Document 2QDKvwE4YZQX1XxDowMx9wmb

$ PLAINTIFF'S i | tXHIOIT NO. I g I^IIHNIIII^IION^ is SUPERIOR COURT OF WASHINGTON FOR KING COUNTY DONALD NOLL and CANDACE NOLL, husband and wife. Plaintiffs, v. UNION CARBIDE CORPORATION, et al. Defendants. No. 13-2-06781-1 SEA J-M MANUFACTURING COMPANY, INC.'S OH.)ICC HONS ANI) RESPONSES TO PLAINTIFFS' INTERROGATORIES Defendant, J-M Manufacturing Company, Inc. (hereafter "JMM" or "Defendant"), hereby responds to Plaintiffs' Interrogatories (hereafter "Interrogatories") propounded by Plaintiffs Donald and Candace Noll (hereafter "Plaintiffs"), as follows: PRELIMINARY STATEMENT JMM last sold asbestos-containing cement pipe ("A/C pipe") over two decades ago. Since that time, the company has relocated and most of the individuals involved with the sale of A/C pipe are no longer employed with the company. Further, many of the documents relating to A/C pipe no longer exist. As a result, collecting the detailed information requested in these Interrogatories requires the company to rely on the best recollections of those witnesses with personal knowledge who are still available and the historical documents that still exist. The J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - I 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 responses herein are made alter reasonable search and investigation. However, JMM's 2 investigation of the facts relating to this ease and its discovery in this action are ongoing. Further 3 discovery, independent investigation, legal research and analysis may supply additional facts, 4 add meaning to known facts, and establish new factual conclusions and legal contentions, all of 5 which may lead to additions, changes and or variations from the present response. Therefore, 6 these responses are made without prejudice to JMM's right to rely upon facts, documents, 7 witnesses or other information discovered or developed after the date of these responses. The 8 responses are based on information and belief of the person verifying the response. 9 The responses contained herein are made in a good faith effort to supply as much factual 10 information and as much specification of legal contentions as is presently known, but shall in no 11 way lead to the prejudice of JMM in relation to further discovery, research, or analysis. 12 GENERAL OBJECTIONS 13 1. JMM objects to Plaintiffs' Interrogatories to the extent that Plaintiffs have sought 14 to impose upon JMM duties and obligations in excess of those expressly set forth in the 15 Washington Code ofCivil Procedure. 16 2. JMM objects to Plaintiffs' Interrogatories on the grounds they contain sub-parts, 17 are compound, are conjunctive, are disjunctive, are not full and complete in and of themselves, 18 contain unauthorized definitions and instructions, and are otherwise violative of the rules of civil 19 procedure of Washington. 20 3. JMM also objects to Plaintiffs' Interrogatories in that they are vague, ambiguous, 21 overbroad and excessively burdensome. 22 4. Further, although JMM has made a good faith effort to respond to these 23 Interrogatories to which it has not objected, in making such response, JMM does not purport to J-M MANUFACTURING COMPANY, rNC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 2 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 L have adopted or applied any definitions set forth at the outset of or at places in Plaintiffs' 2 Interrogatories, nor has JMM assumed the improper, unproved, and hypothetical fuels proffered 5 by Plaintiffs. Additionally, JMM has not accepted the terminology or substance ol Plaintiffs' 4 claims incorporated in, implied in, or alluded to within Plaintiffs' Interrogatories. 5 5. The responses made herein arc made without in any way waiving or intending to 6 waive, but on the contrary expressly reserving: the right to object on the grounds of competency, 7 privilege, relevancy, and materiality, or any other proper ground, to the use of such information, 8 for any purpose, in whole or in part, in any subsequent proceeding in this action, or any other 9 action; and the right to object on any grounds at any time, to any other discovery procedure 10 involving or relating to the subject matter of this request. 11 6. JMM further objects to Plaintiffs' Interrogatories on the grounds and to the extent 12 that said Interrogatories seek information protected by the attorney-client privilege, the attorney 13 work-product privilege and any and all additional protections and privileges pursuant to 14 Washington case and statutory law. 15 7. JMM objects to Plaintiffs' Interrogatories to the extent they are not limited in 16 scope to the specific product or products to which Plaintiffs were allegedly exposed. 17 These general objections are applicable to JMM's response herein, whether or not 18 specifically stated in such response and are hereby incorporated into such response by this 19 reference. 20 21 22 23 J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 3 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street- Suite 4,00 Seattle, Washington 98101-2380 (206) 628-6600 RESPONSES AND ()HJE( I IONS K) INTI .KK< IGAIOUIKS 2 INTERROGATORY NO. I: 3 Identify the person answering these interrogatories on behnll of Defendant, 4 RESPONSE: 5 JMM incorporates herein its Preliminary Statement and General Objections. Subject to and without waiving any objections, JMM states that no single officer, employee 6 or agent of JMM has direct knowledge of each and every answer requested. The answers are derived from numerous sources, persons and documents over an extended period, and 7 are verified by Barry Lin, Special Assistant to the President, in order to comply with applicable legal requirements. Mr. Lin possesses no particularized information concerning 8 the matters encompassed by these answers. 