Document 2JXkgxXxrmJNJ3D308G1q3Er5
FILE NAME: Asbestos Z>> DATE: DOC#: AC> OCUMENT DESCRIPTION>ZZZ/ZZ
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CANAOA PROVINC! OF OtJD!C DIS'1'IUCT OF FRONTENAC
AFl"IDAvrr
I, Me Alai.."1 Dulude, with MConey, Thetford ~in8S, Quebec:, d.epo se and !Say:
offices Canada,
located at be inq duly
835 r'J.e sworn, do
1. TRA'r I am the Sec:ratar.i of As.beltos Co:,?oration
Limitad in the ~ve entitled. &c:tion.1
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2. THAT I am. authori%~ to male. this Affidavit on be hal!
. of AsCeltoa Corporation Li=itad1 t 3. 't'HAT the foreqoinq Italpon. . . to Intarroqatories of
Aabe.toa Corporation Limited are true to the best of my knowledg infor:aation and bt'\1.ief.
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Sworn to IJ1d Subaeril:led ~efc:. me &t Th.tford-Min , Provinc. of Qutlbee, Canada, t:.his 7th aay of April, 19a3.
fA1. L: ~d'.A<~4" connlssi of O.ths J Judici.1 District of Fronten.c
ALAIN DULUDE
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AfNiSbWr~e.l, :whicDhefiesndnaontt alapbreoldsucpta,ckwaigtehs tchoentwaoirndisn:g J:'aw asbestos
Caution
ACvoonitdaiCnsreAatsibnegstoDsusFt iber
Breathing Asbestos Dust Serious Bodily Harm
May
Cause
United
This States
label has Department
been k)rescribed for of Labor, Occupatio
use
by
the
Health Administration k)ursuant
to
29 C.F.R.
nal Safety 51910.1001.
and It
wtihnaes.Jankno)rutoaimcryeu;lg1a9t7ed0, iAnCL19l7a2b.elePd riboargstoofthraawt atismbeesatonds cfoibmrmeenwciinthg
, Caution
fibre.
- This Persons
bag contains crysoti1e expos.d to this mate
asbestos
tuhsi.s admeaqtueartieal proovteerctliovneg d~erviicoedss ams ayinbhreaialalhtaisromhnofuuolld.f
..
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B. 10. Has your ccmpany every been a member 0 f , affil iated with or provided funding for the Industrial
Hygiene Foundation? If so, indicate when your company was a
member or affil iated wi th this organiza tion and set fOt'th
the dates, if o rganiza tion.
applicable,
when
you provided
funding
to
this
ANSWER: ACL was a tion fro. Deeember
m. .ber of the Indu.tri~l Hygiene 1, 1953 until Dec.-ber 31, 1960.
FoundaACL did
not provide Isr with funding, but it is possible that a
naminal annuAl due. was p4id.
tors?
B. 11. Ooes your cc::mpany have a SOard of Direc-
/
ANSWER: Ye s
B. 12. Does
conduct meetings?
your
company's
Board
of
Directot's
ANSWER: Yes.
meetings
B. 13. Have minutes of bHn taken and maintained
the Board of Directot's by your company? If so,
indicate who has custody of the minutes at this time.
-.
ANSWER: 'tes. The Board of Directors.
Secretary main ta ins
the
Min utes 0 f
the
or
B. 14. Has your company, and/or its subsid iar ies affiliate. ever manufactured or distributed asbestos
containing products?
ANSWER: No.
.(
f i 1 i ated
B. 7. wit h
Has defendant ever been a member of or aft he As be s to S Text i 1e Ins tit ute? I f so,
indicate when your this orQanization.
com~ny
was
affiliated
or
was
a
member
of
( ANSWER: ACL v an Institute trom June
...ociate . . .ber 1951 until that
of the Albeatoa Textile organization dissolved.
ACL was not a meager of AT!'. Air Hygiene Subcommittee.
manual
or
B. 8. Doe. your ccmpany puJ:)l ish or distribute a booklet which de.crioes the nature ot the business
/
that such
defendan t manual or
is enQaQed in? If booklet, indicate
so, set when it
forth the ti t1e of w publ ished and
attach a copy ot same hereto.
ANSWER: Annual
'{es. AJI Reports.
a A
publicly
copy 0 e,
traded corporation, ACL issues the Annual Report for 1981 is
attached.
B. corporation
9. ever
Has any employee or representative attended a meeting of the Asbestos
of your Textile
eIdnstthiteustee?m..Itfinsgo. , anidd esnetitfyfoerathch thseucdhaitneds ivoniduwahlichwhoeacahttesnudch-
individual went to such a. conference or meeting.
ANSWER: Asbestos
ACL does not have copies of the Textile Institute, which are in any
records of the case subject to
objections. To compile the information this Interrogatory from other sources
required to answer would entail the
review of employees,
~er.onnel files ~ast and present,
of in
the virtually hundreds of 0 rder to determine whether
they ever might not
attended such meetings. be recorded, or in the
Even case
then, the information of retired ~rsonnel,
it might no 10nQer be in existence.
'":"?"
tion,
B. 35. Has defendant at any time since its incepmaintained any office or department dealing with
medical research? If so, state:
a. the name of each such department; b. the dates each such department was in
operation;
ANSWER: No.
c. the name, address and job position of each such person who has been in charge of sa id departmen t or depar tluen ts.
B. 36. When was the first time the defendant
/
became aware of associated with
or or
knowledgeable of any causally related to
disease or illness the inhalation of
asbestos, asbestos fibers whatsoever? Indicate which
or asbestos dust disease defendant
in any form became aware
of and describe how defenda,\t became aware of its alleged
relationship to inhalation or exposure to asbestos.
ANSWER: By tha 1950' s ebe t.e-J;m~::...,~.~.to.ia:"",~_~,s ~enerally
v. known a&- descr ipti
occurrinq ilt persona
of a me<f1c al~ cond! tron "samet imes ex~se<i to lOOt" aabe.to. in heavy
concentrations on a- continual baais ove-r long- periods
\ of time. Defendant's upon he ar say
information
in
this
area
was
based
tory,
B. 37. In reference to the preced ing In terrog aif defendant acknowledges a causal relationship
bfoeltlwoeweinng asinbfeosrtmoastioannd: disease or illness, set forth the
a. what diseases or illnesses defendant acknowledges are causally related to or associated with exposure to asbestos dust or fibers;
b. the date upon which defendant became aware of the association with or causal rilellnaetsiso;n to each such disease or