industrial hygienist. He worked for GraceConn until January 1987. From 1981 to February 1986, Paul M. Connor was employed as an Industrial Hygienist. Further answering, the Environmental/Health Department of Grace-Conn employed Stephen Venuti, who became a certified industrial hygiene technologist in June 1984, and Marlena fox, an Industrial hygienist who was hired in September 1985. Venuti left GraceConn in 1989. Fox left Grace-Conn in 1990. John Benningson and David Curreri were hired as assistant industrial hygienists in 1966 and are currently industrial hygienists. The hygienists' duties are to recognize, evaluate and control workers' exposure to chemical and physical agents. INTERROGATORY 19 Does Defendant have in its possession any books, pamphlets, memoranda, or written materials of any kind or character that would indicate that asbestos fibers, when Inhaled, can be hazardous to the health of human being? If so, state: w.x. gun i co.-com.'* uimu AXD OBJICTXOM TO rbAIRZPr * MkSTBB IRlUMkTOlIU MB SieOBST* FOR Mooocrioe wotoobbib to pzrimasr 12 I RECEIVED 05/25 19197 1592 ftl 2197991775 03S26S92 14(40 PAGE lb (PRINTED PAGE 15) j * A. The name of each such publication. B. The date of publication and the naaes of the author and publisher (if any). C. The date received by Defendant, if known. D. The name, job title, and address of each person who currently has possession of each publication and its present location. ANSWER 19 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Subject to these objections and the General objections interposed above, Grace-Conn states that relevant, non-privileged, non-trade secret documents will be made available to plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 20 Has Defendant or any of its subsidiary or predecessor companies at any time been a member of any trade organisation or association that published or disseminated any documents or information relating to the hazards of asbestos comprised of other manufacturers, miners, marketers, and/or sellers of asbestos products? Zf so, state: A. The name and address of each such association or organization. B. The dates during which Defendant or any of its subsidiaries or predecessors were members. C. The name and dates of any publications, minutes, or reports published, written, or disseminated by any of the named associations or organizations. D. Whether any of those publications are still in your possession, and if so: 1. A description of the publications, including the date. 2. The current location of such publications. 3. The custodian of such publication. w.k. tun 4 co.-coaa. * umu An ouictioM to ruzsTirr'a smtsk IRIUOUIMISI JUW SIQOSSTI TW obqooctios iwwiniwt to Birwaw is [ RECEIVED 0S/2b 14:47 1992 AT 214744177b 03/26792 14140 fHbt 17 (t'KIMl'ED i/i j 4. ANSWER 20 The method or manner in which such publications are maintained. Grace-Conn objects to this interrogatory on the grounds that it i6 overly broad, unduly burdensome, irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence. Subject to this objection and the General Objections interposed above, Grace-Conn states that it has attended annual meetings of the Asbestos information Association sinee approximately 1977. Further answering, Grace-Conn has been a member of the Perlite institute from 1968 to the present, a sustaining member of the American Industrial Hygiene Association since 1976, and a member of the American Industrial Health Council since 1978. Grace-Conn has been a member of the Association of Walls and Ceilings International since the 1970's, a member of the Vermiculite Institute from 1963 to 1971, a member of the Exterior Insulation Manufacturers Association since 1984, a member of the Safe Building Alliance since the spring of 1984, a member of the Committee for Equitable Compensation since the summer of 1987, a member of the Vermiculite Association since 1988, and is a member of the Construction Products Manufacturers Council. Grace-Conn further states that relevant, non-privilieged, non-trade secret documents containing information responsive to this interrogatory will be made available to plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 21 identify by name and location each plant or manufacturing facility in which the products listed in your answers to interrogatory Nos. 3-6 were manufactured, assembled, or prepared for sale or marketing, specifying which plants produced each item, the dates each plant is or was in operation, and the time span during which each named item was produced or manufactured. ANSWER 21 See the Product Appendix Nos, l-35(i). INTERROGATORY 22 Have printed sales materials been prepared by Defendant or any of its subsidiary or predecessor companies or their agents for purposes of marketing or advertising products containing asbestos? If so, state: A. The name, address, and job title of each person or entity who prepared such materials. w.k. aiACs t CO.-COOT.'0 uinu M OBJECTIONS TO ILURtn't HAflTII IRIUOtATOUII un OTQVB0TB rol OTOPPCT1O0 OTOTOWMtB TO WTHMUff n [ RECEIVED 05/26 14;48 1992 AT 214744177b 83S26S92 14141 8H6E id (rhlHtfcU fMbC. id; j ie B. The name, address, and job title of each person who currently has possession of such materials and their present location. C. The date the materials were prepared. D. The media used to disseminate the sales materials. ANSWER 22 Subject to the General Objections interposed above, GraceConn states that relevant, non-privlleged, non-trade secret documents containing information responsive to this Interrogatory will be made available to plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 23 Have any written or printed materials or instructions of any kind or character been prepared by Defendant or any of its subsidiary or predecessor companies or their agents indicating how asbestos products should be used and maintained? If so, state: A. The name, address, and job title of each person who prepared such materials or instructions or assisted in their preparation. B. The name, address and job title of each person who currently has possession of such materials or instructions and their present location. C. The dates of distribution- or use and the manner in which such materials or instructions were distributed to purchasers of Defendant's products or those of its subsidiaries or predecessors. D. The year each such written material or Instruction was prepared and disclosed to potential consumers. ANSWER 23 Subject to the General Objections interposed above, GraceConn states that it has brochures for the products listed in the Product Appendix. Relevant, non-privileged, non-trade secret documents containing Information responsive to this interrogatory will be made available to plaintiffs in Boston, Massachusetts at a mutually agreeable time. *. MAC* 4 CO.-con. UIWIU lift IS Ul OBJ8CTXOM TO rUIRirr'l Mini xsTSsaoe*T08Z88 jure ifomin row FmOOTCTIOT FMOTOCTB8P TO MrSHDUT [ RECEIVED 05/26 14:40 1992 AT 214744177b S9/26/92 14141 PACE 19 (PRINTED PA6E 19j J 19 INTERROGATORY 24 Does Defendant have insurance policies that night cover the claims nade by Plaintiffs in these cases? if so, list the name of each insurance carrier, the amount of initial coverage, amount of coverage remaining at the present time, and the effective dates of each policy, (if properly answered, this Interrogatory need not be supplemented as to the remaining amount of coverage). ANSWER 24 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence, without waiving its objections, Grace-Conn states that it has identified at least five primary insurance carriers that sold policies that Grace-Conn contends provide coverage for claims in it6 asbestos-related personal Injury cases. Each of these insurance carriers, with the exception of the Continental Casualty Company, has either denied coverage or has accepted coverage under a reservation of rights. Furthermore, Grace-Conn has not yet completed the research on its insurance coverage history. As a result, Grace-Conn cannot be certain at this time about the nature and extent of its insurance coverage. However, to the extent that insurance coverage information is available, Grace-Conn states that the following policies might provide cove rage: Maryland Casualty Company 1. Name insured: Type: Policy Number: Policy Period; Applicable Policy Limits: 2. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: W. R. Grace & Co. Comprehensive General Liability 96-224900 6/3/0/63-6/30/64 $1,000,000 each accident $1,000,000 aggregate W. R. Grace t Co. Comprehensive General a lt> 4 I 6/30/64-6/30/65 $1,000,000 each accident $1,000,000 aggregate n.*. auiei a co.-com.'a unui ,i|. if MB OBJSCTXDM TO PUUSTXrP'a MASTS* linuouniiu UP M(N(TI rop FXopocTioe fsqpootpsp to Pirmpurr l KfcLlVLl 83/i*t, *t3 i33c m <.iimino 85/26^92 14142 4' nov. iwiu i noL 26 3. Name Insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 4. Name insured: Type: Policy Number: policy Period: Applicable Policy Limits: 5. Name insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 6. Name insured: Type: Policy Number: Policy Period: Applicable Policy Limits: w. r. Grace a Co. Comprehensive General Liability 96-257400 6/30/65-6/30/66 $1,000,000 each accident $1,000,000 aggregate N. F. Grace a Co. Comprehensive General Liability 96-269500 6/30/66-6/30/67 $1,000,000 each accident $1,000,000 aggregate w. r. Grace & Co. Comprehensive General Liability 31-278301 6/30/67-6/30/70 $1,000,000 each accident $1,000,000 aggregate W. R. Grace a Co. Comprehensive General Liability 31R-911051 6/30/70-6/30/73 $1,000,000 each accident $1,000,000 aggregate Continental Casualty Company 1. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 2. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: N. R. Grace a Co. Comprehensive General Liability CCP 902-3670 6/30/73-6/30/76 $1,000,000 per occurrence $2,000,000 aggregate W. R. Grace a Co. Comprehensive General Liability CCP 248-3440 6/30/76-6/30/82 $1,000,000 per occurrence $2,000,000 aggregate V.s. OBACI l CO.-COM.'* ABSWBM h|t 17 jun suirimi to ruintrr'i xmtii imiuwmua juw ugnm pob TBQBBCTIOB TBOTOUBMP TO WWMW C RECEIVED MS/2b 11( IS 19S2 A1 21*7191770 93'26s92 14J42 KHbt 21 (PRINTED PAbE j 3. Named insured: Type: Policy Number: policy Period: Applicable Policy Limits: 4. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: W. R. Grace i Co. Comprehensive General Liability CCP 248-3440 6/30/82-6/30/85 $1,000,000 per occurrence $4,000,000 aggregate W. R. Grace & Co. Comprehensive General Liability CCP 248-3440 6/30/85-6/30/86 $3,000,000 per occurrence $10,000,000 aggregate Royal Indemnity Company 1. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 2. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 3. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 4. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: w.a. eiacs t co.-com.'a mswbao mb objictzom to PULzrrrrr' rutbi rmmoe*Tomiia abb bbqobbts fob BBDDOCTIOB FBOBOBBBBB TO BirBBBAHT ia Zonolite Company Comprehensive General Liability RLG 12735 3/31/50-3/31/53 Unknown Zonolite Company Comprehensive General Liability RLG 27635 3/31/53-3/31/54 $100,000 per accident/ occurrence $200,000 aggregate Zonolite Company Comprehensive General Liability RLG 31840 3/31/54-4/1/55 $100,000 per accident/ occurrence $200,000 aggregate Zonolite Company Comprehensive General Liability RLG 035805 4/1/55-4/1/56 $100,000 per accident/ occurrence $200,000 aggregate  RECEIVED 05/Zb 11:50 199Z AT Zll/lllTVfa 85/26/92 1*143 Prttt ZZ IPKiHitU rHbE ZZ; j 5. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 6. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 7. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits; 8. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 9. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 10. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 11. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: Zonolite Company Comprehensive General Liability RLG 045762 4/1/56-4/1/57 Unknown zonolite Company Comprehensive General Liability RLG 045836 4/1/57-4/1/58 Unknown zonolite Company Comprehensive General Liability RLG 053959 4/1/58-4/1/59 Unknown Zonolite Company Comprehensive General Liability RLG 021629 4/1/59-4/1/60 Unknown Zonolite Company Comprehensive General Liability RLG 621620 4/1/60-4/1/61 Unknown Zonolite Company Comprehensive General Liability RLG 021621 4/1/61-4/1/62 Unknown Zonolite Company Comprehensive General Liability Unknown 4/1/62-4/1/63 Unknown w.s. maci t eo.-com-'* wmn # Bwienati so lunnrr'i tumi miuounuu ako uni:i roi nnwcnot ntosowwiD so pifiaoAes it l htLtiVtO Ub/<lb It.b* 13JC m tl-if-rtn/a 05/26/92 14143 rnbt cj (f-nimti/ rnoc. cj, j 12. Named insured: Type: Policy Number: policy Period: Applicable Policy Limits: Zonolite Company Comprehensive General Liability LU 1731-62 Expired 5/26/68 Unknown General Insurance Company of America 1. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: Vermieulite-Northwest, Blanket Liability BLP 270815 6/1/66-6/1/67 $250,000 Xne. Aetna Casualty And Surety Co. 1. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: 2. Named Insured: Type: policy Number: Policy Period: Applicable Policy Limits: Ari-Zonolite Company Comprehensive General Liability 33 AL 84357CC Expired 1/01/70 Unknown Ari-Zonolite Company Comprehensive General Liability 33 AL 053762 Policy in force in 1967 Unknown 3. Named insured: Type: Policy Number: policy Period: Applicable Policy Limits: Nestern Mineral Products Comprehensive General Liability 37 AL 011243 Policy in force in 1966 Unknown 4. Named insured: Type: Policy Number: Policy Period: Applicable Policy Limits: California Zonolite Company Comprehensive General Liability 33 AL 051406CC Expired 12/30/66 Unknown INTERROGATORY 25 As to the disease asbe6tosi s, state: sback t co.