9 INTERROGATORY NO. 2: 10 Has the person answering these interrogatories made reasonable inquiry of all available sources of information such that Plaintiff may rely upon these answers as the truthful and 11 complete answers made on behalf of Defendant? List any and all such sources of information relied upon, including, but not limited to, identifying any mid all records or documents reviewed 12 and persons providing information. 13 RESPONSE: 14 JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the request is vague, 15 overbroad, and overly burdensome. Subject to and without waiving any objections, JMM refers Plaintiffs to its answer to Interrogatory No. 1. 16 INTERROGATORY NO. 3: 17 State the following concerning this Defendant: 18 a. Full and correct name; 19 b. The form in which Defendant presently conducts business (i.e. corporation, partnership, proprietorship, etc.); 20 c. Identify any and all predecessors and related companies as defined above; d. Any and all other forms in which defendant has conducted business at any time, and 21 the date(s) when business was conducted in each form; e. Any and all names by which Defendant has been known or has conducted business, at 22 any time, and the date(s) during which Defendant has been known by and/or conducted business, under each such name; 23 f. Defendant's principal place of business; J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 4 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 4213715.1 1 INTERROGATORY NO. 5: 2 Identify by full and complete trade name, any and all asbestos-containing products as defined above, which this Defendant, any related company, or any predecessors) lias, at any 3 time: a. Designed; 4 b. Manufactured; c. Processed; 5 d. Sold; e. Distributed; f. Applied; 6 g. Installed; h. Patented; 7| i. Specified; or j. Re-labeled. RESPONSE: 9 JMM incorporates herein its Preliminary Statement and General Objections and 10 further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to 12 the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. Subject to and without waiving any 13 objections, JMM states that it sold A/C pipe and couplings manufactured by J-M A/C Pipe Corporation ("JMAC"). 14 INTERROGATORY NO. 6: 15 With respect to each asbestos-containing product listed for each subpart of Interrogatory 16 No. 5: ' a. Identify the specific company (Defendant, predecessor, related company) which 17 designed, manufactured, processed, specified, sold, distributed, applied, installed, patented or re-labeled such product; b. State the year in which Defendant, its related company or its predecessor first 18 designed, manufactured, processed, specified, sold, distributed, applied, installed, patented or re-labeled such product; and, 19 c. State the year in which the Defendant, its related company or predecessor last designed, manufactured, processed, specified, sold, distributed, applied, installed 20 patented or re-labeled such product. RESPONSE: 22 JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is 23 vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 6 Williams, Kastner & Gibbs PLLC 601 Union Street- Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 4213715.1 L RESPONSE: 2 JMM incorporates herein its Preliminary Statement ami General Objections and further objects to this interrogatory on the following specific grounds: (lie interrogatory is 3 vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored (o the facts of this case, and seeks information that is not relevant or reasonably calculated to 4 lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, 5 work product doctrine or is otherwise protected. Subject to and without waiving any objections, JMMI states that the A/C pipe JMM sold contained chrysotilc fiber and certain 6 classes of pipe also contained crocidolitc asbestos. The exact ingredients and percentage varied over time and between pipe type, hut the A/C pipe generally contained 12-20% 7 asbestos fiber. The A/C pipe sold by JMM had a rough cement gray exterior and a smooth interior. The pipe came in various diameters and lengths and was sold in various 8 configurations including with machined ends and attached couplings on some product. The pipe had information stenciled and adhered to it that varied depending on pipe type. JMM 9 did not manufacture the products, and therefore, had no patents. 10 INTERROGATORY NO. 1 1: 11 Identify any and all facilities at which Defendant, any predecessor or any related company, at any time, manufactured or processed asbestos-containing products, or processed raw 12 asbestos. For each such facility identified: a. State the date(s) which said facility was owned and/or operated by Defendant, any 13 predecessor or any related company; b. State the, date(s) during which asbestos-containing products and/or raw asbestos were 14 manufactured or processed, at said facility; and, c. Identify each person serving as the manager or supervisor of said facility during any 15 time which the facility has been owned and/or operated by Defendant, any predecessor or any related company, and state the date(s) of the tenure as manager or 16 supervisor for each. 17 RESPONSE: 18 JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is 19 overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information and documents that are not relevant or reasonably 20 calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information or documents that are protected by the 21 attorney client privilege, work product doctrine or are otherwise protected. Subject to and without waiving any objections, JMM states that it did not manufacture the A/C pipe and 22 couplings it sold. JMM facilitated the purchase of raw asbestos, pursuant to an Operations Management Agreement with JMAC for use by JMAC in manufacturing the A/C