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PAGE 4 VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF NEWPORT NEWS D. GARLAND MOORE, WILLIAM L. KELLEY, Plaintiffs, V. H.K. PORTER COMPANY, INC., et al. Defendants. AT LAW NOS. 13 603-S, 14062-S & 14577-S AT LAW NO. 13945-S RESPONSES OF DEFENDANT MANVILLE CORPORATION ASBESTOS DISEASE COMPENSATION FUND TO PLAINTIFFS' INTERROGATORIES Defendant Manville Corporation Asbestos Disease Compensation Fund (hereafter "the Fund"), by and through its attorneys, KNIGHT, DUDLEY, DEZERN & CLARKE, hereby submits the following Responses to Plaintiffs' Interrogatories. PRELIMINARY MATTERS The Fund objects to these discovery requests to the extent that they ask for information relating to the Fund's involvement in the asbestos industry. The Fund has never been involved in the manufacture, sale or distribution of asbestos or asbestos containing products. Nevertheless, the Fund interprets these questions to relate to Manville Corporation, its predecessors or subsidiaries (hereafter "related entities"). The Fund objects to these discovery requests to the extent that they call for production of documents entitled to protection as privileged attorney client communications or attorney work product. To the extent that the information contained herein differs in any respect from any prior response to discovery, these answers shall be deemed to update and supersede such prior answers in any and all cases. The Fund reserves the right to supplement these responses to the extent that new or additional information becomes available. RESPONSES Interrogatory No. 1: Describe in detail Manville's complete corporate history, including, but not limited to, date and place of incorporation, corporate purpose, principal place of business, and location of sales offices, and including any mergers, consolidations, asset purchases, acquisitions or spinoffs which concern or affect manufacture, sale, or distribution of asbestos-containing products. In addition: (a) State the name of any subsidiary or predecessor corporation, its date of incorporation, and its corporate purposes; (b) If Manville has bought or sold any asbestos product line or stock in a company dealing in asbestos-containing products, state the date of the sale and identify the seller or purchaser; (c) Identify each document related to the history or transaction(s) set forth above. (d) State whether Manville agreed to be, or has been held by any Court to be, legally responsible for the past liabilities of any nature of any other such corporation or entity. For each Court which has so held, identify the case, the jurisdiction of the Court, and the date of the Order. RESPONSE: For many decades, Manville Corporation or related entities engaged in the manufacture and sale of asbestos containing products, as well as the mining, milling and sale of asbestos fiber. The H. W. Johns Company, a predecessor to Manville Corporation, first commenced business in 1858. Manville Corporation or related entities first became involved in the mining and milling of asbestos in 1916 when it purchased the Jeffrey Mine in Asbestos, Quebec. Johns-Manville Corporation was incorporated in New York in 1927. Johns-Manville Products Corporation, incorporated in 1927 in Delaware, was responsible for the manufacture of asbestos containing products. Johns-Manville Sales Corporation, incorporated in 1929 in Delaware, was responsible for the sale of asbestos containing products. In 1975, Johns-Manville Products Corporation merged into Johns-Manville Sales Corporation. A corporate reorganization in 1982 created a new parent corporation known as Manville Corporation, and in 1985 Johns-Manville Sales Corporation became Manville Sales Corporation. 2 Manville Corporation or related entities' principal place of business is Denver, Colorado. Upon information available to the Fund the following subsidiaries of Manville Corporation or related entities at one time were related to the asbestos industry. CURRENT MANVILLE SUBSIDIARIES Cobra Canada, Inc. (50% owned by American Standard) Incorporated in Canada Name changed from Cobra Friction Products, Limited - 1981 Johns-Manville Corporation Incorporated in New York - 1926 Authorized to do business in Colorado, New Jersey, and New York Georgia, New Hampshire, Johns-Manville East Africa, Limited Incorporated in Delaware - 1968 Authorized to do business in Delaware Johns-Manville India, Limited Incorporated in Delaware - 1965 Authorized to do business in Delaware Manville (Great Britain) Limited Incorporated in the United Kingdom of Great Britain and North Ireland Name changed from Johns-Manville (Great Britain) Limited - 1982 Manville De France S.A. Incorporated in France Name changed from Johns-Manville De France S.A. - 1982 Manville Do Brazil Ltda. Incorporated in Brazil Name changed from Johns-Manville Do Brazil - 1982 Manville Italian S.p.A. Incorporated in Italy Name changed from Johns-Manville Italiana S.P.A - 1982 Manville Japan, Limited Incorporated in Japan Name changed from Johns-Manville Japan, Limited - 1981 Manville Mexicana S.A. de C.V. Incorporated in Mexico Name changed from Johns-Manville Mexicana, S.A. de C.V. - 1982 3 Manville Sales Corporation Incorporated in Delaware Authorized to business in all fifty sates and the District of Columbia Name changed from Johns-Manville Sales Corporation - 1985 Manville Sudamericana Ltda Incorporated in Delaware Authorized to do business in