--con. *s umu r* as An ouBCTion to ruimrr'i nastib iiriuoumiii mo ugnni roa IMBBBIW WDWWM TO MfMMUH [RECEIVED 05/26 14:51 1992 AI 2147441776 5'26s92 14144 24 itHiltiLU l-'Ht.t Ct) j A. The date on which Defendant or ite subsidiary or predecessor first learned that such disease was caused by inhalation of asbestos fibers by humans. B. how Defendant became aware of the existence of the disease. C. who within the company first discovered, recognised or understood the adverse consequences or effects of the disease and/or of asbestos exposure. d. What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. B. Whether any such information is still maintained by Defendant or its subsidiary or predecessor in any written form. F. Who is the custodian of such information. G. The date on which you first received knowledge or information that asbestosis was caused by inhalation of asbestos fibers. ANSWER 25 Grace-Conn states that this interrogatory is vague and ambiguous in that it lacks sufficient specificity regarding type of asbestos, and the level, duration, nature, and manner of exposure. Further, this interrogatory calls for an expert opinion. INTERROGATORY 26 As to the disease lung cancer, state: A. The date on which Defendant or its subsidiary or predecessor first learned that such disease was caused by inhalation of asbestos fibers by humans. B. How Defendant or its subsidiary or predecessor became aware of the disease and its relationship to asbestos exposure. C. Who within the company or its subsidiary or predecessor first discovered or recognized the adverse consequences or effects of asbestos exposure. D. What information was disseminated within Defendant's company or it6 subsidiary or predecessor regarding such adverse consequences or effects. I. BUCK 4 CO.-COM. ' MlWill ! 21 MB OBJICTXOM TO KAXBTXPP'S HAITI! IRIUOUTOIXII AM MQVMTI POX PBODPCTlPB PBOPOBMKB TO PIP1SBAMT [ RECEIVED BS/26 14:51 1992 AT 2147441776 03/26x92 14144 FA6E IS (HhiHitD I'Abt J 25 E. Whether any such information is still maintained by Defendants or its subsidiaries or predecessors in a written form. F. who is the custodian of such information. G. The date on which you first received knowledge or information that lung cancer was caused by inhalation of asbestos dust and fibers. ANSWER 26 See the answer to Interrogatory No. 25, above. INTERROGATORY 27 As to pleural disease, pleural thickening or pleural plagues, state: A. The date on which Defendant or its subsidiary or predecessor learned such disease was caused oy inhalation of asbestos fibers by humans. B. How Defendant or its subsidiary or predeaessor became aware of the disease and that it was caused by exposure to asbestos. C. Who within the company or its subsidiary or predecessor first discovered or recognised the adverse consequences or effects of asbestos exposure. D. what information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. E. Whether any such information is still maintained by Defendant or its subsidiary or predecessor in a written form. F. Who is the custodian of such information. ANSWER 27 Grace-Conn objects to this interrogatory as vague and ambiguous in that the term "pleural disease" is undefined and subject to various interpretations. Further responding, GraceConn states see the answer to Interrogatory 25, above. INTERROGATORY 28 As to the disease mesothelioma, state: w.x. MACS 4 CO.-COM. * Mmu Ado oasscEXOM to ruxiTirri mnu zsTsaaoA*oaiis ms iioviiti fob FKOBOCTrOS WOMWBSS TO Mnmw 22 [ RECEIVED 8S/2b 14:52 1992 AT 214/441775 03/26/92 14143 2b iPKiHitu Fflbt cbj j A. The data on which Dafendant or its subsidiary or predecessor first learned such disease wss caused by inhalation of asbestos fibers by hunans. B. The date on which Defendant first suspected that mesothelioma was caused by inhalation of asbestos dust and fibers. C. How Defendant or its subsidiary or predecessor became aware of the disease and that it was caused by exposure to asbestos. d. who within the company or its subsidiary or predecessor first discovered or recognised the adverse consequences or effects of asbestos exposure. E. What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. F. Whether any such information is still maintained by Defendants or its subsidiary or predecessor in a written form. G. Who is the custodian of such information. H. Whether Defendant agrees that there is no known medical cure for mesothelioma. ANSWER 28 See the answer to Interrogatory No. 25, above. INTERROGATORY 29 As to gastro-intestinal cancer, laryngeal cancer, pharyngeal cancer or lymphatic cancer, state: A. The type of cancer and the date on which Defendant or its subsidiary or predecessor first learned that such diseases were caused by inhalation of asbestos fibers by humans. B. What cancers has the Defendant or its subsidiary or predecessor become aware can be caused by exposure to asbestos fibers? C. The date on which Defendant first suspected other cancers were caused by asbestos inhalation. D. Who within the company or its subsidiary or predecessor first discovered the adverse consequences or effects of asbestos exposure. . eaaca co .-com. ahwxu , 23 objsctxom co ruuerzrr'o lunn imiMMHOlIU AID HQWITI POE PEOPPCTIO0 PEOPOCTD1D TO ma [ RECEIVED 05/26 14:52 1992 AT 2147441776 05/'26/'92 14145 PAGE 7 (PRINTED PAGE 1) J E. What information was disseminated with Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. P. Whether any such information is still maintained by Defendant or its subsidiary or predecessor in a written form. G. Who is the custodian of such information. ANSWER 29 See the answer to interrogatory 25, above. INTERROGATORY 30 Does Defendant contend that asbestos products can be manufactured or designed so as to eliminate all potential health hazards to persons working with or exposed to them? if the answer is affirmative/ explain in detail/ and attach any studies or surveys on which this answer is based. ANSWER 30 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, Irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence. Grace-Conn further objects to this interrogatory on the grounds that it is vague and ambiguous in that it lacks specificity in many ways, including the time period, the amount and type of asbestos, the method of manufacture, whether other materials are included in the composition of the products and whether materials to bind and/or encapsulate asbestos fibers are included. INTERROGATORY 31 Describe in detail the types of packages or packaging which Defendant or any of its subsidiary or predecessor companies used for asbestos material or products, listing the dates each type of package wa6 used, a physical description of each type of package, and providing a description of any printed material or trademarks that appeared thereon. ANSWER 31 Subject to the General Objections interposed above, GraceConn states see the Product Appendix Nos. 1--35(J)- Further responding, Grace-Conn states that, to the extent that they exist, relevant, non-privileged, non-trade secret documents containing information responsive to this interrogatory will be made available to plaintiffs in Boston, Massachusetts at a mutually agreeable time. W.B. ABACS k CO.-CORN. 'I ANSWEBJ lift >4 AND OBJECTIONS TO FLAZRTXFT'B HASTEN INTNBBOOATOBIBS AND BEQUESTS ros FSOPPCTIOB BBOBOPNDEP TO DEFENDANT [ RECEIVED 85/26 14:53 1992 AT 2147441776 93^26/92 14146 rHbfc 26 (HU HIED fHbt 2B> 1 INTERROGATORY 32 Has Defendant or any of its subsidiary or predecessor companies at any time entered into a "rebranding" agreement with any other company, either as buyer or seller, concerning asbestos materials or asbestos products? If so, state, as to each such agreement: a. The name of the company manufacturing the asbestos products. B. The trade name affixed to those products. C. The periods of time covered by each such agreement. D. The volume, in dollar amount, of each transaction. E. The initial purchaser of the products. ANSWER 32 Subject to the General Objections interposed above and interpreting "asbestos materials" to mean "asbestos containing products", Grace-Conn states no. INTERROGATORY 33 List the name and address of each company from which Defendant or its subsidiary or predecessor purchased BMterials or asbestos products which Defendant sold or distributed in any form, stating the form of the materials, the dates of such purchases, and the ultimate disposal of such materials. ANSWER 33 Intrepreting "asbestos materials" to mean "asbestos containing products", Grace-Conn states not applicable. INTERROGATORY 34 Does Defendant or any of its subsidiaries or predecessor currently have possession of any writings or contracts on those rebranding agreements set forth in the answer to interrogatory No. 32? If the answer is affirmative, state: A. The name, address, and job title of each person having custody of each of those documents and their current location. B. a brief description of each such document, including the dates and the parties signatory. .*. MAC! I CO.-com.'I UIKIU Mt ouicnon to ruiirirri mru imUOUfUIU AMD KBQOIJTB FOR mOOOCTIOO FMOFQOeOlO TO DirmPAWT 29 [ RECEIVED 05/2b It: 53 1992 AT 2147*4*4177b 03/26/92 14146 PAtE 29 (PRINTED PAEE 29; j ANSWER 34 Not applicable. INTERROGATORY 35 Prior to 1968, did any parson fila a claim against a worker's Compensation carrier covering Defendant or any of its subsidiaries or predecessors alleging that he/she contracted a disease from inhaling asbestos fibers? If so, provide: A. A list of the claim, including each claimant's name, address and the date each claim was filed, and including the caption and jurisdiction of the claim. B. The disease alleged in each such claim. C. A brief summary of the disposition of each such elaim. D. The name, address and title of the person having custody of the records pertaining to each such claim. ANSWER 35 Grace-Conn objects to this interrogatory on the grounds that none of the plaintiff or decedent workers were employees of Grace-Conn and, therefore, this interrogatory is Irrelevant, immaterial and seeks information not reasonably calculated to lead to the discovery of admissible evidence. Subject to these objections and to the General Objections interposed above, GraceConn states that in 1955 an employee, possibly named Weismantle, of the California Zonolite Company, in its Sacramento, California plant, filed a claim with the State Compensation Insurance Fund in California for disability allegedly because of asbestosis. No further information is known about this possible olaim. In providing this information about the California Zonolite Company, Grace-Conn does not admit that the knowledge or activities of that company are in any way imputable to Grace-Conn. Other worker's compensation claims prior to 1968 are as follows: a. 1. William Locke; December, 1965; California. 2. Lila6 Welch; April 1967; Montana. 3. Frank G. Alviderez; September 15, 1967; California. 4. Herman Hermsen; September 11, 1967; Montana. 5. Eddie Manuel; March 1967; California. 6. Johnnie Lee Pace; 1966; Michigan. 7. Donald Zak; 1964; Minnesota. b. 1. Lung Condition. 2. Asbestosis. 3. Lung Condition. 4. Asbestosis. aacs co.-Cobb. >s mu m* MB O0JBCTIOB0 TO rUiniFf'l IU1TII imiuoeATomiBB an uovun roi tmopocTiQB Howwnwm to ponmpAST 2 [ RECEIVED 05/26 14:54 1992 AT 2147441776 8S726792 1*147 PACE 314 irumitLI rHbc. jd/ J 5. Lung Condition. 6. Occupational Disease. 7. Occupational Disease. C. 1. settlement. 2. settlement. 3. closed; no payment. 4. closed; no payment. 5. unknown. 6. settlement. 7. unknown. d. Grace-Conn states that Arthur D'Errico is the custodian of the records. In providing this information about claims resulting from the activities of the California Zonolite Company and the Western Mineral Products Company, Grace-Conn does not admit that the knowledge or activities of those companies are in any way imputable to Grace-Conn. INTERROGATORY 36 Did Defendant or any of its subsidiaries or predecessors maintain written minutes of corporate meetings, either board of directors, departmental, or otherwise, which reflect discussionspertaining to any subject matter related to asbestos, asbestos health hazards or asbestos products? If 60, for each such set of minutes, statei A. The dates of each such meeting. B. The general subject matter discussed at each meeting. C. Who was in attendance at each meeting. D. Where and by whom the written minutes are presently maintained. E. By whom the minutes were taken and put into final format. r. Whether the minutes were abstracted and reports disseminated to other individuals, and if so, the names and job titles of those individuals. ANSWER 36 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to these objections and the General .. Mutes i eo.-com.'s umu mm oincnMi to rutzsTirr'a unit xesBUHMsxotzsa ass siqvssts rot wowctiw raomron to Difiwuff 27 L nc.t-c.ivt.ij *jo/Lb it. 3*1 looi. ni tiimifio 83/26'92 14147 rnoL Ji irniflitw rnoc. 31 Objections interposed above, Grace-Conn states that to the extent that they exist, relevant, non-privileged and non-trade secret documents containing such information will be made available to the plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 37 Do you or any of your subsidiaries, including foreign business entities, currently manufacture any products containing asbestos? If so, statet a. As to each product, whether such product is mined, manufactured, and/or marketed or sold. B. The names and addresses of the companies mining, manufacturing, marketing, and/or selling each of those products. C. The trade or brand name of each of those products mined, manufactured, marketed, and/or sold. D. The date each of the named products was placed on the market. E. A description of the physical (chemical) composition of each of the named products, including the type of asbestos contained in the product. F. A description of the physical appearance of each product and its packaging. G. A detailed description of the intended uses of each of the named products. H. whether there are any warning labels on said products or containers regarding potential asbestos-related health hazards. ANSWER 37 Subject to the General Objections interposed above,. GraceConn states that it does not currently manufacture any products which contain commercial asbestos. However, Grace-Conn does currently manufacture products containing vermiculite. Products which contain vermiculite may or may not contain trace amounts of naturally occurring asbestiform tremolite. a. Subject to the General Objections interposed above, Grace-Conn states that all of the products in the product appendix were manufactured, marketed, and sold. Further responding, Grace-Conn states see the answer to Interrogatory 3, above. w.a. uui 4 eo.-eon.'i Mimti UD OBJECTIONS TO rUURTXrr' JUNTO. ISTIMOOBTOaiBN JUID HSQVSSYS FOB OOPWCTIOB fMWWWD TO P0TNNWUST 30 [ RECEIVED BS/26 14:S5 1992 AT 2147441776 05S26S92 14148 PAGE 32 (PRINTED PAGE 32) J 32 b. see the Product Appendix Nos. 23-28, 30, 33-35(b). c. See the Product Appendix Nos. 23-28, 30, 33-35(a). d. See the Product Appendix Nos. 23-28, 30, 33--35(c). e. See the Product Appendix Nos. 23-26, 30, 33-35(d). f. See the Product Appendix Nos. 23-26, 30, 33-35<g 4 j). 9` See the Product Appendix Nos. 23-28, 30, 33-35(h). h. See Answer 14, above. INTERROGATORY 38 State whether you or any of your predecessors and/or subsidiaries maintain, from 1940 through the present or for any Jortion thereof, copies of invoices, shipping documents, bills of adin^, purchase orders, or other documents of a similar nature relating to the mining, manufacture, marketing, salt or distribution of asbestos products. If so, state: A. The location of such documents. B. The name and address of the custodian of the documents. c. The format in which the documents are kept, i.e., hard copy, microfilm, microfiche, etc. d. In what form the documents can be accessed, i .e., by state, by product, etc., and if by product, whether kept according to asbestos or non-asbestos. ANSWER 38 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, Immaterial and not reasonably calculated to lead to the discovery of admissible evidence. Subject to these objections and the General Objections interposed above, Grace-Conn states that it will supplement its answer to this interrogatory on a case-by-case upon indication of exposure of a plaintiff to a specific Grace-Conn product at a specific job site or location. INTERROGATORY 39 nay you call company representatives as witnesses at the trial of any of these cases? If so, list: A. The name, address, and job title of each company representative who may be called. am . MMI l CO.-COM. >0 MWIM Oaf* OMKCTXOM TO IUOTtrr'1 HUTU nmuoaunui mo mqvuts rot MOPPCTtOO PMQPOPretP TO WPMMT 29 [ RECEIVED 85/26 14:55 1992 AT 214744177b 05/26^92 14148 FA6E 33 IPKiHTfcU t-Hbt, jjj j b. A summary of tht testimony expected to be given by each such witness. C. List any and all previous times that the named witnesses have either given deposition or trial testimony in an asbestos-related case, including the jurisdiction, style of the case, case number, date of testimony, and the name of the attorney taking the deposition for the Plaintiffs in that case. ANSWER 39 Grace-Conn has not yet decided whom it will call at the time of trial but reserves the right to do so prior to trial. Whan such decision is made, the information requested will be supplied in an appropriate manner. INTERROGATORY 40 Have Defendant or its subsidiaries or predecessors ever acquired through purchase, reorganization, or merger another corporation, company, or business which manufactured, sold, processed, distributed, or contracted or supplied products containing asbestos? If so, for each such entity, statei a. Pull and correct name; B. Principal place of business; C. State of incorporation; D. Date of acquisition by Defendant; E. Whether or not the business entity was ever authorized to transact business in the State of Texas; ANSWER 40 Grace-Conn objects to this interrogatory on the grounds that it is irrelevant, immaterial, burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to this objection and to the General Objections interposed above, Grace-Conn states the following: Grace-Conn acquired the assets of the Zonolite Company in 1963. As a result of this acquisition, Grace-Conn acquired the Superior Asbestos Company as a wholly-owned subsidiary, and a majority of the shares of the Texas Vermiculite Company. Grace-Conn also acquired a minority of the shares of Western Mineral Products Company, California Zonolite Company, Ari-zonolite Company, Tennessee Zonolite Company, and vermiculite-Northwest, Inc. The Superior Asbestos Company was dissolved in 1964 or 1965. In w.m. iucx co.-con. * i juwwm* M OSJSCT1BM TO fUIRirr'l RUfll immoauoina Aim uqniti tern. 0BODVCTIOS MOIOWIDIS TO DOTISUT so C RECEIVED S5/Zb 14: Sb 1932 HI 2147931776 3/26/'92 14149 HHtat 24 iHKIHitb rntit. jt t j 1966, western Mineral Product* was merged into Grace-Conn. Alao in 1966, Grace-Conn acquired the remainder of the outstanding stock of California Zonolite Company and Vermiculite-Northwest, Inc. Grace-Conn acquired an additional one-third interest in Ari-Zonolite in 1966. in 1967, Grace-Conn acquired the remainder of Tennessee Zonolite's outstanding stock. California Zonolite and Ve rmiculite-Northwest, Inc. wore dissolved by December 31, 1969. Tennessee Zonolite was dissolved in 1970. Grace-Conn acquired the remainder of the stock of Ari-Zonolite in 1974, and that company was dissolved effective December 31, 1974. In 1975, Grace-Conn acquired the remainder of the outstanding stock of Texas Vermiculite, and that company was dissolved. In providing this information, Grace-Conn does not admit that it assumed the liability of any of these companies, or that the knowledge or activities of these companies are in any way imputable to Grace-Conn. Relevant, non-privileged documents containing information responsive to this interrogatory will be made available to the plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 41 Was each of your asbestos products generally expected to reach, or packaged to reach, the consumer or user, without substantial change in the condition in which it was sold? If not, with respect to any such product, explain in what way the Defendant claims its products were altered or substantially changed after sale or distribution and before reaching the user. ANSWER 41 See the General Objections interposed above. Grace-Conn further objects to this interrogatory on the grounds that it is vague and ambiguous in that the term "substantial" is undefined and subject to various interpretations. INTERROGATORY 42 For each asbestos-containing product identified in response to interrogatory No. 6, identify all foreseeable users such as insulators, helpers, pipefitters, welders, machinists, plasterers, drywall finishers, carpenters, boilermakers, shipwrights and riggers, etc. of any of Defendant's asbestoscontaining products. ANSWER 42 See the General Objections interposed above. Grace-Conn further objects to this interrogatory on the grounds that the term "foreseeable" calls for a legal conclusion. w.b. asses co.--coim.* mroi i ji sn ouseriom to rbAxorirr** naitsi ibtbuumatoaxbs An ugvim fob FSOOOCTIQS FSOFOOnSO TO OlFSSOAST  RECEIVED 05/26 14)56 1992 AT 2147441776 S3/26S92 14138 PftBE 35 IPRiMTEl) RASE 35) J INTERROGATORY 43 Based upon the material content* of your asbestos-containing products, the method of manufacturing, and the method of application, can such products be generally applied without liberating asbestos fibers into the air? A. If there is a different answer concerning different products manufactured, sold, distributed, or used by your company, then specify the different products by precise manufacturer's name and popular name. B. If there is a difference in your answer depending on the year or years in which a particular product was used, then specify in detail what year or years you are referring to and the specific products you are referring to and year involved. ANSWER 43 Grace-Conn is unable to answer this interrogatory because it is incomprehensible given its unrelated premises. INTERROGATORY 44 Was it a foreseeable use of your asbestos-containing products that they may have been removed, stripped, or replaced at some time after installation? ANSWER 44 See the General Objections interposed above. Grace-Conn further objects to this interrogatory on the grounds that the term "foreseeable" calls for a legal conclusion. INTERROGATORY 45 Before 1970, did you or your subsidiaries or predeeessor(s) ever arrange for any labor inspectors, insurance company inspectors or anyone from your company to go to job sites where your products were being used or installed to make or take dust level counts? If so, state when this procedure started, the purpose of 6uch procedures, and all results of such procedures. ANSWER 45 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence. Grace-Conn further objects to this interrogatory on the grounds that it is vague and ambiguous in that the term "labor inspectors" is undefined and capable of various W.B. MUCK 4 CO.-COW. ' UMIM Bays 1] jure objbctiom to ruumrr'8 Mint xmuoMMim ud invun m BBOPUCTIOO rmPPPPMDIP TO MFWWT l RECEIVED 0b/Zb 1*:57 IH2<Z Hi <J19/vti V7b 03/26/92 i4i30 rnt>t jb (rnjnitLi i-Hbt joj j interpretations. Subject to these objections and the General Objections interposed above, Grace-Conn states not to its knowledge. INTERROGATORY 46 If Defendant performed or had performed any dust level counts, what action, based on the results, did your company take? ANSWER 46 Subject to the General Objections interposed above, GraceConn states that as a result of various considerations, including but not limited to air sampling performed by Grace-Conn personnel at its Libby, Montana mine and mill, CPD commenced plans in 1969 to close the old dry and wet mills in Libby. The new wet mill became fully operational in 1975. As a result of various considerations, including periodic dust studies performed by Grace-Conn personnel at its manufacturing facilities, plans were also commenced to cut air pollution in the Zonolite expanding plants through the use of silos, closed expansion circuits, dust collectors in furnaces, exhaust vents, and other engineering measures. With regard to the tests in the answer to Interrogatory 59, below, Grace-Conn states that the results of such testing indicated that Threshold Limit Values were within the then-existing ACGIH standards, therefore no action was required. INTERROGATORY 47 Has your company or its subsidiaries or predecessor(s) ever conducted or caused to be conducted any studies designed to assist in minimizing or eliminating the inhalation of asbestos dust and fibers by those exposed to the use of your company's products? If so, give the following: A. Name of the person or firm conducting such studies; B. The date the studies began and the date they were completed; C. Any publication or other written dissemination of the results of the studies; D. The nature of any action to eliminate or minimize the inhalation of asbestos dust fibers; ANSWER 47 Grace-Conn objects to this interrogatory on the grounds that it is misleading and argumentative in that it assumes that asbestos dust and fibers would be produced in the course of the *.*. eases t co.-com ` nnu *!] 1) * ouirim, to luimrr'i uim IRnUWTDlIII ADD BEQUEST* BOB TBOPVCTIOB WCIOMiMP TO flirS"*T [ RECEIVEO HS/Zb 19SZ Af 21** (**m rib 03^26x92 14*31 I'Hbt jt irnlnic-ij rt>c jh , use o Grace-Conn's products. Subject to this objection and to the General Objections interposed above, Grace-Conn states no. INTERROGATORY 4B Does your company have, has it ever had, or have your predecessor(s) or subsidiaries ever had, a Research Department? If so, give the year such Research Department was established, and whether or not such Research Department has operated continuously since being established. Btate also: A. The amount of time and money expended each year on research concerning asbestos or asbestos-containing products? B. what percentage of gross sales did your company or its predecessor(s) spend on research concerning the health effects of asbestos? C. State in detail the purposes, duties, and responsibilities or such Research Department. ANSWER 48 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial, . and not reasonably calculated to lead to the discovery of admissible evidence. Subject to this objection and the General Objections interposed above, Grace-Conn states that the Zonolite Company had a research division when Grace-Conn acquired the assets of Zonolite in 1963. Grace-Conn has continued the department which is now in its Construction Products Division. Grace-Conn also maintains the Washington Research Center in Columbia, MD. The Washington Research Center performs research related to all of Grace-Conn's various business units including, to a limited extent, the Construction Products Division. INTERROGATORY 49 Does your company have, or has it ever had, or have your predecessor(s) or subsidiaries ever had, a Medical Department? If so, state: A. The year such Medical Department was established) B. Whether or not such Medical Department has operated continuously since being established; C. The name of each director, chief, or head of your Medical Department year by year, beginning with the first year you had a Medical Department, and the last known address and phone number of each; *.*. MACS 6 CO.--CBM. ' AMWISS 14 mb osascTxoM to rumirr* masts* xvtbuooatoaiss amb siqobsts rom BBODOCTIOB TBOBOWIB1B TO PSFKMPABT [ RECEIVED 05/2b 1*1:50 1052 rtl tltri-iint, 3'26^92 14131 rubfc 00 (PRINTED Prtbt JU, j D. State the duties and responsibilities of such Medical Departaent. ANSWER 49 Orace-Conn states that it has never had a Medical Departaent. INTERROGATORY 50 Did your coapany or its predecessor!s) or subsidiaries ever place any warning directly on any of its asbestos-containing product or on their packaging. If so, identify the product(s) and year said warning was first applied. ANSWER 50 See Answer 14, above. INTERROGATORY 51 Did your coapany or its predecessor(s) or subsidiaries ever stamp or place the naae of the coapany, its initials, or any identifying logo on any of its asbestos-containing products? If so, please state the naae brand names of such products, a description of such stamp or logo and the dates such were placed on the referred products. ANSWER 51 No. INTERROGATORY 52 Has your coapany, or your predecessor!s) or subsidiaries, ever devised a research plan to develop, or actually developed or had developed, a product which did not contain asbestos and which could be substituted for one or more of your asbestos-containing products? If so, state the date that such research plan was begun and when 6uch asbestos-free product was first placed on the market. ANSWER 52 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to this objection and to the General Objections interposed above, Grace-Conn states that tests were begun in approximately July, 1965, to reformulate Mono-Kote (MR-3) without added asbestos fibers as a possible way to reduce costs and improve performance. Such testing continued in 1966. w.m. adace co.