pipes in 231 plants owned by JMM in Stockton, CA and Denison, TX. By way of further response, J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 9 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 4213715.1 JMM refers Plaintiffs to its objections and answer to Interrogatory No. 7, which arc incorporated herein by reference. INTERROGATORY NO. 12: Identify any and all persons known by you to have any knowledge concerning the manufacture, sale, distribution, possession, application, installation or use of the products listed in response to Interrogatory No. 6. RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. Subject to and without waiving any objections, JMM states that its corporate representative Jim Reichert may have knowledge regarding information responsive to this interrogatory. INTERROGATORY NO. 13: With respect to the products listed in response to Interrogatory No. 6, did Defendant, any predecessor or related company or the manufacturer of the products ever conduct tests of any kind on any or all of said products concerning possible or potential health hazards involved in its use or in the use of materials contained therein? RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. Subject to and without waiving any objections, JMM states that its investigation to date has not indicated that JMM itself commissioned any laboratory tests on the products relating to the health consequences of asbestos or the dust generated by any use of the products. INTERROGATORY NO. 14: If your answer to Interrogatory No. 1 is "Yes," with respect to each product test: J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 10 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street- Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 a. State the location where (he test was performed; b. Identify eacli and every individual who conducted or participated in said test; c. Describe the results of said test; d. State the date upon which said test was conducted; e. Identify any and nil documents referring to, relating to or reflecting said test or the results thereof; and f. Identify each and every individual who received a copy of any document referring to, relating to or reflecting the results of said test. RESPONSE: Not Applicable. INTERROGATORY NO. 15: Did any person, including but not limited to, an officer, agent or employee of Defendant, any predecessor or related company recommend any design changes as a result of any test referenced in your response to the preceding interrogatory? RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. Subject to and without waiving any objections, JMM states no. By way of further response, JMM states that its investigation to date has not indicated that JMM itself commissioned any laboratory tests on the products relating to the health consequences of asbestos or the dust generated by any use of the products. INTERROGATORY NO. 16: If your answer to Interrogatory No. 15 is "Yes," with respect to each such recommended design change: a. State the product or products involved; b. State the test or tests involved; c. State the nature of the change recommended; d. Identify the person(s) making the recommendation; e. State the nature and effective date of any change made; and f. Identify each and every person who participated in the decision to make or not make the recommended design change. J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 11 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 1 INTERROGATORY NO. 1 l2l 2 If your answer lo Interrogatory No. IX is "Yes," identify each such count or test performed, by stating when and where it was conducted, and with respect to each count or test so 3 identified: a. Identify the product being manufactured, used, applied, or installed; 4 b. Identify each and every person who conducted, participated in conducting, or analyzed the results of, said count or test; 5 c. State the purpose of said count or test; d. State what, if any, actions were taken in response to the results of said count or test; 6 and e. Identify any and all documents referring to, relating to or reflecting said count or test, 7 including, but not limited to, any actions taken in response to the results of such count or test. 8 RESPONSE: 9 Not Applicable. 10 INTERROGATORY NO. 20: 11 Did Defendant, any predecessor or any related company, at any time, place any warning 12 signs or labels on the containers in which any of the products listed in response to Interrogatory No. 6 were packaged? 13 RESPONSE: 14 JMM incorporates herein its Preliminary Statement and General Objections and 15 further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, duplicative, lacks foundation and is not reasonably tailored to the facts 16 of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the 17 extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. Subject to and without waiving any 18 objections, JMM states that the A/C pipe and couplings sold by JMM did not come in containers, as JMM understands that term. By way of further response, JMM states that 19 the following warning and work practice recommendation was placed on the A/C pipe manufactured by JMAC. 20 21 22 23 J-M MANUFACTURING COMPANY, rNC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 13 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 CAUTION Do not use power saws to cut this pipe. Breathing dust created by improper work practices may cause serious bodily harm. When cutting, machining or tapping, refer to the recommended work practice guide furnished by your employer. AVISO No use herramientas automations para cortar tuberia. Respirin' cl polvo producido por cordes con herramientas automaticas peude truer conseeueneias graves a la salud. Consulte la informacion suministrada por su supervisor antes de cortar tornear o