Delaware Name changed from Johns-Manville Sudamericana, Limited - 1982 New Materials, Inc. Incorporated in New York - 1958 Authorized to do business in New York Railroad Friction Products (50% owned by American Standard) Incorporated in Delaware - 1954 Authorized to do business in Arizona, Arkansas, California, Delaware, Georgia, Idaho, Illinois, Indiana, Kansas, Maryland, Minnesota, Missouri, New York, North Carolina, North Dakota, Oregon and Pennsylvania Termoacusticos, S.A. de C.V. Incorporated in Mexico - 1973 PREVIOUS MANVILLE SUBSIDIARIES Acoustical Construction Corporation Incorporated in New York - 1930 Dissolved - 1946 American Mineral Company Name changed from Seehaver Clay & Mineral Company - 1947 Incorporated in California Merged into Desert Minerals, Inc. - 1975 Asbestos Construction Company, Inc. Incorporated in New York - 1922 Name changed to Johns-Manville Insulation Contracting & Supply Company - 1960 Asbestos and Danville Railway Company Incorporated in Quebec, Canada - 1897 Authorized to do business in Quebec Divested - 1982 Banner Rock Corporation Incorporated - 1929 Dissolved - 1938 4 Beton et Mollith S.A. Incorporated in Belgium - 1923 Name changed to Johns-Manville S.A Canadian Johns-Manville Asbestos, Limited Incorporated in Canada - 1954 Name changed to Johns-Manville Amiante Canada, Inc. - 1980 Canadian Johns-Manville Ontario, Limited Incorporated in Ontario, Canada - 1950 Dissolved - 1968 Celite Corporation Name changed from Fibre Corporation - 1928 Dissolved - 1939 Chem Blend System Corporation Incorporated in New Jersey - 1965 1970 - Acquisition Dissolved - 1972 Coalinga Asbestos Company, Inc. Incorporated in Delaware - 1960 Authorized to do business in California and Delaware Merged into Johns-Manville Sales Corporation - 1975 Cobra Friction Products, Limited (50% Held by J-M - 1981) Incorporated in the Dominion of Canada - 1960 Authorized to do business in the Dominion of Canada Name changed to Cobra Canada, Inc. Crown Tuft Carpet, Inc. Incorporated in Georgia - 1963 Merged into Johns-Manville Products Corporation - 1972 Divested to Celotex Corporation - 1972 Delaware Johns-Manville Corporation Incorporated - 1927 Name changed to Johns-Manville Corporation of Delaware - 1927 Desert Minerals, Inc. Incorporated in California - 1956 Merged into L. Grantham Corporation - 1975 Fibre Corporation Incorporated - 1914 Name changed to Celite Corporation - 1928 Grantham Mines Corporation Incorporated in California - 1969 Name changed to L. Grantham Corporation - 1969 5 Holophane Company, Limited (The) Incorporated - 1911 Amalgamated with Canadian Johns-Manville - 1978 Company, Limited Holophane S.A. de C.V. Incorporated in the Dominion Authorized to do business in Jersey and the Dominion Divested - 1988 of Canada California, of Canada 1962 New York, Ohio, New Interstate Flooring and Construction Company, Incorporated - 1930 Dissolved - unknown Inc. Jayem Exploration Company, Limited Incorporated in Quebec, Canada - 1961 Dissolved - 1980 John Brand Corporation Incorporated in Delaware Name changed from Johns-Manville Dutch Brand Products - 1970 Dissolved - 1972 Johns-Manville (Great Britain), Limited Incorporated in the United Kingdom of Great Britain and North Ireland Name changed from Johns-Manville Company, Limited - 1966 Name changed to Manville (Great Britain) (Limited) - 1982 Johns-Manville (United Kingdom), Limited Incorporated - 1959 Merged into Johns-Manville Company, Limited - 1965 H. W. Johns Manufacturing Company Incorporated - 1858 Reorganized as H. w. Johns Manufacturing Company - 1874 Merged with Manville Covering Company to become H.W. Johns-Manville Company - 1901 H. W. Johns-Manville Company Organized through merger between Manville Covering Company and H. W. Johns Manufacturing Company - 1901 Name changed to Johns-Manville, Inc. - 1920 Johns-Manville Amiante Canada, Inc. Incorporated in Canada Authorized to do business in Quebec, Canada Name changed from Canadian Johns-Manville Asbestos, - 1980 Sold - 1983 Limited 6 Johns-Manville Belgium, S.A. Incorporated in Belgium - 1961 Divested - 1983 Johns-Manville Boley, Limited Incorporated in Delaware - 1931 Name changed to Johns-Manville Sudamericana, Limited - 1955 Johns-Manville Canada, Inc. Incorporated in the Dominion of Canada - 1978 Authorized to do business in Alberta, British Columbia, Manitoba, New Brunswick, Nova Scotia, Ontario, Prince Edward Island, Quebec, Saskatchewan and Yukon Territory Sold - 1983 Johns-Manville Ceiling Corporation Incorporated - 1973 Name changed to Southern Johns-Manville (Delaware) - 1973 Products Corporation Johns-Manville Company, Limited (United Kingdom) Incorporated in the United Kingdom - 1939 Name changed to Johns-Manville (Great Britain), Limited - 1966 Johns-Manville Construction Incorporated - 1956 Name changed to Johns-Manville Service Corporation - 1960 Johns-Manville Corporation of Delaware Name changed from Delaware Johns-Manville Corporation - 1927 Name changed to Johns-Manville Products Corporation - 1932 Johns-Manville De France S.A. Incorporated in France Name changed from Societe Anciens Establissements Chataignon, Flechet et Cie., Succs. - 1961 Name changed to Manville de France S.A. - 1982 Hordot and Johns-Manville De Ventas S.A. de C.V. Incorporated in Mexico - 1962 Name changed to Johns-Manville Mexicana, S.A. de C.V. - 1962 Johns-Manville Development Corporation Incorporated in Delaware Authorized to do business in California, Colorado, