Document 1g7JDLn3RZo55BdY8EzxV8Jdq
UNITED STATES DISTRICT COURT AOR u-. i.iCT -o iir t THE NORTHERN DISTRICT OF WEST-FlVTOOIWIfeRseuRG, w v a
BARBARA CANTWELL CHRISTMAN, et al., Plaintiffs,
v. AMERICAN CYANAMID COMPANY,
Defendant.
) )
)
)
) ) ) )
) )
)
li,;, : -1 10r!1
THOMAS F. ST A! FORD. CLERK
Civil Action No. 80-0024-P
DEFENDANT AMERICAN CYANAMID COMPANY'S FIRST SUPPLEMENTAL RESPONSES TO PLAINTIFFS'
______________ FIRST INTERROGATORIES
Pursuant to Federal Rule of .Civil Procedure 33, defendant provides the following supplemental responses to Plaintiffs' First Interrogatories without, however, waiving its position that such information is irrelevant to matters properly in litigation in this case. Defendant also reasserts objections 1, 3, 4, 5, 6 and 7 of its First and Second Objections to Plain tiffs' First Interrogatories to the extent they apply to the material now being provided for the first time. A copy of these objections is attached hereto.
2. With regard to defendant's Willow Island facility: (d) For each year since 1965, state separately the number of male employees and the number of female employees employed in each department identified in response to Interrogatory No. 2(a) Answer: See Objection 1. From 1975 to the present, the answer is as follows:
N41710
Year 1975 1975 1975 1975 1975 1975 1975 1975 1975
1976 1976 1976 1976 1976 1976 1976 1976 1976
1977 1977 1977 1977 1977 1977 1977 1977 1977 1977
2
Department
Employees Male Female
Special Chemicals
101
13
Pigments
54 8
Aureomycin
23 0
Catan
24 0
Catalyst
80
Beta Naphthol Complex 37
0
Stores
27 0
Maintenance
225 0
Power/Effluent
28 0
Special Chemicals
68
Pigments
66
Aureomycin
24
Catan
25
Catalyst
. 23
Beta Naphthol Complex 44
Stores
29
Maintenance
240
Power/Effluent
27
6 9 0 0 5 0 0 1 0
Special Chemicals
89
Pigments
61
Aureomycin
23
Catan
25
Catalyst
15
Beta Naphthol Complex 45
Surfactants
9
Stores
30
Maintenance
204
Power/Effluent
22
7 8 0 0 6 0 0 0 0 0
Year 1978 1978 1978 1978 1978 1978 197 8 1978 1978 1978
3
Department
Employees
Male
Female
Special Chemicals
90
7
Pigments
57 8
Aureomycin
24 0
Catan
25 0
Catalyst
23 6
Beta Naphthol Complex 45
0
Surfactants
90
Stores
30 0
Maintenance
205 0
Power/Effluent
23 0
1979 1979 197 9 1979 1979 1979 1979 197 9 1979 1979
Special Chemicals Pigments Aureomycin Catan Catalyst Beta Naphthol Complex Surfactants Stores Maintenance Power/Effluent
78 38 29 21 12 '47
8 32 228 21
3 6 0 0 4 0 0 1 2 0
1980 1980 1980 1980 1980 1980 1980 1980 1980 1980
~ Special Chemicals
88
Pigments
24
Aureomycin
27
Catan
20
Catalyst
15
Beta Naphthol Complex
6
Surfactants
8
Stores
30
Maintenance
196
Power/Effluent
21
6 4 1 0 5 0 0 0 0 0
11
(b) If so, describe each method of advertisement or recruitment and its purpose; (c) Identify the individual{s) responsible for adopting and implementing the program; and (d) Identify any publication used. Answer; For the years 1970-1974 see Objection 1. Since 1975, the answer is as follows:
In May 1978, the Willow Island Plant recruited indus trial mechanics by using classified display advertising in the following newspapers; Marietta Times, Marietta, Ohio; Parkersburg News, Parkersburg, W. Va.; Parkersburg Sentinel, Parkersburg, W. Va.; St. Marys Oracle, St. Marys, W. Va.; and the Tyler Star News, Sistersville, W. Va. The Willow Island Plant Manager, R. J. Clay, was responsible for adopting and implementing the program.
24. Identify any documents reflecting or relating in any way to the absence of women in P&M positions and to a | decision to hire women into those positions at any time since I 1965. Answer; See Objection 1. This interrogatory also seeks docu ments concerning defendant's affirmative action plans, policies ; and programs, and documents filed with federal agencies regard-
f
I ing defendant's compliance with employment regulations. Such inquiries concern a process of searching self-examination by the
i company and sensitive negotiation between the government and ^ the company. As a matter of public policy, materials reflecting
: this policy of candid self-evaluation and self-criticism should | rarely be discoverable. Intrusion into this process could frus
trate and make less useful the self-examination and conciliation ! that is often necessary and is sought by government agencies, i Absent a showing of special relevance--which is not apparent i here--these matters should not be inquired into.