rosear el material. * Other information may have included the AWWA Manual No. M16 - Work Practices for Asbestos-Cement Pipe, The recommended Work Practices for A/C Pipe, A/C Pipe and Health, an A/C & Health audio visual presentation, as well as information which may have been provided orally by field representatives. When JMM began selling A/C pipe in 1983, warnings and cautions were already being utilized for the A/C pipe. JMM continued the practice of providing the warnings and cautions between 1983 and 1988. JMM further refers Plaintiffs to its objections and answer to Interrogatory No. 10, which arc incorporated herein by reference. INTERROGATORY NO. 21: If your answer to Interrogatory No. 20 is "Yes," identify each and every product upon which such a warning was placed, and with respect to each such product identified: a. State the date on which any order directing that a warning be placed on said product first issued; b. Identify any and all persons participating in the decision to issue that order; c. State the first date on which such warning was actually placed on said product; d. State the first date on which such product accompanied by such warning was first sold, distributed or installed; e. Sate the exact wording of this first warning; f. State the exact location and size of this first warning as it appeared on said product; g. Identify any and all persons who participated in any phase of the drafting or design of said first warning, including, but not limited to those who performed the actual drafting and design work, those who reviewed the work, those who edited the work and those who approved the warning; h. State why you placed such warning on said product, including, but not limited to, whether you placed such warning on said product because you received a directive, command, suggestion, legal opinion, or any type of communication (written or otherwise) from any person, firm, corporation, governmental agency, committee, association, attorney or institute; and i. Identify any and all documents referring to, relating to or reflecting said warning, its drafting, and/or the decision to place the warning on said product, including, but not J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 14 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 4213715.1 limited to, any communication as described in subpnrt li o! this interrogatory. RESPONSE: JMM incorporates herein its Preliminary Stntenient ami General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, duplicative, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information and documents that are not relevant or reasonably calculated to lead to the discovery of admissible evidence. .I MINI further objects to this interrogatory to the extent that it seeks information or documents that are protected by the attorney client privilege, work product doctrine or are otherwise protected. Subject to and without waiving any objections, JMM refers Plaintiffs to its objections and answer to Interrogatory No. 20, which are incorporated herein by reference. By way of further response, JMM states that copies of the warning and cautions arc already in Plaintiffs' counsel's possession. INTERROGATORY NO. 22: With respect to each product identified in response to Interrogatory No. 21 as having been accompanied by a warning, state whether, subsequent to the first warning described above, any different warning was ever placed upon said product. Any alteration, change or modification in the language, wording, capitalization, punctuation, style of type or printing, size, color, or location on the package or container, of the warning constitutes a different warning. RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, duplicative, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. Subject to and without waiving any objections, JMM refers Plaintiffs to its objections and answers to Interrogatory Nos. 20-21, which are incorporated herein by reference. By way of further response, JMM states that copies of the warning and cautions are already in Plaintiffs' counsel's possession. INTERROGATORY NO. 23: With respect to each different warning which accompanied each product listed in response to Interrogatory No. 21: a. State the date on which any order directing that such different warning be placed on said product first issued; b. Identify any and all persons participating in the decision to issue that order; J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 15 4213715.1 Williams, Kastner & Gibbs PLLC 60! Union Street. Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 c. State the first date on which such different warning was actually place on said product; d. State the first date on which such product accompanied by such different warning was sold, distributed or installed; 3 e. Describe, with specificity, any and all changes, modifications or differences between the different warning and the prior warnings(s); 4 f. Identify any and all persons who participated in any phase of the drafting or design of such different warning, including, but not limited to, those who performed the actual 5 drafting and design work, those who received the work, those who edited the work and those who approved the different warning; 6 g. State why you placed such different warning on said product, including, but not limited to, whether you placed such different warning on said product because you 7 received a directive, command, suggestion, legal opinion, or any type of communication (written or otherwise) from any person, firm, corporation, 8 governmental agency, committee association, attorney or institute; and h. Identify any and all documents referring to, relating to or reflecting, said different 9 warning, its drafting, and/or the decision to place the different warning on said product. 