-com. until r| js amd nuiniMi *o fumirr'i naitia XMTHMMATOtXSS AMD UQUMM POD FDODVCTIOlt pdopommped to okpbmbamt L RECEIVED US/Zb 1**. S3 I33 Hi uimuio 5/26x92 14152 rnoc irmniu> rnoc. 39 m late 1968, California Zonolite began an attempt to eliminate asbestos from Hono-Kote (MK-3). Similar efforts were initiated at another Grace-Conn facility in June, 1969. While Monokote (KK-3) was never reformulated, it was replaced by two new substitute products, Monokote (MK-4) and (mk-5), neither of which contains commercial asbestos, mk-4 was first marketed in 1970 and HK-5 was first marketed in 1972. Grace-Conn denies that Monokote (MK-4) was fully capable of being used as a substitute product, because it did not have the full range of underwriters' Laboratories ratings which had been obtained for MK-3. versakote or Prep Coat *4 was discontinued by Grace-Conn in 1973 when Grace-Conn ceased production of all spray textured products containing commercial asbestos. A new product called Versakote, which did not contain commercial asbestos, was marketed commencing in 1973. drace-Conn currently manufactures several construction products some of which do, and some of which do not, contain vermiculite. INTERROGATORY 53 Did your company or its predecessor(s) or subsidiaries ever recall any products containing asbestos from the market or strenm of commerce? If so, Btate: A. All details of such recall; b. The name of the product recalled, including the reason for the recall and the names and current addresses of those individuals who determined that it should take place; C. The datBs of recall; D. The purpose for the recall. ANSWER 53 Grace-Conn objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to these objections and the General Objections interposed above, Grace-Conn states no. INTERROGATORY 54 Before 1970, did you ever manufacture or sell products which did not contain asbestos and which could be substituted for your asbestos-containing products? If so, state the date such asbestos-free products were first placed on the market. w.e. met i eo.com.'a umu tty, ic *t OBJICTIOMB TO rumirf'l HMTII lRiuouniiu mid gun roa W8WCTIW aaoaooaptp w dwiumt [ RECEIVEB 05/2b 14:59 199Z HI ^iieiti/Vto 3x26x92 14132 t-Htat in irninju mbi. i, j ANSWER 54 Subject to the General Objections interposed above, GraceConn states no. INTERROGATORY 55 Have any products you identified in your response to Interrogatory Nos. 52 and 54 not performed as intended? Please list all such products that have not performed as intended. ANSWER 55 See the answer to interrogatory 52, above. INTERROGATORY 56 Did your company or its predecessor(s) or subsidiaries ever make, order, or arrange for any industrial hygiene surveys regarding asbestos or asbestos-containing dust? if so, give the date of such surveys and state who, or what entity, was responsible for completion of such surveys. ANSWER 56 Grace-Conn objects to this interrogatory on the grounds thatit is overly broad, unduly burdensome, irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence. Grace-Conn further objects to this interrogatory on the grounds that it is vague and ambiguous in that the phrase "industrial hygiene surveys" is undefined and subject to various interpretations. Subject to these objections and the General Objections interposed above, Grace-Conn states that, to the extent that they exist, relevant, non-prlvileged, non-trade secret documents will be made available to plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 57 As to either the threshold limit values or maximum allowable concentrations of both asbestos dust and total dust provided by the American Conference of Governmental industrial Hygienists, state: A. The year in which Defendant or any predecessor(s) or subsidiaries were first advised of such limits or concentrations; B. The name of the employee or official of the company receiving such advice; *-*. tuct i et.-eom.'i umu si mid omiction to ruwxorirr'a iuitu IRIUDOATSUtl mid iigsun roil modpenow nwowron to bummit I tiCfkftii vttU tfd/,0 j j. i nj << ni r >u 03/26/92 MI53 i* i ri 4 rt 4 c<4> rnoc i* , 41 C. how Defendant received notice of euch limits or concentration!. ANSWER 57 Subject to the General Objections interposed above, GraceConn states that a 1956 Montana State Board of Health report to the Zonolite company, whose assets Grace-Conn did not acquire until 1963, referred to maximum allowable concentrations of dust, silica and asbestos, as recoaaended by the ACGXH, the U.8. Public Health Service, and the American industrial Hygiene Association. Grace-Conn expressly denies that this information is relevant to the subject matter of this lawsuit on attributable to Grace-Conn. Review of documents indicates that in 1968, threshold limit values were mentioned in an HEM report on air sampling done at Grace-Conn's vermiculite mine and mill in Libby, Montana. To the extent that they exist, relevant, non-privileged, non trade secret documents containing Information responsive to this interrogatory will be made available to the plaintiffs in Boston, Massachusetts at a mutually agreeable time. INTERROGATORY 58 Here the threshold limit values of maximum allowable concentrations inquired about in Interrogatory No. 63 for total du6t, and not asbestos dust alone? ANSWER 58 See the answer to Interrogatory 57, above, presuming that plaintiffs mean to refer to interrogatory No. 57. INTERROGATORY 59 State in detail what tests, if any, Defendant ever made with regard to the quantity, quality, or threshold limit values of asbestos dust or particles to which workers were exposed while using, working with or around, or installing your asbestoscontaining products. ANSWER 59 Subject to the General Objections interposed above, GraceConn states the following concerning tests conducted at GraceConn's request relating to the spraying of Mono-Rote fireproofing (MR-3)t 1. Tabershaw-Cooper Associates conducted air sampling in July, 1970, at three buildings in San Francisco. Fiber concentrations for workmen operating the spray nozzles were found to be below the then existing Threshold Limit Value for occupational exposures. *. axes co.-com. ' umu ray* u mb osjsctxom to rumwa xum IimiOMTOUII MID UQSMTI roa rmoppcTiOB ntowBuap to whumw [ RECEIVED BS/26 15: M 1992 AT 21H7441776 *3/26/92 1*133 PACE 4a (PRINTED PAGE HI) J 2. in 1970, the Wtrby Laboratory reported on air samples taken by Grace-Conn employees during Mono-Kota spraying operations in Chicago, Illinois, Los Angeles, California, Omaha, Nebraska and Bethpage, New York. Fiber concentrations were found to be well within the then existing threshold limit values set by the ACGIH. The following tests were conducted during spraying operations of Mono-Kote (MK-4) and (MK-5): 1. On February 26, 1976, Grace-Conn conducted air sampling during the application of MK-5 at the Allstate Insurance and Title Co., Irving, Texas. 2. On June 1, 1976, Grace-Conn conducted air sampling during the application of MK-4 at 60 State Street, Boston, Massachusetts. 3. On January 26, 1977, Grace-Conn conducted air sampling during the application of MK-4 at the Westminster Court Building, Westminster, California. 4. On March 2, 1977, Grace-Conn conducted air sampling during the application of MK-5 at the Jackson Hospital, Montgomery, Alabama. 5. On March 8, 1977, Grace-Conn conducted air sampling during the application of MK-4 at the Hyatt Regency, Dallas, Texas. 6. On March 9, 1977, Grace-Conn conducted air sampling during the application of MK-5 at the Imperial Savings and Loan Office Building,. San Diego, California. 7. On March 10, 1977, Grace-Conn conducted air sampling during the application of MK-4 at the South County Hall of Justice, Fremont, California. 8. On March 11, 1977, Grace-Conn conducted air sampling during the application of MK-4 at the California federal Savings k Loan, Burbank, California. 9. On May 3, 1977, Grace-Conn conducted air sampling during the application of MK-4 at the Union Bank & Trust Co., Kokomo, Indiana. 10. On June 2, 1977, Grace-Conn conducted air sampling during the application of Mono-Kote, type unknown, at an unknown iob site, by pandol & Sons, applicators, Delano, California. Investigation continues for additional information concerning this test. w.x. cun ca.-com.'f jumwiu and NJienen to ruimrri maitu imuoumiH and uonm pox WOWCTtW PXOPOOMDSP TO PKPKMPAMT n l ntuti tfa/.o xa.ai idzl. i tn'iiinu 95/26/92 14154 i rtat i n i A i t*v riuc, i-> / 43 11. On April 26, 1963, Gract-Conn conducted air sampling during the application of MK-5 at the Westshore Office Building, Harrisburg, Pennsylvania. 12. On June 3, 1965 Grace-Conn conducted air saapling during the application of HR-5 at 599 Lexington Avenue, New York, New York. 13. On June 19, 1965, Grace-Conn conducted air samplings during the application of HK-5 at 53rd Street and 3rd Avenue, New York, New York. 14. On July 30, 1985, Grace-Conn conducted air saapling during the application of mk-5 at the Allied Bank Tower, Dallas, Texas. 15. On April 15, 1986, Grace-Conn conducted air saapling during the application of MK-5 at 10 South LaSalle Street, Chicago, Illinois. 16. On April 16, 1966, Grace-Conn conducted air saapling during the application of MK-5 at 190 South LaSalle Street, Chicago, Illinois. 17. On April 17, 1986, Grace-Conn conducted air saapling during the application of MK-5 at the Corporetua Office Complex, Lisle, Illinois. 18. On June 18, 1986, Grace-Conn conducted air saapling during the application of MK-5 at Concourse B, Stapleton Airport, Denver, Colorado. Fiber concentrations in all spray areas at each job site listed above were found to be well'below the then existing Threshold Liait Value for occupational exposure. INTERROGATORY 60 Pleaae state the following with respect to each expert witness you that you nay call during trial of these cases. Please designate with specificity the expert witnesses that you will call, including: (a) The name, address, and job classification of each such expert witness; (b) The subject matter on which the expert is expected to testify; (c) The substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion; *.*. SBACB t CO. -COMB. OBSITUS hp 40 MM UJICflMS TO tLAZSTIFF'S HOSTU ibtxmooatoxibs ui axemen roi wwwcnwi >m>bbwi to Mneaw l RECEIVED (IS/Zb lb. HI lbbl i 4iimiab 83/26/92 14135 rmc irniAiLb rnoL j (d) Whether any person identified in subparagraph (a) above has provided a report or other documentation to you, and if so, identify each such document or report; (e) Identify all documents that you have provided to each person identified in response to subparagraph (a) above; (f) Describe in detail the education and work history of, and identify any books, treatises, articles, published and unpublished reports, studies or other scholarly works authored by any individual identified in response to subparagraph (a) above. Alternatively, in lieu of said response, attach a copy of a resume or curriculum vitae and a list of publications to your answers. ANSWER 60 Grace-Conn has not yet decided whom it will call at the time of trial but reserves the right to later supplement these Interogatories prior to trial. When such decision is made, the information requested will be supplied in an appropriate manner. INTERROGATORY 61 Please state the name, present address and present telephone number, along with the experience and qualifications, if applicable, of each and every person, known to Defendant or to Defendant's agents, having knowledge of facts relevant to these cases involving, but not limited to: (a) identification of asbestos-containing products to which each and every individual Plaintiff, separate and distinct from all other Plaintiffs within the group, allegedly was exposed or facts disputing the identification of asbestos-containing products in this case. (b) Each and every individual Plaintiff's, separate and distinct from all other Plaintiffs within the group, alleged damages, Injuries and/or facts disputing each and every Plaintiff's alleged damages and/or Injuries; (c) the negligence of any person or entity other than Defendant which Defendant contends was a cause of each and every individual Plaintiff's, separate and distinct from all other Plaintiffs within the group, alleged injuries and/or damages; (d) each of Defendant's defenses enumerated in Defendant's last filed Answer in each of these cases. **. e>ACB i CO.-COM.'S JUMWIM avb objection to rukxarxrr' kutix nmuunuu ut utniTi rax BBoowCTtoe eeoeooeaie to esrisiuuw  RECEIVED flS/Eb 1S.H2 iaa<: Hi tit rtn < tt* 3^26/92 14155 rntaC 13 rrttat 10 / ANSWER 61 Defendant Grace-Conn objects to the portion of this interrogatory which requires information regarding the experience and qualifications of any persons listed in response to the interrogatory as such information is not discoverable under Tex. R. Civ. P. 166(b)(2)(d). Defendant Grace-Conn further objects to the form of this interrogatory as it invades the attorney work product exemption by requesting witnesses' names to be broken out by category. Without waiving the foregoing objections, with regard to identity and location of persons with knowledge of relevant facts, Defendant Grace-Conn at this time is only able to designate plaintiffs. Discovery is continuing, and such response will be supplemented pursuant to Tex. R. Civ. P. 166(b)(6). INTERROGATORY 62 Please identify documents which will be used at time of trial, (Exhibit List, Deposition List), which are relevant to each of Defendant's enumerated defense in Defendant's last filed Answer. ANSWER 62 Defendant Grace-Conn objects to this interrogatory as being . overly broad and unduly burdensome. Defendant Grace-Conn further objects to this interrogatory as it invades the attorney work product exemption, attorney-client privileges and party communication exemption. Purhter, such interrogatory is designed to circumvent Tex. R. Civ. P. 167. INTERROGATORY 63 Please state when you first received a copy of the Fleischer/Drinker Report published in 1945/1946. ANSWER 63 Grace-Conn states that it is unaware of when it first became aware of this article, except that it appears to have been in recent years. REQUE8T rOB PRODOCTION REQUEST 1 Please produce a true and correct copy of each photograph of each asbestos-containing product identified in answer to Interrogatory No. 4. w.m. suet co.-con. umu un oMcesoei to rumirr'i iuitii mmieumiii mb asQoiava pm *mot>CTos amorowapap to wnimr <2 1. RECEIVED MS/2b lb.Mb 1 33E Hi Elt<'1tl//D 0SS26S92 t * I 36 rHbt. id irniim.i/ rHbt id/ j RESPONSE 1 Subject to the General Objections interposed above, GraceConn states that to the extent they exist, relevant, nonprivileged, non-trade secret documents responsive to this request will be made available to the plaintiffs in Boston, Massachusetts at a mutually agreeable time. REQUEST 2 Please produce any diagrams or schematics indicating, stating or detailing the existence of any of your subsidiaries, predecessors, or divisions as defined on Page 1 of these interrogatories and Request for Production. RESPONSE 2 Subject to the General Objections interposed above, GraceConn states that to the extent they exist, relevant, nonprivileged, non-trade secret documents responsive to this request will be made available to plaintiffs in Boston, Massachusetts at a mutually agreeable time. N.R. GRACE t CO.-CONN By its attorney, DATEDi State |ar No. 04294520 Mehaffy & Weber mtteerrfflrst Tower 2615 Calder Avenue P.0. Box 16 Beaumont, TX 77704 (409) 835-5011 w.. iu co.-com. Mimt * outanii to lumxrr'i iujtu iaTsmooauoBZio on UQVMva ros WOWtCTlW WBWWBM TO Ufmm o [ RECEIVED 05/26 15:13 1992 fll 214 mi 77b 5"26'92 t5>96 Prttit (HhlNltu f-Hbt. t- > j PRODUCT APPENDIX COMMERCIAL ASBESTOS-CONTAINING PRODUCTS 1. a. Econo-White 65 and Econo-White 70. b. Zonollta Company (1956-1963); Grace-Conn (1963 until approximately 1970). e. 1956 by Zonollta Company; 1963 by Grace-Conn. d. Chemical Compoeltlom Short fiber chrysotlle asbeatoa, Perlite, Bentonite (Montmor11Ionite type). Titanium dioxide, Sodium lauryl sulfate. Contained approximately 14.97 percent and 14.43 percent 7M asbestos, respectively, by weight. e. Approximately 1970. f. Lack of market. g. White acoustical plaster. h. Acoustical plaster for walls and ceilings. 1. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) North Little Rock, Arkansas; 1956-1968. (2) Sacramento, California. (3) Dearborn, Michigan. (4) Omaha, Nebraska. (5) Trenton, New Jersey. (6) Albany, New York. (7) Ellwood City, Pennsylvania; made for a two-year period, late 1950's or early 1960's. (8) Travelers Rest, South Carolina. (9) Kearney, South Carolina. (10) Dallas, Texas. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. k. Grace-Conn did not manufacture an asbestos free substitute for this product. .*. iulcs co--com. * a umu m* l ut oancntu w KAXimrr's mnu mnu UTUMMT9M m. u m utnitui mnwmon w. m woworom to wwomt [ RECEIVED 05/26 15:13 1992 AT 211/H417?b 05/26x92 15106 ------------------- rn--------------- : eubt. J W-H1HIC.U rHbL J/ J i 2. a. Zono-Coustic 2 and Zono-Coustic Z. b. Zonolite Company (1960-1963); Grace-Conn (1963 until approximately 1973). c. 1960 by zonolite Company; 1963 by Qrace-Conn. d. Chemical Composition: Short fiber ehrysotile asbestos, Vermiculite, Titanium dioxide, Sodium lauryl sulfate. Plaster of Paris, Hydrated lime. Contained approximately 12.64 percent 7M asbestos by weight. e. Approximately 1973. f. Lack of market. g. Off-white acoustical plaster. h. Acoustical base coat for walls and ceilings. i. The product was manufactured at some or all of the plants listed below, where approximate dates of production are known, they are also listed. (1) Worth Little Rock, Arkansas; 1961-1962. (2) Los Angeles, California. (3) Newark, California; 1970-1973. (4) Sacramento, California. (5) Wilder, Kentucky. (6) Dearborn, Michigan. (7) st. Louis, Missouri.(8) Omaha, Nebraska. (9) Trenton, New Jersey. (10) Albany, New York. (11) Portland, Oregon; 1960's. (12) Ellwood City, Pennsylvania. (13) Travelers Rest, South Carolina, 1959-1963. (14) Kearney, South Carolina. (15) Dallas, Texas. (16) Spokane, Washington; 1959-1962. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. k. Grace-Conn did not manufacture an asbestos free substitute for this product. w.a. (MCI 6 c*.-com.>0 JJMWSM 2 an oMScrsem *o rbURirr'i mhd ruth imueuTMT ae. n u> uimoiu IWWieWTOW WO. C4 W8WBTO6 TO DWrWWBAMr [ RECEIVED BS/26 15:1** 1992 AX 21 **?****177b 05^26^92 13107 r*L ** (HHIKIED ^Hbt i / j 3. a. Zonolite Acoustical Plastic/Plaster. b. Zonolita Company (approximately 1945 until 1963); GraceConn (1963 until approximately 1972). c. 1945 by Zonolite Company; 1963 by Grace-Conn. d. Chemical Composition; (Standard) Short fiber chrysotile asbestos, Vermiculite, Bentonite (montmorilIonite type), Sodium lauryl sulfate. Contained approximately 17.11 percent 7M asbestos in standard acoustical plaster. Bermuda Tan: short fiber chrysotile asbestos, Vermiculite, Bentonite (montmorlllonite type), Sodium lauryl sulfate, Dowlcide, Sodium nitrite. Contained approximately IB.69 percent 7M asbestos by weight in Bermuda Tan. e. Approximately 1972. f. Lack of market. g. Light beige acoustical plastic. h. Acoustical coating for ceilings. i. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) Birmingham, Alabama. (2) Phoenix or Glendale, Arisona; 1959-early 1970's. (3) North Little Rock, Arkansas; 1951-mid 1960's. (4) Los Angeles, California; 1951-early 1970's. (5) Sacramento, California. (6) Denver, Colorado; 1952-1959. (7) Tampa, Florida; 1950's-1967. (B) Easthampton, Massachusetts. (9) North Billerica, Massachusetts. (10) Dearborn, Michigan. (11) Minneapolis, Minnesota; 1949-1962. (12) St. Louis, Missouri. (13) Omaha, Nebraska; 1962-1970. (14) Trenton, New Jersey; 1964. (15) Albany, New York. (16) Portland, Oregon. (17) Ellwood City, Pennsylvania; 1946-1960. (18) Travelers Rest, South Carolina; 194B-1963. (19) Kearney, South Carolina. (20) Dallas, Texas; 1973. (21) Spokane, Washington; 1945-early 1970's. (22) Milwaukee, Wisconsin; made until 1971, beginning date unknown. w.a. umi c.-con. > juuweaa > Jure oijicmow to ruiRirr'i jumbmo mnn imuouron n. u jure uohimu mcnooAToaT n. u nowww to nnmun t RECEIVED BS/Zb 15:14 1992 AT 214744177b 05/26^92 1S t 87 PAGE S (PRINTED PAGE " 5) j j. This product was packaged in multi-walled, paated-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. k. Grace-Conn did not manufacture an asbestos free substitute for this product. 4. a. Zonolite Finish Coat (Decorator's White). b. zonolite Company (1950-1963). First produced by GraeeConn in 1963; the product may have been produced until 1974. c. 1950 by Zonolite Company; 1963 by Grace-Conn. d. Chemical Composition: Short fiber chrysotlle asbestos, Vermiculite, Bentonite (montmorillonite type), Titanium dioxide, Sodium lauryl sulfate. Contained approximately 13.11 percent 7M asbestos by weight. e. Product may have been produced by Grace-Conn until 1974; information indicates that asbestos was deleted by 1973. f. Lack of market. g. white textured cementitious finish. h. Decorative textured cementitious finish. 1. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) Los Angeles, California. (2) Sacramento, California. (3) Denver, Colorado; 1952-1965. (4) Pompano Beach, Florida; 1971-1974. (5) Wilder, Kentucky. (6) Easthampton, Massachusetts. (7) Dearborn, Michigan. (6) Trenton, New Jersey. (9) Albany, New York. (10) Portland, Oregon. (11) Travelers Rest, south Carolina; 1950's. (12) Dallas, Texas; 1973. (13) Spokane, Washington. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft >.i. esses co.-cess.'s umu 4 mo ouicnon to fumur'i mu masts* iitmoaxTsiT *o. ! am* aooitxomas. 1MTSSMOQATOAT W. 04 WOWO0BW TO OWSSPAOT [ RECEIVED BS/Z6 lb:ZB 199Z AT Z147441776 05 S26/92 161 13 PAGE 1 (PRINTED PAGE 1) j 01 paper, vhieh la prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. k. Grace-Conn did not Manufacture an asbestos-free substitute for this product. 5. a. Zonolite Finish Coat (Decorator's white)(Extra Bard). b. zonolite Company (1961-1963). First produced by GraceConn in 1963; product nay have been produced until approximately 1974. c. 1961 by Zonolite Company, 1963 by Grace-Conn. d. Chemical Composition: Short fiber chrysotile asbestos, Vermlculite, bentonite (montmorillonits type). Titanium dioxide. Sodium lauryl sulfate. Contained approximately 12.78 percent 7H asbestos by weight. e. Product may have been produced by Grace-Conn until 1974; Information indicates that asbestos was deleted by 1973. f. Lack of market. g. White textured cementitious finish. h. Decorative textured cementitious finish. i. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) Los Angeles, California. (2) Sacramento, California. (3) Denver, Colorado. (4) Pompano beach, Florida; 1971-1974. (5) Wilder, Kentucky. (6) Basthampton, Massachusetts. (7) Dearborn, Michigan. (8) Trenton, New Jersey. (9) Albany, New York. (10) Portland, Oregon. (11) Travelers Rest, South Carolina. (12) Dallas, Texas. (13) Spokane, Washington. j. This product was packaged in multi-walled, pasted valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. >.> mci ce.-eon. <0 umu 5 oijicTjoii to ruimrr'i amsrow mru tniMMIR M. 03 ARP APOZTXOSAS IRTRMtOeATORT RO. 00 MOIWIBIP TO P0P1RPAMT RECEIVED 05/26 15:23 1992 AT 2147441776 3/26S92 13116 HA6 2 IPHtHIEb HA6E 2> J k. Grace-Conn did not manufacture an asbe*tos-free substitute for this product. 6. a. Zonolite Spra-Tex (Regular). b. Zonolite Company (approxiaately 19SS to 1963); Grace-Conn (1963-1972). c. 1955 by Zonolite Company; 1963 by Grace-Conn. d. Chemical Compositioni Short fiber chrysotile asbestos, Veraiculite, Kaolin clay, Titanium dioxide. Sodium lauryl sulfate. Contained approximately 33.045 percent 7M asbestos by weight. e. 1972. f. Lack of market. g. White decorative celling finish. h. Decorative textured finish. i. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) North Little Rock, Arkansas; may have been made after 1961. (2) Los Angeles, California. (3) Sacramento, California. (4) Pompano Beach, Florida. (5) Wilder, Kentucky. (6) New Orleans, Louisiana. (7) Omaha, Nebraska. (B) Trenton, New Jersey. (9) Albany, New York. (10) Ellwood City, Pennsylvania; 1957-1963. (11) Travelers Rest, South Carolina. (12) Kearney, South Carolina. (13) Spokane, Washington. j. This product was packaged in multi-walled, pasted-valva bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. k. Grace-Conn did not manufacture an asbestos free substitute for this produet. >.i. macs co.-com.'s Mimu tap* c at osjicrxom to tuiRirr'i aksspkd aajtbs rSTIABOOATOBT so. <1 Am ADPITlOMUb nwiMwow wo. rsorovspip to pkfksoast l RECEIVED 05/26 15. ZZ 199Z AT 2197991/76 S/26/92 15115 KHbt i It'KiMfcb KHDt 1 I J 92 7. a. Zonolite Spra-Tex (Extra-Hard). b. Zonolita Company (1961-1963); Grace-Conn (1963-1972). c. 1961 by Zonollt# Company; 1963 by Grace-Conn. d. Chemical Compoaition: Short fiber chrysotile asbestos, Kaolin clay, Titanium dioxide, Sodium lauryl sulfate, Vermiculite, ZOO concentrate. Contained approximately 32.09 percent 7H asbestos by weight. e. 1972. . Lack of market. g. white textured ceiling finish. h. Decorative textured finish. i. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) North Little Rock, Arkansas. (2) Los Angeles, California. (3) Sacramento, California. (4) Pompano Beach, Florida. (5) Wilder, Kentucky. (6) New Orleans, Louisiana. (7) Omaha, Nebraska. (8) Trenton, New Jersey. (9) Albany, New York. (10) Bllwood City, Pennsylvania; 1961-1963. (11) Travelers Rest, South Carolina; 1961-1963. (12) Xearney, South Carolina. (13) Spokane, Washington. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically. National Motor Freight Classification 100-1. k. Grace-Conn did not manufacture an asbestos free substitute for this product. B. a. Z-Tex, may also be marketed as EZ-Tex, E-Tex 2 and Z-Tex 2 Super White. b. The zonolite company (from approximately 1958 to approximately 1962). w.x. iun k ce.-coes.'s umu i ASP OSJBCTIOM TO tUUSTITF'S AMBDED MMTSX IRUMUmi PO. 6> MB MDSTXOBM. hhmwmww so. n nwowron to whimh [ RECEIVED 05/26 15:23 1932 ft! *117111//b 02/26S92 13)16 rHbc. j \rtiimtu rnt>L ^ i j 03 i c. 195S. d. Chemical Composition! Exact composition unknown at this time. The product contained approximately 14.3 percent short fiber chrysotile asbestos, investigation continues. e. 1962. f. Lack of market. g. white or beige sprayed texture product. h. Sprayed texture product. i. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) North Little Rock, Arkansas. (2) Sacramento, California. (3) Pompano Reach, Florida. (4) wilder, Kentucky. (5) St. Louis# Missouri. (6) Trenton, New Jersey. (7) Albany, New York. (6) Travelers Rest, South Carolina. j. This product was packaged in multi-walled, pasted valve bags constructed of two 60-pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically. National Motor Freight Classification 100-1. k. Grace-Conn did not manufacture an asbestos free substitute for this product. 9. a. Perltex Super-40 Fog. The product may have been sold under the following name at various times: Perltex Fog. Grace-Conn believes that the product may have been produced and sold under the alternative name prior to b. Western Mineral Products until 1966; Grace-Conn (1966 until approximately 1973). c. This was a western Mineral Products product. Grace-Conn manufactured the product from the time it acquired Western Mineral Products in 1966. d. Chemical Composition: Short fiber chrysotile asbestos. Talc, Whiting, staramic, Dowicil, Methocel, NTA, Daxad- w.i. eases i eo.-cen.'s uum a An tuienm to iuiitxw*i mums Mim IVTBMOOATOftT NO. < J on ADDITIONAL lenaaooAToar no. eaoTownwo to oanePAet [ RECEIVED 05/2b IS: 24 1992 AT 219/41177b 03S26S92 13<17 tHbt t irtil/lic,u rhbc 04 17, Titanium dioxide. Ultramarine blue. Contained approximately 5.5 percent short fiber chrysotile asbestos by weight. e. 1973. f. This product was discontinued in 1973 in accordance with Grace-Conn's decision to discontinue production of all Perltex textured products containing commercial asbestos. 9- White or beige base coat. h. Base coat for decorative textured finish. 1. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) Pompano Beach, Florida; after 1971. (2) Omaha, Nebraska; before 1972. 3* This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed oy the transportation industry, specifically. National Motor rreight Classification 100-1. k. Grace-Conn produced and sold Zonolite Super-40 FOG, a texture product formulated without commercial asbestos. 10. a. Perltex Super-40 Perlite. b. Western Mineral Products until 1966; Grace-Conn <1966 until approximately 1973). c. This was a Western Mineral Products product. Grace-Conn manufactured the product from the time it acquired Western Mineral Products in 1966. d. Chemical Composition; Short fiber chrysotile asbestos, Casein, Trisodium phosphate, Dowicil, Sodium nitrite, Methocel, Whiting, Perlite aggregate, Lithopone, NTA, Staramic. Contained approximately 7 percent short fiber chrysotile asbestos by weight. a. 1973. f. The product was discontinued in 1973 in accordance with Grace-Conn's decision to discontinue production of all Perltex textured products containing commercial asbestos. g. White or beige textured finish product. v.a. umi i co.-con. >a uinu ray* f am minim to fumirr'i amdid mitu iriumatoit mo. ai ns adoxtiowu. utiuiwwmt to. ii ummn to mwimw [ RECEIVED BS/2b lb: 24 1S32 HI ^14 /til Tib 05/26x92 15:17 t'Rfait b (PH INTED rribL b; J B5 h. Decorative textured finish. i. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) Pompano Beach, Florida; 1972-1973. (2) Omaha, Nebraska; mid-sixties. (3) Dallas, Texas. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. k. Grace-Conn produced and sold Zonolite Super-40 Perlite, a texture product formulated without commercial asbestos. 11. a. Perltex Super-40 Polycoarse. The product may have been sold under the following alternative trade name: Perltex Polycoarse. Grace-Conn believes that the product may have been produced and sold under the alternative name prior to 1966. b. Western Mineral Products until 1966; Grace-Conn (1966 until approximately 1973). c. This was a Western Mineral Products product. Grace-Conn manufactured the product from the time it acquired western Mineral Products in 1966. d. Chemical Composition: Short fiber chrysotile asbestos, Whiting, Talc, Staramic, Lithopone, Methocel, Dowicil, Daxad-17, Ultramarine blue. Polystyrene aggregate, NTA. Contained approximately 5 percent short fiber chrysotile asbestos by weight. e. 1973. . This product was discontinued in 1973 in accordance with Grace-Conn's decision to discontinue production of all Perltex textured products containing commercial asbestos. g- White or beige textured product. h. Sprayed texture product. 1. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. w.a. mi t eo.-con. >j uinu ays i an oMicTioii m nunirr'i juami luavsm mrmotuoM eo. > abb amitioui wxnosATQKT eo. < fiowmpn to pirnmrr [ RECEIVED 05/26 15: 2S 1932 ftT 2137311771, 13/26x92 13118 fhUt b irttlrtitu rt>t o/ J 06 (1) Pompano Beach, Florida; 1972-1973 (2) Omaha, Nebraska; mid-aixtie-1972. j. This product was packaged in multi-walled, pasted-valve begs constructed of two 60-pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. k. Grace-Conn produced and sold Zonolite Super-40 Polycoarse, a texture product formulated without commercial asbestos. 12. a. Perltax Super-40 SAV. b. Western Mineral Products until 1966; Grace-Conn (1966 until approximately 1973). c. This was a Western Mineral Products product. Grace-Conn manufactured the product from the time it acquired Western Mineral Products in 1966. d. Chemical Composition: Short fiber chrysotile asbestos, Casein, Trisodium phosphate, bowicil, Methocel, 8odium . nitrite, whiting, South African varmiculite aggregate, Lithopone, Staramic, NTA. Contained approximately 6.0 percent short fiber chrysotile asbestos by weight. e. 1973. f. This product was discontinued in 1973 in accordance with Grace-Conn's decision to discontinue production of all Perltex textured products containing commercial asbestos. g. White or beige textured finish. h. Decorative textured finish. i. The product was manufactured at some or all of the plants listed below, where approximate dates of production are known, they are also listed. <1) Pompano Beach, Florida; 1971-1973. (2) Omaha, Nebraska, mid-sixties-1972. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60-pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically. National Motor Freight Classification 100-1. .!. iui t eo.-eoae.a8 umu u BSO OBJECTIONS TO PLAXBTirr' AMEBOID HASTES tSTERBOSATOBI BO. 8} AMD ABDXTZOBAL . IBTBBBOSATOBT BO. El WOfOBBH TO DEMBOABT t RECEIVED 05/26 15:25 1932 (IT 21474*U77b 05^26^92 15118 PA6E 7 (PRINTED PACE 7; j 07 k. Grace-Conn produced and sold Zonollte Super-40 BAV, a texture product formulated without commercial asbestos. 13. a. Perltex Spray Surfacer. This product may have been sold under the following alternative trade namest Plastertax, Perltex Super-40 Spray Surfacer or Perltex Super 40. b. Western Mineral Products until 1966; Grace-Conn (1966 until approximately 1973). c. This was a Western Mineral Products product. Grace-Conn manufactured the product from the time it acquired Western Mineral Products in 1966. d. Chemical Composition: Chrysotile Asbestos, Lithopone, Pyrophyllite, Whiting, Casein, Mica AA, Mica XX, Kaoloid clay, Soya Flour, Tri Sodium Phosphorous, RA 47 Titanium, Snow Flake Lime, Dowicide G., Calcium Sterrate, Sodium Nitrate, Perlite. Contained approximately 6-11% 7TF1 or 7Rr9 chrysotile asbestos by weight. e. Approximately 1973. f. This product was discontinued in 1973 in accordance with Grace-Conn's decision to discontinue production of all Perltex textured products containing commercial asbestos. g. Product was a texture product, applied over board, concrete, metal or plaster, white in color. h. Spray texture coating. i. The product was manufactured at one or both of the plants listed below. Approximate dates of manufacture are also listed. (1) Pompano Beach, Florida; 1971-1973. (2) Omaha, Nebraska; before 1972. j. This product was packaged in multi-walled, pasted valve bags constructed of two 60-pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight classification 100-1. k. Unknown 14. a. Perl-Coustic b. Western Mineral Products until 1966; Grace-Conn (1966date unknown; Grace-Conn currently has no evidence that this product was manufactured after 1973). imi i co.-com.'s Mimas u mb OMicTioaa *o tumirr'i mhhd unn imuounil OO. (I MO moxtioial laTSKBOOXTOBT ao, M IPOTOOPPIP TO WTItMlT [ RECEIVED BS/Zfc IS:2C 1992 AT 21H7HH177E 3'26s92 13119 PACE 6 (PRINTED PACE tij J 08 c. This was a Western Mineral Products product. Grace-Conn manufactured the product from the time it acquired Western Mineral Products in 1966. d. Chemical Composition! Short fiber chrysotile asbestos, Perlite, Bolka-Floc BW-20, Bentonite, Sodium Nitrite, Dowieide G, Naconal DB Beads. Contained approximately 15-17% 7M asbestos by weight. e. unknown. However, Grace-Conn currently ha6 no evidence that the product was manufactured after 1973, when GraceConn ceased the production of all acoustical plaster products containing commercial asbestos. f. Unknown. However, Grace-Conn currently has no evidence that the product was manufactured after 1973, when GraceConn ceased the production of all acoustical plaster products containing commercial asbestos. g. Acoustical Plaster. h. Acoustical rinish Coat. 1. The product was manufactured at the plants listed below; Approximate dates of production are unknown. (1) Omaha, Nebraska. (2) Milwaukee, Wisconsin. j. This product was packaged in multi-walled, pasted valve bags constructed of two 60-pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor rrelght Classification 100-1. k. unknown. 15, a. Prep-Coat #3 b. Western Mineral Products until 1966; Grace-conn (1966date unknown; Grace-Conn currently has no evidence that this product was manufactured after 1973). c. This was a Western Mineral Products product. Grace-Conn manufactured the product from the time it acquired Western Mineral Products in 1966. d. Chemical Composition: Short fiber chrysotile asbestos. White cement. Calcium Carbonate, vermiculite. Finish Lime Double Hydrated, Perlite. Contained approximately 4-5% asbestos by weight. w.a. eases m.-om.'e umu ny u an ouienwi ye numrr>i unnu nim imuouTwi no. ci see additional immwMoii no. fmwwiwd to mwimit [ RECEIVED 85/2S 15:2b 1992 AT 21171417/6 83/26792 15119 rn a U'himc.u rnsc 3/ J e. Unknown. However, Grace-Conn believes that the date was approximately 1972. C. Unknown. However, Grace-Conn currently has no evidence that the product was manufactured after 1973, when GraceConn ceased the production of all sprayed textured products containing commercial asbestos. g. Investigation continues. h. Believed to be a decorative exterior finish. 1. The product was manufactured at the plant listed below. Approximate dates of production are unknown. (1) Omaha, Nebraska. j. This product was packaged in multi-walled, pasted valve bags constructed of two 60-pound pllesof natural kraft paper, which is prescribed by the transportation Industry, specifically. National Motor Freight Classification 100-1. k. Unknown. 16. a. Versakote or Prep Coat #4. b. Western Mineral Products until 1966; Grace-Conn (1966 to present). c. This was a Western Mineral Products product. Grace-Conn manufactured the product -from the time it acquired Western Mineral Products in 1966. d. Chemical Composition; Short fiber chrysotile asbestos. Aluminum stearate, Gelvatol, Hamaco, Daxad-17, Darex set accelerator, Nopco PD-1, Aluminum hydrate, Dowicil, Whiting, White portland cement. Perlite aggregate, Titanium dioxide, Hydrated lime. Contained approximately 4.52 percent short fiber chrysotile asbestos by weight. e. This product has not been withdrawn from the market; since 1974, no asbestos has been used in this product. f. Not applicable. g. White or beige textured finish. h. Very hard, decorative textured exterior finish. j. The product was manufactured at some or all of the plants v.i. nui co.-coax. miui i mio ouimni to tLMOTzrr's unnt mmi IRmotUMT BO. Cl UV ADDITXOOM. iwmwTMT oo. <4 moFOPQPKP to oiriaoiurr C RECEIVED B5/2b 15:27 1992 ftT 2147H>1177b 95/26^92 1S>29 t'Htit id (t'Him't.U t-Mbt lUi j ie listed below, where approximate dates of production are known, they are also listed. (1) Pompano Beach, Florida; 1972-1973. (2) Omaha, Nebraska; 1972. k. This product was packaged in multi-walled, pasted valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation Industry, specifically, National Motor Freight Classification 100-1. 1. A product called versakote has been manufactured without commercial asbestos since 1974. 17. a. Spra-Wyt. b. Western Mineral products until 1966. Manufactured by Grace-Conn from 1966 until a time unknown, but believed to be not later than 1973. c. This was a Western Mineral Products product. Grace-Conn manufactured the product from the time it acquired western Mineral Products in 1966. d. Chemical Composition: 7M Asbestos, Bentonite, Titanium dioxide, Hydrated lime, Duponol, Perlite. The percentage of asbestos is unknown at this time. e. Exact discontinuance date unknown, but not later than 1973. f. Unknown. g. Acoustical plaster, color unknown. h. Acoustical finish coat. i. The product was manufactured at some or all of the plants listed below. Approximate dates of production are not known. Investigation continues. (1) Denver, Colorado. (2) Minneapolis, Minnesota. (3) Omaha, Nebraska. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically. National Motor Freight Classification 100-1. .. *uci i co.-con. * umm it AMD ouicnow to rfcumrr<i jmmhd uihi iRtesoeurocy no. > ui uditioiu wssaosaeoaT wo. h nonwrap to timtm [ RECEIVED BS/Zb IS:27 1392 fU 219799177b *5^26/92 13120 ii If-Klfutu f-Htac "/ J IB. ft. Hi-Sorb Acoustical Piaster. 11 b. Western Mineral Products until 1966. Manufactured by Grace-Conn from 1966 until a date unknown, but believed to be not later than 1973. c. Originally produced by Western Mineral Products under license from Highland Stucco and Lime Products, Inc., Van Nuys, California. First manufactured under license by Grace-Conn in 1966. d. Chemical Composition: (XX White Hi-Sorb) Short fiber chrysotile asbestos. South African Vermiculite, Perlite, Plaster of Paris, Bentonite, cal. Concentrate, Titanium, Drywall Additive. Contained approximately 8-10% 7M asbestos by weight in XX white Hi-Sorb. (Oyster white Hi-Sorb) Short fiber Chrysotile asbestos, South African Vermiculite, Vermiculite, Plaster of Paris, Bentonite, Cal. Concentrate, Drywall Additive. Contained approximately 8-101 7M asbestos by weight in Oyster White Hi-Sorb. e. Exact discontinuance date unknown, but not later than 1973. f. Unknown. g. Textured ceiling plaster, oyster white; also available in color variations. h. Acoustical plaster. i. The product was manufactured at some or all of the plants listed below. Approximate dates of production are not known. Investigation continues. (1) Denver, Colorado. (2) Minneapolis, Minnesota. (3) Omaha, Nebraska. j. This product was packaged in multi-walled, pasted valve bags constructed of two 60-pound plies of natural kraft paper, which is prescribed by the transportation industry. Specifically, National Motor Freight Classification 100-1. k. Unknown. 19. a. High Temperature Insulating Cement. v.i. mci eo.*cem.>i Mmu r>a it M tulCTiou *o numrr'i inmn nui iersuoejAOftY eo. <> jure uomoni mmoMww w. towwiwb to wfiimw [ RECEIVED HS/Zb 15:ZB 199Z AT ZlH7*m?7b PAtfc U (HKINIEu rHbt id j S3/26/92 13121 ____________ _________________________ ______________ b. Zonolite Company (approximately 1938-1963); Grace-Conn (1963 until 1971). c. Approximately 1938 by Zonolite Company; 1963 by GraceConn. d. Chemical Composition: Short fiber chrysotile asbestos, Vermiculite, Bentonite (montmorlllonite type). Sodium lauryl sulfate, Sodium Nitrate. Contained approximately 17.11 percent asbestos by wei9ht or approximately 18.69 percent asbestos by weight. e. 1971. f. Lack of market. g. Light beige insulating cement. h. High temperature insulating cement. i. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also.listed. (1) Birmingham, Alabama. (2) Phoenix or Glendale, Arizona; 1959-early 1970's. (3) North Little Rock, Arkansas; 1951-mid 1960's. (4) Los Angeles, California; 1951-1971. (5) Sacramento, California. (6) Denver, Colorado. (7) Tampa, Florida; 1950's-1967. (8) Chicago, Illinois; 1970-1971. (9) Wilder, Kentucky; 1970-1971. (10) Easthampton, Massachusetts. (11) North Billerica, Massachusetts. (12) Dearborn, Michigan. (13) Minneapolis, Minnesota; 1949-1962. (14) St. Louis, Missouri; ?-mid-1960's. (15) Omaha, Nebraska; 1955-1970. (16) Trenton, New Jersey; 1964. (17) Albany, New York. (18) Portland, Oregon. (19) Ellwood City, Pennsylvania; 1948-1960. (20) New Castle, Pennsylvania; 1969-1971. (21) Travelers Rest, South Carolina; 1948-1963. (22) Kearney, South Carolina; 1963-1964. (23) Dallas, Texas. (24) Spokane, Waahington; 1945-early 1970's. (25) Milwaukee, Wisconsin; made until 1971, beginning date unknown. j. This product was packaged in atrong paper bags weighing 25 pounds each. .i. nci t co.-coss.'o umu ra* 17 ms o>jBC*xosa to rumirr'i umn uim mmoMTon so. n mo uotimim. XSTIKKOQATOST SO. FSOTOgSDlD TO WWMIIT [ RECEIVED BS/26 IS:28 1992 AT 21H7HH177S 03s26"92 I5i21 PACE 13 (PMMEtj FA.CE 13; J, 13 k. Grace-Conn did not manufacture an asbestos-free substitute for this product. 20. a. Zonollte Mono-Kote (HK-1). b. Produced by Zonollte Company from December 1956. Virtually all sales ended by 1962, although there may have been some sales until approximately 1969. c. December 1958 by the Zonollte Company, 1963 by GraceConn. d. Chemical Compositioni approximately 11.9% short fiber chrysotlle asbestos, vermlculite, plaster of parls, Portland cement, ZOD concentrate. e. virtually all sales ended by the end of 1962, although there may have been some sales by Grace-Conn until approximately 1969. f. Lack of market. g. Cementitious light beige fireproofing material. h. Cementitious fireproofing. i. The product was manufactured at some or all of the plants listed below. Approximate dates of production are not known. (1) Phoenix, Arisona. (2) Los Angeles, California. (3) Sacramento, California. (4) Denver, Colorado. (5) Tampa, Florida. (6) Wilder, Kentucky. (7) New Orleans, Louisiana. (8) Dearborn, Michigan. (9) Minneapolis, Minnesota. (10) Omaha, Nebraska. (11) Trenton, New Jersey. (12) Albany, New York. (13) Portland, Oregon. (14) Travelers Rest, South Carolina. (15) Dallas, Texas. (16) Spokane, Washington. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor rreight Classification 100-1. m.b. SRAM co.-eon.'a um i md ouktioii to ruiRirr'i Minis mim imiMMon eo. as mo mktiom. ierSMOSATOlT BO. <4 WQWWBID W BfMIMW [ RECEIVED 05/26 15:29 1992 AT 2147441776 B3S26/92 13122 PAGE 14 (PRINTED PAGE 14) J 14 k. Grace-Conn did not manufacture an asbestos-free substitute for this product. 21. a. zonolite 8pre-lnaulation (MK-2). b. Zonolite Company from (I960 - 1963); Grace-Conn (1963 until approximately 1972). c. 1960 by Zonolite Company; 1963 by Orace-Conn. d. Chemical Composition; Short fiber chrysotile asbestos, Vermiculite, White Portland Cement, Plaster of Paris, ZOD concentrate. Contained approximately 11.78 percent 7M asbestos by weight. e. Approximately 1972. f. Lack of market. g. Dark beige cementitious material. h. insulation and acoustical material for application to metal building interiors. i. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) Sacramento, California. (2) Denver, Colorado. (3) Wilder, Kentucky. (4) Minneapolis, Minnesota. (5) Omaha, Nebraska. (6) Trenton, New Jersey. (7) Weedsport, New York. (8) North Little Rock, Arkansas; a small amount may have been made at this plant some time after 1960. (9) Portland, Oregon. (10) Traveler's Rest, South Carolina; 1960. (11) Dallas, Texas. (12) Spokane, Washington; 1960-1962. (13) Milwaukee, Wisconsin; discontinued about 1967. (14) Los Angeles, California. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. k. Grace-Conn did not manufacture an asbestos-free substitute for this product, w.i. nwi ct.-eem.fi annu it ut oBJscTiom to nMRipr'* umn tuna 1 MTIRJtOOATOAY MO. it AMD ADDITIONAL UWaimTBtt MO. M WOIOiDB TO DWMMW [ RECEIVED 05/26 15:29 1992 AT 21H7H*H77b 33/26/92 13 I 22 PABE 15 (PRINTED PflfiE lb; I5 1 22. a. Zonolite Mono-Kote (HK-3). b. Zonolite Company <1959 - 1963); Oraca-Conn (1963 - 1973). c. 1959 by Zonolite Company. 1963 by Grace-Conn. d. chemical Composition; Short fiber chrysotlle asbestos, Vermiculite, Plaster of Paris, Sodium lauryl sulfate. Contained approximately 13.23 percent 7ff or 12.16 7R short fiber chrysotlle asbestos by weight. a. 1973. f. Discontinued to comply with federal regulations. g. Light beige cementitious material. h. Cementitious fireproofing. i. The product was manufactured at some or all of the plants listed below. Where approximate dates of production are known, they are also listed. (1) Phoenix, Arizona (Glendale); 1960-1973. (2) North Little Rock, Arkansas; 1959-1973. (3) Los Angeles, California; 1959-1973. (4) Newark, California; 1965-1973. (5) Sacramento, California. (6) Santa Ana, California; 1972-1973. (7) Denver, Colorado; 1959-1973. (6) Jacksonville, Florida; 1968-1973. (9) Tampa, Florida; 1960-196-7. (10) Chicago, Illinois (W. Chicago); 1959-1973. (11) Wilder, Kentucky. (12) New Orleans, Louisiana; some NX-3 was made at this plant for a short period in the early 1960's. (13) Easthampton, Massachusetts; 1964-1973. (14) Dearborn, Michigan. (15) Minneapolis, Minnesota; 1960-1972. (16) Kansas City, Missouri. (17) St. Louis, Missouri; 1959-1973. (IB) Omaha, Nebraska; 1962-1973. (19) Trenton, New jersey; 1964. (20) Albany, New York. (21) Weedsport, New York; 1965-1973. (22) Portland, Oregon; 1963-1973. (23) Ellwood City, Pennsylvania; mid-1960's. (24) New Castle, Pennsylvania; 1969-1973. (25) Travelers Rest, South Carolina; 1959-1965. (26) Kearney, South Carolina; 1966 or 1967-1973. (27) Dallas, Texas. v.s. mack co.-comr. uinu as Jun DMieiiMi to lumirr'i akmdkd mini inKKKOOATOKT OO. (J MO ABOITIOBAI. iwmoMtow wo. 94 nwBBiwa to pkmkpmt [ RECEIVED 05/26 15:3(1 1992 AT 21*17441776 83/26/92 15123 PflKE lb (PH 1/UtU Pfitit Ibl j ______________ 16 {2B) Spokane, Washington; 1959-1973. (29) Milwaukee, Wisconsin. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically. National Kotor Freight Classification 100-1. k. While Mono-Kote (HK-3) was never reformulated, it was replaced by two new products, Mono-Kote (MK-4) and (NK5), neither of which contains commercial asbestos. MK-4 was first marketed by Grace-Conn in or around 1970. KK-5 was first marketed by Grace-Conn in or around October, 1972. PRODUCTS WHICH DO NOT COMTAIN COMMERCIAL ASBK8TQ8 23. a. lonolite Mono-Kote (MK-4). b. W. R. Grace a Co. - Conn (1970 to the present, in Southern California and Arisons only). c. 1970, in California; 1971, elsewhere. d. Chemical Composition: Grace-Conn objects to providing the chemical composition of this product because the composition is a trade secret. Further answering, this product contains expanded vermicullte. e. This product i6 sold only in Southern California and Arisona. f. Not applicable. g. Cementitious beige fireproofing product. h. Cementitious fireproofing. i. The product has been approved for manufacture or manufactured at the plants listed below, where approximate dates of production are known, they are also listed. (1) Los Angeles, California; 1977. (2) Santa Ana, California; 1977 to present. (3) Newark, California; 1972 to 1974. (4) Phoenix, Arisona; present. (5) Trenton, New Jersey; 1972. (6) New Castle, Pennsylvania; 1972. w.a. tua C0.-C08K. 'a uiui 21 MB MJBCTXOBS TO VLAZBTlPT'a MtBBBBB WITH XBT8M08ATO1X BO. 81 ABB ABBIttMU IIWWOWO BO. 84 HOFOIWPID TO WFIHBUT [ RECEIVED 0S/26 IS: 30 XSS2 A1 X-4 95/26/92 15s 23 rttbc. 11 iriuniuj rnac. iii j 1' (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) (22) (23) Omaha, Nebraska. Huirkirk, Maryland. Portland, Oregon. Nest Chicago, Illinois. Dallas, Texas. Basthampton, Massachusetts. Kearney, South Carolina. Irondale, Alambama. wilder, Kentucky. Little Rock, Arkansas; 7 - 1989. Milwaukee, Wisconsin; 7 - 1991. Minneapolis, Minnesota; 7 - 1989. New Orleans, Louisian; 7 - 1969. Dearborn, Michigan; ? - 1990. Jacksonville, Florida; 7 - 1990. St. Louis, Missouri; 7 - 1990. Denver, Colorado; 7 - 1990. j. This product is packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically. National Motor rreight Classification 100-1. k. This product has never contained commercial asbestos. 24. a. b. C. zonolite Mono-Kote (HK-5). w. R. Grace & Co. - Conn (July, 1972 to the present). 1972. d. Chemical Composition: Grace-Conn objects to providing the chemical composition of this product because the composition is a trade secret. Further answering, this product contains expanded vermlculite. e. This product has not been withdrawn from the market. f. Not applicable. g. Cementitious beige fireproofing product. h. Cementitious fireproofing. i. The product has been approved for manufacture or manufactured at some or all of the plants listed below. Whtere approximate dates of production are known, they are also listed. (1) Irondale, Alabama (2) Fhoenlx, Arisons .t. tt*ci t co.-con. '% wmu 22 no oojbctiomb to ruiRjrri mwbbbo Him IRIllOMtOkI BO. 63 no SMieiORJU. IltlMOMIOlt WO. 96 QBOronOBO ro pofoooaot [ RECEIVED 05/2b IS:31 1992 AT 2147441776 9^26X4? 19,26 PAGE 18 (PRINTED PAGE 18; J ___ ______ * 1. k. 25. a. b. c. d. e. f. g. h. (3) North Little Rock, Arkansas (4) Newark, California (5) Santa Ana, California (6) Denver, Colorado (7) Jacksonville, Florida (6) w. Chicago, Illinois (9) Wilder, Kentucky (10)Muirkirk, Maryland (11)Baathampton, Massachusetts (12{Dearborn, Michigan (13{Minneapolis, Minnesota (14)St. Louis, Missouri (15)Omaha, Nebraska (16{Trenton, New Jersey (17)Portland, Oregon (18)New Castle, Pennsylvania (19)Kearney, South Carolina (20{Dallas, Texas (21{New Orleans, Lousiana; 7-1909 (22)Milwaukee, Wisconsin; 7-1991 This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically. National Motor Freight Classification 100-1. This product has never contained commercial asbestos. Plaster Aggregate. Zonolite Company (1942 to 1963); Grace-Conn (1963 to the present). 1942 by the Zonolite Company; 1963 by Grace-Conn. Chemical Composition: Grace-Conn objects to providing the chemical composition of this product because the composition is a trade secret. Further answering, this product contains expanded vermiculite. This product has not been withdrawn from the market. Not applicable. Beige. When used with gypsum in plaster, it results in a lightweight, insulating, firs resistant, plaster for application to surfaces, such as masonry metal lathes, gypsum lathes, or monolithic concrete surfaces. w.a. iuci t co.-com.'* umn m* n abp tuictitii n rumirr'i mono mitii mmoMrai ao. n mid mbhimm. IitmOaATMT SO, 14 HWWMWW TO BIMOBMT l RECEIVED 85/26 15:31 1992 at ZlH7Htl77b PAGE 19 (PR 1N TED PACE ___________________ 3<'26/'92 1 3< 24 J 1S i j. k. 26. a. b. c. d. This product was manufactured at the plants listed below. (1) Dallas, Texas. (2) San Antonio, Texas. (3) North Little Rock, Arkansas. (4) New Orleans, Louisiana. (5) Nashville, Tennessee. (6) Trenton, New jersey. (7) Weedsport, New York. (6) Basthampton, Massachusetts. (9) Kansas City, Missouri. (10) New Castle, Pennsylvania. (11) Dearborn, Michigan. (12) Newark, California. (13) Portland, Oregon. (14) Phoenix, Arizona. (15) Santa Ana, California. (16) Kearney, South Carolina. (17) Jacksonville, Florida. (18) Pompano Beach, Florida. (19) Tampa, Florida. (20) High Point, North Carolina. (21) xrondale, Alabama. (22) West Chicago, Illinois. (23) Omaha, Nebraska. (24) Minneapolis, Minnesota, (25) wilder, Kentucky. (26) Denver, Colorado. (27) St. Louis, Missouri. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation Industry, specifically, National Motor Freight Classification 100-1. In early 1987, a change was made to poly-lined bags. This product has never.contained commercial asbestos. Concrete Aggregate. Zonolite Company (1942-1963); Grace-Conn (1963 to the present). 1942. Chemical Composition! Grace-Conn objects to providing the chemical composition of this product because the composition is a trade secret. Further answering, this product contains expanded vermiculite. w.i. rna ct.-cam.'i umu mi* 21 mo QMimon *o ruttoTirr'i msrbsd nmtsil XTCTMAVORT *0. O MB UPmoiU lOTWOgATOBt mo. 94 MOPOtmOIP TO PKrMPMT [ RECEIVED 85/26 16:28 1992 AT 21979*11776 eS'26/92 IC14 PACE 2 (PRINTED PAGE 2) j e. This product has not been withdrawn from the market. f. Hot applicable. g. Tan expanded vermiculite. h. Added to concrete to make light weight concrete. i. This product was manufactured at the plants listed below. (1) Dallas, Texas. (2) San Antonio, Texas. (3) North Little Rock, Arkansas. (4) New Orleans, Louisiana. (5) Nashville, Tennessee. (6) Trenton, New Jersey. (7) Weedsport, New York. (8) Basthampton, Massachusetts. (9) New Castle, Pennsylvania. (10) Dearborn, Michigan. (11) Newark, California. (12) Portland, Oregon. (13) Phoenix, Arizona. (14) Santa Ana, California. (15) Kearney, South Carolina. (16) Jacksonville, Florida. (17) Pompano Beach, Florida. (18) Tampa, Florida. (19) Kansas City, Missouri. (20) High Point, North Carolina. / (21) Zrondale, Alabama, I960 to present. (22) Nest Chicago, Illinois. (23) Omaha, Nebraska. (24) Minneapolis, Minnesota. (25) Wilder, Kentucky. (26) Denver, Colorado. (27) St. Louis, Missouri. (28) Los Angeles, California, 1975-6. (29) Milwaukee, Wisconsin. (30) Muirkirk, Maryland. (31) Oklahoma City, Oklahoma. (32) Traveler's Rest, South Carolina. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically. National Motor Freight Classification 100-1. In early 1987, a change was made to poly-lined bags. k. This product has never contained commercial asbestos. .i. hmi co.