Document 2Eb6Kj6eEQ0JZ7L3NzMEdZ8a

IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO HELEN V.-ARTHUR, Individually and as Executrix of the Estate of Charles E. Arthur, Deceased, Plaintiff vs. B. F. GOODRICH CHEMICAL COMPANY, et al., Defendants ) ) ) ) ). ) ) ) ) ) ) Case No. 77-976623 Judge Burt W. Griffin REQUESTS BY DEFENDANT DON CHEMICAL COMPANY FOR ADMISSIONS BY PLAINTIFF (First Set) Defendant DON CHEMICAL COMPANY (hereafter "Dow") hereby requests pursuant to the provisions of Rule 36 of the Ohio Rules of Civil Procedure that plaintiff admit, as pro vided in that Rule, each of the following propositions of fact: 1. Plaintiff does not have any information that vinyl chloride manufactured by Dow was used at the premises .of B. F. Goodrich or B. F. Goodrich Chemical Company while plaintiff's decedent was working there. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 074704 2. While plaintiff's decedent was working at the premises of B. F. Goodrich or B. F. Goodrich Chemical Company, he was not exposed to any vinyl chloride, or related product, which was manufactured by Dow. William D. Ginn William H. Wallace James T. Crowley OF COUNSEL: Thompson, Hine and Flory David ^ L. Parham 1100 National City Bank Building Cleveland, Ohio 44114 (216) 241-1660 Attorneys for Defendant Dow Chemical Company PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 074705 CERTIFICATE OF SERVICE Copies of the foregoing Requests By Defendant Dow Chemical Company For Admissions By Plaintiff (First Set) were mailed this - day of January, 1978 to the following: Steven A. Sindell, Attorney for Plaintiff 910 Leader Building, Cleveland, Ohio 44114 Irving Berger, Attorney for Defendants B. F. Goodrich Chemical Company and B. F. Goodrich Company 1700 Union Commerce Building, Cleveland, Ohio 44115 George Zucco, Attorney for Defendant International Commodities Export Company 1525 Leader Building, Cleveland, Ohio 44114 Frank Soldat, Attorney for Defendants Pittsburgh Plate Glass Company Chemical Division, Tenneco Chemicals, Inc., Monsanto Company, Ethyl Corporation Industrial Chemicals Division, Allied Chemical Corporation Industrial Chemicals Division, Stauffer Chemical Company Plastics Division, Precision Gas Products, Inc., and PPG Industries, Inc. Chemical Division 55 Public Square, Cleveland, Ohio 44113 McNeal, Schick, Archibald,. Attorneys for Defendants Continental Oil Company, Conoco Chemicals Continental Oil Company, Conoco Chemicals and Scientific Gas Products, Inc. 520 Williamson Building, Cleveland, Ohio 44114 Gallagher, Sharp, Fulton, Norman & Mollison, Attorneys for Defendants Air Products and Chemicals, Inc. Chemicals Group and Air Products and Chemicals, Inc. Industrial Gas Division 630 Bulkley Building, Cleveland, Ohio 44115 Steven E. Sigalow, Attorney for Matheson Gas Products 1500 Akron Center Building, Akron, Ohio 44308 Walter Bates, Attorney for Defendants Bordon Chemical, Borden, Inc. and Monochem, Inc. 1144 Union Commerce Building, Cleveland, Ohio 44115 Craig D. Barclay, Attorney for Defendant Montedison USA, Inc. Suite 900, 37 W. Broad Street, Columbus, Ohio 43215 American Chemical Corporation, Defendant 2112 Bast 223rd Street, Long Beach, California 90810 Stinnes Oil & Chemical Company, Defendant 750 Third Avenue, New York, New York 10017 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 074706 Diamond Shamrock Chemical Co., Defendant 300 Union Commerce Building, Cleveland, Ohio 44115 Union Carbide corporation, Chemicals a Plastics, Defendant 270 Park Avenue, New York, New York 10017 Shell Chemical Company, Chemical Sales, Defendant One Shell Plaza,.Houston, Texas 77002 Agriment, Inc., Defendant 445 Park Avenue, New York, New York 10022 Stanalchem, Inc., Defendant 299 Park Avenue, New York, New York 10017 Richard C. Talbert, Attorney Corporation - 2121 The Superior Bldg. Cleveland, Ohio 44114 for Defendant Allied Chemical Robert G. Quandt, Attorney Company 1448 Leader Bldg. Cleveland, Ohio 44114 for Defendant, Stauffer Chemical Richard Reminger, Attorney Inc. 731 Leader Building Cleveland, Ohio 44114 for Defendant ' Tenneco Chemicals, Walter Bates, Attorney for Defendants Bordon Chemical, Borden, Inc. and Monochem, Inc. 1144 Union Commerce Building, Cleveland, Ohio 43215 BK ORDER" UCC 074707