10 RESPONSE: 11 JMM incorporates herein its Preliminary Statement and General Objections and 12 further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, duplicative, lacks foundation and is not reasonably 13 tailored to the facts of this case, and seeks information and documents that are not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further 14 objects to this interrogatory to the extent that it seeks information or documents that are protected by the attorney client privilege, work product doctrine or are otherwise 15 protected. Subject to and without waiving any objections, JMM refers Plaintiffs to its objections and answers to Interrogatory Nos. 20-22, which are incorporated herein by 16 reference. By way of further response, JMM states that copies of the warning and cautions are available for inspection at Plaintiffs' request. 17 INTERROGATORY NO. 24: 18 State the date on which any official of Defendant or its predecessor(s) first had 19 knowledge, notice, information or understanding that exposure to asbestos would, could or might cause each of the following diseases: 20 a. Pleural disease; b. Asbestosis; 21 c. Mesothelioma; d. Lung cancer; and 22 e. Any other forms of cancer. 23 RESPONSE: J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 16 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 JMM incorporates herein its Preliminary Statement mid General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. .IMM further objects to this interrogatory to (he extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected and to the extent it improperly calls for a medical opinion and/or expert opinion. The interrogatory fails to distinguish between different fiber types and ignores important factors such as differences in the friability of asbestos fibers in different products, different uses of asbestos-containing products, different exposures of individuals at different work sites, engaged in different crafts and the frequency, proximity, regularity and duration of particular exposures. Subject to and without waiving any objections, JMM states that JMM employed numerous persons throughout the course of its business, any one of whom may have obtained varying degrees of knowledge regarding asbestos and asbestos-related diseases at varying points in time. When JMM, as a corporation, obtained any particular knowledge cannot be determined with accuracy. INTERROGATORY NO. 25: With respect to each disease set forth in Interrogatory No. 24: a. Identify the official who first obtained the knowledge, notice, information or understanding to which the interrogatory refers; b. Identify any and all documents referring to, relating to or reflecting such knowledge, notice, information or understanding; and, c. Describe what, if any, action said official, Defendant, any predecessor or any related company took in response to such knowledge, notice, information or understanding. RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information and documents that are not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information or documents that are protected by the attorney client privilege, work product doctrine or are otherwise protected and to the extent it improperly calls for a medical opinion and/or expert opinion. The interrogatory fails to distinguish between different fiber types and ignores important factors such as differences in the friability of asbestos fibers in different products, different uses of asbestos-containing products, different exposures of individuals at different work sites, engaged in different crafts and the frequency, proximity, regularity and duration of particular exposures. Subject to and without waiving any objections, JMM refers Plaintiffs J-M MANUFACTURING COMPANY, rNC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 17 4213715.1 Williams, Kastncr & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 lo its objections and answer (o Interrogatory No. 24, which are incorporated herein by reference. INTERROGATORY NO. 26: Did Defendant, any predecessor or any related company, or any workers' compensation insurance carrier thereof, ever have any claims for lung diseases or death from lung disease, whether directly or indirectly attributed to asbestosis, mesothelioma, hmg cancel,, or exposure to asbestos-containing products? RESPONSE: JMM incorporates herein its Preliminary Statement and Genera! Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. Subject to and without waiving any objections, JMM states that Plaintiffs' counsel are already in possession of documents and information responsive to this interrogatory. INTERROGATORY NO. 27: If your answer to original Interrogatory No. 26 was "Yes/' please provide the following information for each of the first live (5) claims. a. Identify the claimant; b. Identify the entity against which the claim was filed; c. State the date upon which the claim was filed; d. List the locations(s) at which claimant was exposed to asbestos; e. Identify each and every board, administrative body, commission or court which handled or reviewed said claim and state the state the style and cause number applicable to said claim before each such body; f. Identify the disease alleged by claimant; g. State the final disposition of the claim including any and all benefits paid, and the entity making such payments; h. If different from the date on which the claim was filed, state the date on which defendant first had notice of the claim; and i. Identify any and all documents referring to, relating to or reflecting said claim. RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 18 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite4100 Seattle, Washington 98101-2380 (206) 628-6600 of this case, and seeks information and documents dial are not relevant or