-cora.'a tmmi ny juid mjimni *o luiiripri unmt Hum imilMtmiT BO. II ABB UDItlDBIl toiwiMimww bo. m momibdh mrwpw [ RECEIVED BS/Z5 15:33 1992 AT Zl^li776 03/26^92 13127 rn l irnmau rm,t i, j I 27. a. b. e. d. Stabilised Concrete Aggregate. Zonolite Company (from some time no earlier than 1942 until 1963)} Grace-Conn (1963 to present). Produced by Zonolite Company from some time no earlier than 1942. Chemical Composition: Grace-Conn objects to providing the chemical composition of this product because the chemical composition is a trade secret. Further answering, this product contains expanded vermiculite and an alr-'entralning agent. e. This product has not been withdrawn from the market. f. Not applicable. g. Dark gray expanded vermiculite. h. Added to concrete to make light weight concrete. i. This product was manufactured at the plants listed below from 1976 to the present, investigation continues with regard to pre-1976 manufacture. (1) Dallas, Texas. (2) San Antonio, Texas. (3) North Little Rock, Arkansas. (4) New Orleans, Louisiana. (5) Nashville, Tennessee. (6) Trenton, New Jersey.. (7) Needsport, New York, 1975 to present. (8) Basthampton, Massachusetts. (9) New Castle, Pennsylvania. (10) Dearborn, Michigan. (11) Newark, California. (12) Portland, Oregon. (13) Phoenix, Arizona. (14) Santa Ana, California. (15) Kearney, South Carolina. (16) Jacksonville, Florida. (17) Pompano Beach, Florida. (18) Tampa, Florida. (19) High Point, North Carolina. (20) xrondale, Alabama, 1980 to present. (21) West Chicago, Illinois. (22) Omaha, Nebraska. (23) Minneapolis, Minnesota. (24) Wilder, Kentucky. (25) Denver, Colorado. w.b. tuei i co.-cora.*a miwm it MB OMBCTZOBB VO ILUItirP'l MltNB Ullll ibtmbosmobt n. n mb mbztzobm. IBTEBBOSATOBT BO. 4 W8WWBIB TO WPIHItH [ RECEIVED B5/Z6 IS: 34 1992 AT 214744177b 05'26'92 1S> 27 ertbt 2 irKlKitL! <L) i 92 (26) St. Louis, Missouri. (27) Los Angeles, California, 1975. (28) Milwaukee, Wisconsin. (29) Muirkirk, Maryland. (30) Oklahoma City, Oklahoma. (31) Traveler's Rest, South Carolina. j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation Industry, specifically. National Motor Freight Classification 100-1. In early 1967, a change was made to poly-lined bags. k. This product has never contained commercial asbestos. 28. a. Masonry Fill (also manufactured as Masonry Insulation). b. Zonolite Company (1956 or 1959 to 1963); Grace-Conn (1963 to the present). c. 1958 or 1959. d. Chemical Composition: Grace-Conn objects to providing the chemical composition of thia product because the - chemical composition is a trade secret. Further answering, this product is a fill for concrete blocks which contains expanded vermiculite which is coated, among other reasons, to make the fill water repellent. e. This product has not been withdrawn from the market. f. Not applicable, g. Dark gray vermiculite fill. h. Used to fill concrete blocks. i. The product has been manufactured at the plants listed below. (1) Dallas, Texas. (2) San Antonio, Texas. (3) Oklahoma City, Oklahoma. (4) Little Rock, Arkansas. (5) New Orleans, Louisiana. (6) Nashville, Tennessee. (7) Trenton, New Jersey. (8) Weedsport, New York. (9) Easthampton, Massachusetts. (10)Muirkirk, Maryland. (11)New Castle, Pennsylvania. *.. macs i co.-con. >i unmi 27 * oMKcrioaa to fuimrr>i mono umi IITUBMIon BO. 01 MO MPXTXO0JU. 2itmoaxmt bo. a ppopowppbp to orooMT [ RECEIVED 05/26 15:34 1992 AT 2147441776 83>'26-'92 13s 28 PAGE 3 (PRINTED PAGE 3) J 03 j. k. 29. a. b. e. d. e. f. g. h. l. (12{Dearborn, Michigan. (13{Newark, New jersey. (14{Portland, Oregon. (15{Phoenix, Arisons. (16{Santa Ana, California. (17{Kearney, South Carolina. (IB)Jacksonville, Florida. (19{Pompano Beach, Florida. (20{Tampa, Florida. (21{High Point, North Carolina. (22)irondale, Alabama. (23)Chicago, Illinois. (24)Omaha, Nebraska. (25{Minneapolis, Minnesota. (26{Wilder, Kentucky, (27{Denver, Colorado. (28{St. Louis, Missouri. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically. National Motor Freight Classification 100-1. In early 1987, a change was made to poly-lined bags. This product has never contained commercial asbestos. Z-Crete. Zonolite Company (from the mid-1940's until approximately 1959). Mld-1940's. Chemical Composition: Grace-Conn objects to providing the chemical composition of this product because the chemical composition is a trade secret. Further answering, this product contained expanded vermlculite. Approximately 1959. Patent sold to another company. Dark gray expanded vermlculite. Structural underground pipe insulation. Orace-Conn is unable to answer this interrogatory on the basis of its current knowledge. j. This product was packaged in strong paper bags weighing 31 pounds each. *.i. iuei * co.-cora.'i Mimi rtf* si mo winiom *o luiRirr'i uimn muui immxoeaTooT me. cs ut uhukmu imuomMT oo. momwn to oerraoMT [ RECEIVED 85/26 15:35 1992 AT 2147441776 03/26S92 15128 PAEE 4 (PRINTED PAGE 4J J 94 k. This product never contained commercial asbestos. 30. a. Top Crete. b. W. R. Grace t Co. - Conn (November, 1900 to the present). c. November, 1960. d. Chemical Composition: Grace-Conn objects to providing the chemical composition of this product because the chemical composition is a trade aecret. Further answering, this product contains expanded vermieullte. e. This product has not been withdrawn from the market. f. Not applicable. g. Dull gray overcoat for Mono-Kote fireproofing. h. Overcoat for Mono-Kote fireproofing. i. The product has been approved for manufacture or manufactured at the plants listed below. (1) Nest Chicago, Illinois (2) Dallas, Texas (3) Basthampton, Massachusetts (4) Kearney, South Carolina (5) Irondale, Alabama (6) Newark, California (7) Phoenix, Arizona (8) Santa Ana, California (9) Trenton, New Jersey j. This product was packaged in multi-walled, pasted-valve bags constructed of two SO pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. In early 1967, a change was made to poly-lined bags. k. This product has never contained commercial asbestos. 31. a. Top Crete 210. b. W. R. Grace a Co. - Conn (July, 1961 to June, 1983). c. July, 1981. d. Chemical Composition: Grace-Conn objects to providing v.a. iua co.-com.'* umu n,, wi oufCTIMi to ruiirirr't mhoid uitn no. is ui rnntaiu imMomwT oo. 4 wawwpra to mwimuhi [ RECEIVED 85/26 15:37 1992 AT 2147HH1776 85/26/92 15158 PAGE 9 (PRINTED PAGE 9) ] (15) Denver, Colorado; ? - 1990 j. This product was packaged in milti-walled, pasted-valve bags constructed of two 60 pound plies o natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor rrelght Classification 100-1. Xn early 1987, a change was nade to poly-lined bags. k. This product has never contained cosunerclal asbestos. nun t eo.-coni.'* miwii s bhirson e ruimrr'i Nunn Mini imuoumr w. I) mw wonioau IimiWMBIT . U HWWWOT TO MnitMT l RECEIVED Ub/Eb Ib.db 133C Hi iiimuro 05/26S92 15129 r noc j i f niAi tnot, 95 e. . 9* h. i. j- k. 32. t b. c. d. e. . 9* h. i. the chemical composition of this product because the chemieal composition is a trade secret. Furthee answering, this product contained expanded vermiculite. June, 1983. Product was identical to Top Crete, and wa6 replaced by Top Crete. Replaced by Top Crete, an identical product. Dull gray spray overcoat for Hono-Kote fireproofing. Overcoat for Hono-Kote fireproofing. The product has been approved for manufacture or manufactured at the plants listed below. (1) West Chicago, Illinois (2) Dallas, Texas (3) Basthampton, Massachusetts (4) Kearney, South Carolina (5) Newark, California This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. This product never contained commercial asbestos. Top Kote. W. R. Grace t Co. - Conn (June, 1979 to June, 1983). June, 1979. Chemical Composition! Grace-Conn objects to providing the chemical composition of this product because the chemical composition is a trade secret. Further answering, this product contained expanded vermiculite. June, 1983. Lack of market. Dull gray overcoat. Overcoat for Mono-Kote fireproofing. The product has been approved for manufacture or manufactured at the plants listed below. (MCI CO.-COW.'I M9WSX9 n >1 mV (Micfini to Fumirri mimbi mitu iniUOMmT Vo. |] MO mdxtxooax. 9IWIMQ MOII VO. BB MOfOWIMB TO PVrVPMT [ RECEIVED BS/26 15:36 1992 AT 2147441776 03S26S92 13129 PAGE fa (PRINTED PAGE fa I j (1) West Chicago, Illinois (2) Dallas, Texas (3) Easthampton, Massachusetts (4) Kearney, South Carolina (5) Newark, California (6) Portland, Oregon (7) Trenton, New Jersey j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. k. This product never contained commercial asbestos. 33. a. b. Zonolite 105. W. R. Grace Co. - Conn (August, 1980 to the present) (currently inactive). c. August, 1960. d. Chemical Composition: Grace-Conn objects to providing the chemical composition of this product because the composition is a trade secret. Further answering, thi6 product contains expanded vermiculite. e. This product has not been withdrawn from the market. . Not applicable. g. Dull gray cementitious material. h. Fireproofing. i. The product has been approved for manufacture or manufactured at the plants below. (1) Nest Chicago, Illinois (2) Dallas, Texas (3) Basthampton, Massachusetts (4) Kearney, South Carolina (5) irondale, Alabama (6) Muirkirk, Maryland (7) Newark, California (8) Phoenix, Arizona (9) Portland, Oregon (10)fianta Ana, California (11)Trenton, New Jersey (12)8t. Louis, Missouri; 7 - 1990 (13) Denver, Colorado; ? - 1990 v.i. nMi co.-coi. mmiu m* ai tan pijictini *o miKirp'i JumniD uitii iimieoATCu ao. i us amhioui. urawMoit wo. m mmmi to PKPCTPJurr [ RECEIVED 0S/2b IS. 3b 1932 fti ^l**V**tl < fb 05^26^92 15*29 \ r ( \rntniLu rntst <i j ' 0*" 1 j. This product was packaged in multi-walled, pasted-valve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation Industry, specifically, National Motor Freight Classification 100-1. In early 1987, a change was made to poly-lined bags. k. This product has never contained commercial asbestos. 34. a. Spatterkote. b. W. X. Grace a Co. - Conn (1984 to the present) (currently inactive). C. 1964. d. Chemical Composition: Grace-Conn objects to providing the chemical composition of this product because the composition is a trade secret. Further answering, this product contains expanded vermiculite. e. This product has not been withdrawn from the market. f. Not applicable. g. Dull gray cementitious material. h. Spatterkote is to be applied to all cellular steel floor units with flat plate on the bottom before the application of Mono-Rote. Spatterkote is optional on other steel surfaces. i. The product has been approved for manufacture or manufactured at the plants listed below. Where approximate dates of production are known, they are also listed. 1) Zrondale, Alabama 2) Phoenix, Arizona 3} North Little Rock, Arkansas 4) Newark, California 5) Santa Ana, California 6) Denver, Colorado 7) Jacksonville, Florida 8} W. Chicago, Illinois 9) Wilder, Kentucky 10) Murkirk, Maryland 11) Easthampton, Massachusetts 12) Dearborn, Michigan; 7-1990 13) Minneapolis, Minnesota 14} St. Louis, Missouri; 7-1990 .. esses t eo.-eonr.' uimi si am sinenMi to rsktrxrr*> mupid hastes zarsamoeATosT eo. u ahd abdxtxmiax. XWTfaSOSATOST eo. <4 WBWDIt TO WriMMT [ RECEIVED BS/Z6 15:37 1992 AT Z1H7H4177G 03/26/92 13!30 PAGE 8 (PRINTED PAGE 8j 08 15) Omaha, Nebraska; 7-1989 16) Trenton, New Jersey 17) Portland, Oregon 18) New Castle, Pennsylvania 19) Kearney, South Carolina 20) Dallas, Texas j. This product was packaged in multi-walled, pasted-velve bags constructed of two 60 pound plies of natural kraft paper, which is prescribed by the transportation industry, specifically, National Motor Freight Classification 100-1. In early 1987, a change was made to poly-lined bags. k. This product has never contained commercial asbestos. 35. a. Sonolitc 3300 Thermal Barrier. b. N. R. Orace a Co. - Conn (April, 1975 to the present). c. April, 1975. d. Chemical Composition: Grace-Conn objects to providing the chemical composition of this product because the composition is a trade secret. Further answering, this product contains expanded vermiculite. e. This product has not been withdrawn from the market. f. Not applicable. g. Dull gray overcoat for polyurethane insulation. h. Overcoat for polyurethane insulation. i. The product has been approved for manufacture or manufactured at the plants listed below. (1) Dallas, Texas. (2) Trenton, New Jersey. 13) Chicago, Illinois. (4) Newark, California. (5) Portland, Oregon. (6) Phoenix, Arisons. (7) Santa Ana, California. (8) Easthampton, Massachusetts. (9) Kearney, South Carolina. (10) Xrondale, Alabama. (11) Muirkirk, Maryland. 112) New Castle, Pennsylvania. (13) Wilder, Kentucky. (14) St. Louis, Mi6Souir; 7 - 1990 v.i. osacs 6 eo.-etn. >i umu jj Mt o0JIctio*0 to rLAzrrirr * akhdkd mith xetBsaoeaTexT eo. ts ud unttonu. unwwwBow o. norownw to diwbw RECEIVED 05/26 15:50 1992 AT 21H7441776 09/26S02 13144 PAGE 1 (PRINTED PAGE i) J 01 CERTIFICATION STATE OF FLORIDA COUNTY OF PALM BEACH, SS. > Terri L. Pika, being firat duly sworn, on oath deposes and says she is Controller, Office of Environmental Policy of W. R. Grace & Co. - Conn., defendant in the above-entitled action; that she has read the foregoing answers to interrogatories and knows the contents thereof; that said answers were prepared by and with the assistance of employees and representatives of the corporation, with the assistance and advice of counsel, upon which she has relied; that the answers set forth herein, subject to Inadvertent or undiscovered errors, are based on and therefore necessarily limited by the records and information still in existence, presently recollected and thus far discovered in the course of the preparation of these answers; that consequently W. R. Grace & Co. - Conn, reserves the right to nake any changes in the answers if it appears at any tine that omissions or errors have been made therein or that more accurate information is available; and that subject to the - limitations set forth herein the said answers arc true to the best of her present knowledge, information and belief. *Effct L. rIKfc Subscribed and sworn to before me 1992 HMCMPMriMO WfCBI--MM0CCWW [ RECEIVED HS/Zfc 15:51 1992 AT 21H7HH177G *3'26S92 1344 PAGE 2 (PRINTED PAGE 2) ) 1181SFC TICA.TE OF SERVICE This is to certify that a true and correct copy of the above and foregoing instrument has been forwarded by regular mail taij all counsel of record on this the rOr.Mt. day of ------- 1 1992.