reasonably calculated to lead to the discovery of admissible evidence. JIMIV! further objects to this interrogatory to the extent that it seeks information or documents that are protected by the attorney client privilege, work product doctrine or are otherwise protected. INTERROGATORY NO. 2H: Identify any and all material safety data sheets concerning the products listed in response to Interrogatory No. 6 prepared, at any time, by, or on behalf of, Defendant, any predecessor or any related company. RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is overbroad, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. Subject to and without waiving any objections, JMM states that JMM did not manufacture the A/C pipes and couplings and investigation to date has not indicated that JMM ever prepared material safety data sheets concerning sucli products. INTERROGATORY NO. 29: Identify any and all trade organizations, associations, or other entities, including but not limited to American Textile Institute (ATI), Asbestos Information Association (AIA), Industrial Health Foundation or Industrial Hygiene Foundation (IHF), National Insulation Manufacturers Association (NIMA), National Insulation Contractors Association (NICA), National Safety Council (NSC), American Ceramics Society (ACS), National Building Materials Distributors Association (NBMDA), Sprayed Mineral Fiber Manufacturers Association (SMFMA), Thermal Insulation Manufacturers Association (TIMA), Quebec Asbestos Mining Association (QAMA), to which Defendant, any predecessor or any related company has belonged or in which any or all j of the same have participated since 1925, and state the applicable dates of such membership or participation. RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected and to the extent it seeks information which is as equally accessible to Plaintiffs as to JMM. Subject to and without waiving any J-M MANUFACTURING COMPANY, rNC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 19 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101 -2380 (206) 628-6600 objections, JMM states that at certain times it lias belonged or pnrtieipakd in the following organizations: American Gas Association, American Society lor Testing Materials, American Waterworks Association, International Association of Plumbing and Mechanical Official, Factory Mutual Research Corporation, National Flcctrical Manufacturers Association, National Sanitation Foundation, Plastic Pipe and Fitting Association, Plastic Pipe Institute, Underwriters Laboratories, Uni-Bell PVC Pipe Association, and The Vinyl Institute. INTERROGATORY NO. 30: Identify any and all present or former directors, officers, employees, or agents of defendant, any predecessor or related company, who have testified in any manner whatsoever including a discovery or evidence deposition, or in a trial, in the last 20 years on behalf of or against the defendant, any predecessor, or related company, in any lawsuits involving a claim or claims based upon allegations of personal injury or property damage caused by exposure to, the use of, the application of, the installation of, or the presence of any asbestos or asbestoscontaining product, other than persons who testified as plaintiffs in their own cases. Specifically included within the scope of this request are any suits involving the issue of insurance coverage for claims of personal injury or property damage resulting from the exposure to, the use, application, installation or presence of asbestos or asbestos-containing products. RESPONSE: JMM incorporates herein its Preliminary Statement and General Objeetions and further objects to this interrogatory on the following specific grounds: the interrogatory is overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. Subject to and without waiving any objections, JMM states that its corporate representative Jim Reichert may have knowledge regarding information responsive to this interrogatory. Jim Reichert has been deposed on (i) November 14, 2000 in Hardcastle v. Advocate Mines', (ii) May 6, 2008 in Bradford v. A. W. Chesterton Company, et at.', (iii) May 7, 2008 in PaulPlacencia v. American Standard; Inc.', (iv) August 19, 2008 in Larry Stewart v. A.W. Chesterton, et al; (v) July 8, 2008 in Kermit Kelly, et al v. American Cast Iron Pipe Company, et al.', (vi) September 4, 2008 in Wallace Davis v. A. W. Chesterton Company, et al.', (vii) on July 22, 2009 in William Church, et al. v. Asbestos Corporation, et al.', (viii) September 29, 2009 in Ralph Miller v. A.W Chesterton Company, et al.', (ix) July 7, 2010 in Roberta K. Echaves, et al. v. 3M Company, et al.', (x) October 19, 2011 in Byron George, et al. v. Amcord, Inc., et al.', (xi) April 23, 2012 in Donald Mendel v. Ameron International Corp., et al.; (xii) September 19, 2012 in Elizama Longer, et al. v. 3M Company, et al.; (xiii) February 11, 2013 in Ernest Ornellas, et al. v. A.H. Voss Company, et al; (ixv) February 15, 2013 in John Milton Stephens, et al. v. AC and S, Inc., et J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 20 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 al.\ (xv) April 15, 2013 in Marguerite Jlloont, ct at. v. ( ulportland Company, ct at.; nml (xvi) April 16, 2013 in Kerry Kanonas, ct at. v. Amcord, Inc., ct at. INTERROGATORY NO. 31: With respect to your answers to Interrogatory No. 30, identify any and all documents, including, but not limited to, transcripts or notes of testimony, referring to, relating to or reflecting the testimony of such expert witnesses or employees, directors, officers, or agents. RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is premature, vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information and documents that are not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. INTERROGATORY NO. 32: Has Defendant, any predecessor or any related company, ever been cited, warned, fined, sanctioned or otherwise officially written up for, any violation of a federal, state or local statute, law, rule, ordinance, code, administrative order, executive order, or the like, by any federal, stale or local governmental entity, which violation concerned asbestos in any way? RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. JMM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. INTERROGATORY NO. 33: If your answer to Interrogatory No. 32 is "Yes," with respect to each such violation: a. Identify the governmental entity issuing the citation, warning, fine, sanction or write up; b. State the date of the citation, warning, fine, sanction or write-up; c. Describe the violation and state the date(s) during which it occurred; d. Identify the statute, law, rule, ordinance, code or order to which the violation related; J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 21 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 4213715.1 e. State what, if any, specific fine, penalty, or sanction was imposed; f. State the date and the manner in which said violation was corrected; g. Identify any and all officials of Defendant, its predecessor or its related company having knowledge or notice of said violation and state the date on which said knowledge or notice was received; and, h. Identify any and all documents referring to, relating lo or reflecting said violation. RESPONSE: JMM incorporates herein its Preliminary Statement and General Objections and further objects to this interrogatory on the following specific grounds: the interrogatory is vague, overbroad, overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. .IMIM further objects to this interrogatory to the extent that it seeks information that is protected by the attorney client privilege, work product doctrine or is otherwise protected. INTERROGATORY NO. 34: Is the defendant, any predecessor or related company, claiming any document responsive to any interrogatory or any request for production filed by Simmons Browder Gianaris Angelides & Barnard LLC as being protected from disclosure because of a privilege claimed for any reason? If yes, please list each document being claimed as protected from disclosure in a privilege log providing the date of the document, the identity of the author, what individual or entity the document was addressed to, the identity of any individuals or entities provided copies of the document, a brief description of the nature of the document, and the particular privilege claimed as shielding the document from disclosure. RESPONSE: JMM will identify by privilege log on a continuous basis any document it determines should be withheld on the basis of privilege. INTERROGATORY NO. 35: State whether this defendant has ever generated reports in compliance with the Asbestos Information Act of 1988, Pub. L. 100-577, 15 U.S.C. Section 2607, and if so for each such document, please state; a. The date said documents were generated and filed; b. The location of any copies of said reports under the control of this defendant; c. The location of any draft reports, memos or any other notes concerning the preparation of said reports; and d. The name, address and phone number of the individual having custody and control of each said report. J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 22 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 be installing, servicing, or removing the asbestos-containing products, including but not limited to any asbestos-cement, pipe and, it so, describe I he same, stale to whom 2 they were given, the dates they were given, and deseiibe (lie manner in which they were given. 3 RESPONSE: Not Applicable. 4 INTERROGATORY NO. 38: 5 If your answer to Interrogatory No. 36 was in the affimmtive, for each asbestos- 6 containing product, including but not limited to any asbestos-cement pipe, state: a. T3ie type of asbestos contained in the product as it was first manufactured; 7 b. The percentage of asbestos contained in the product as it was first manufactured; c. Any modification to the product which altered the percentage or type of asbestos in 8 the product and the dates of such modification; d. The source or supplier of asbestos in each product and/or of the asbestos-containing 9 product; e. The color, physical characteristics, and appearance of each product; 10 f. Any and all other names under which the product was sold, at any time; g. The number and date of each patent or patent application for each product; 11 h. If the product continued to be produced alter the deletion of asbestos, all reasons why the asbestos was deleted, the identity of the person(s) who made the decision to delete 12 the asbestos, and the date the product was first produced without the asbestos; i. If the product is no longer produced, all reasons it was discontinued, the identity of 13 the person(s) who made the decision to discontinue the product, the brand name of the replacement product, and the date the replacement product first went into 14 production; and j. The reasons why asbestos was used as an ingredient in each such product. 35 RESPONSE: 16 Not Applicable. 17 Responses to INTERROGATORIES submitted this 30th day of July, 2013. 18 WILLIAMS, KASTNER, & GIBBS PLLC 19 By: 20 Amanda L. Spencer, WSBA #42023 21 Attorneys for Defendant 22 ]013565vl J-M Manufacturing Company 23 J-M MANUFACTURING COMPANY, INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES - 24 4213715.1 Williams, Kastner & Gibbs PLLC 601 Union Street, Suite 4100 Seattle, Washington 98101-2380 (206)628-6600 1 yjuiHrryMK 2 DONALD NOLL, ci !. v. UNION CARKimt CORPORATION, cl at Cause No. M 2 06781 I 3! I have read the foregoing DEFENDANT J-M MANUFACTURING COMPANY, INCUS 4 OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES and know Us 5 contents. 6 I am Special Assistant to the President of J-M MANUFACTURING COMPANY, INC., 7 a party to this action, and am authorized to make this verification for and on its behalf, and .1 8 make this verification for that reason. I am informed and believe and on that /pound allege that 9 the matters staled in the foregoing document arc hue. 10 Executed on this ? 9 day of y 2013, at Los Angeles, California. 11 I declare under penalty of perjury under the laws of the Stales of California and n Washington and that the foregoing is true and correct. 13 14 15 16 17 -Gnr~ 18 ovm 19 20 21 22 23 CALIFORNIA JURAT WITH AFFIANT STATEMENT tiOVi nwMi Ht com? & mtyj i^fsee Attached Document (Notary to cross out linos t- 6 Inflow) [J See Statement Below (Lines 1-6 to be completed only by documonl siynerls], not Notary) Signature of IXxumont Sigoor No, 1 State of California County of .L^_Ao^k^ A A .A Ak At, A. C. C. HERRAWf Cowpfcste* # 2007*31 HOQiy. IMM.t-------ft artli i *TStmWmWB lo> Cownty g aCvo9m9o. Expire* F* STY* lip II. 20171 Place Notary Seal Above Sigiicilutu ol iXxxifiiwii Signoi Wo. X (il .niy) Subscribed and sworn to (or affirmed) before me on this 3^1- day of by _____ J 20JL2?.. Ynai (i >j^avxy...U'Ci...........__........... ..... Name ol Signcf proved to me oil the basis of satisfactory evidence to bo the person who appeared before me (.) (and (2)rrr__ ___________ ___ Nan* crl Skjiuo proved to me on the basis of satisfactory evidence to be the person who appeared before me.) Signature OPTIONAL Though the information below is not required by law, it may prove valuable to persons relying on the document and could prevent fraudulent removal and reattechment of this form to another document. Further Description of Any Attached Document Title or Type of Document: Document Date; 0*1 -- t ~hNumber ol Pages; _____________ __ L 2010 National Notary Association * NaBonoWotory.cxg - 1-600-US NOTARY (l-&00-576-6a2?7 ftemrS9to aamEi^:reiMLa$Bvicis The undersigned certifies under penalty of perjury under the laws of the Slate of Washington that on the below date, 1 caused to he served via email, messenger, and/or US. M postage pro-paid, a true and correct copy of the foregoing document to the .following: Benjamin R. Couture Brian D. Weinstein WEINSTEIN COUTURE PLLC 1001 Fourth Avenue, Suite 4400 Seattle, WA 98154 Email: service@wcinstcinconture.cpm Attorneys for Plaintiffs Rob Woodward Ryan J. Kiwala SIMMONS BROWDER GIANAR1S ANGEIJDES & EARNER!) EEC One Court Street Alton, IE 62002 Email: rwoodward@shBmonsErm.eom; rkiwaia@.simrnonsfinn.com Co-counselfor Plaintiffs Melissa K. Roeder Polly K. Becker FORSBERG & UMLAUF 901 Fifth Avenue, Suite 1400 Seattle, WA 98164 Email: asbestos3@rorsberg-unilauf.eom; T?becker@,forsberg-um)auf.com Attorneyfor American Biltrite, Inc. Christopher S. Marks Eliot M. 1 larris Rachel Talion Reynolds SEDGWICK, EEP 520 Pike Street, Suite 2200 Seattle, WA 98101 Email: ehris.marks@scdgwiek)aw,com; eliot.harns@scdgwicklaw.com; rachel.revnoids@sedgwicklaw.com Attorneysfor CBS Corporation; General Electric Company Diane J. Kero GORDON THOMAS HONEYWELL, LLP 600 University Street, Suite 2100 Seattle, WA 98101 Email: service@gth-law.com Attorneyfor CertainTeed Corporation; Bird, Inc. Jeanne F. Loftis BULLIVANT HOUSER BAILEY PC 888 SW Fifth Avenue, Suite 300 Portland, OR 97204-2089 Email; asbestos-pdx@bullivant.eom Attorneyfor Borneo Products Texas, Inc. 4213715.1 Mark Fucile Daniel J. Kcising 2 FUC1LH & RBI SI NO, LLP 800 NW Sixth Avenue, Suite 211 3 Portland, OR 97209 Emai1: servicc@fr)lp.c-om 4 Attorneysfor Ford Motor Company 5 Jim Gidley 6 PERKINS GOJK LLP 1120 NW Couch Street., 10th Floor 7 Portland, OR 97209 Email: igidIey@perkin.scoie.com 8 Attorney for Honeywell International, Inc. 9 Steven W. Fogg Hugh E. Handeyside 10. CORR CRONIN LLP 1001 Fourth Avenue, Suite 3900 1 1 Seattle, WA 98154-1051 Email: asbestos@corrcronin.com; 12 sfogg@coiTcronin.com; hhandevside@corrcronin.com 13 Attorneysfor Industrial Holdings Corporation 14 J. Michael Mattingly 15 RIZZO MATTINGLY BOSWORTH PC 411 SW Second Avenue, Suite 200 16 Portland, OR 97204 Email: recordsmanagement@rizzopc.eom 17 Attorneysfor Kclly-Moore Paint Company, Inc. 18 Timothy K. Thorson 19 CARNEY BADLEY SPELLMAN, P.S. 701 Fifth Avenue, Suite 3600 20 Seattle, WA 98104 Email: asbestos@camevlaw.com 21 Attorneyfor Saberhagen Holdings, Inc. 22 23 Hai ry N. Mesher Ihinn I). Zeringer SEDGWICK, LLP 520 Pike Street, Suite 2200 Seattle, WA 98101 Email: hairy nuu:hiu^]ie(.jjy^yi^kJ.^w,coin; briun./.cnngAU Attorneys for Georgia Pacific, l.J.C Pain P. Fraser PERKINS COlE LLP J201 3rd Avc.Sic 4800 Seattle, WA 98101- 3099 Email: HW asbestos.SEA@Perkinscoio.com Co-counselfor Honeywell International, Inc. Mark 13. Tuvim Kevin J. Craig GORDON & REES, LLP 701 Fifth Avenue, Suite 2130 Seattle, WA 98104 Emai 1: asbestos-sea@gordonrecs.com Attorneysfor Ingersoll-Rand Company Marissa A. Alkhazov BETTS PATTERSON MINES 701 Pike Street, Suite 1400 Seattle, WA 98101 Email: malkha2ov@bDmlaw.com; betts-asbestos@bpmlaw.com Attorneyfor Pfizer, Inc. Ronald C. Gardner GARDNER TRABOLSI & ASSOCIATES, PLLC 2200 Sixth Avenue, Suite 600 Seattle, WA 98121 Email: asbestos@gandtlawfirm.com Attorneyfor Simpson Timber Company; Simpson Lumber, LLC 4213715.1 o 1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Jeffrey M. Wolf Amanda L. Spencer WILLIAMS, KASTNLK & GIBBS 601 l Jnion Street, Suite 4100 Seattle, WA 98101 Lmail: wkgu.sbfffStos@williamsko8tMcr.com Attorneysfor Kaiser tiypsum Company, Inc. Signed at Seattle, Washington this 30,h day of July, 2013. s/Diane M. Bui is WILLIAMS, KASTNER & GIBBS PLLC 601 Union Street, Suite 4100 Seattle, WA 98101-2380 Telephone: (206) 628-6600 Fax: (206)628-6611 Email: dbulis@williaiTiskastner.com 4213715.1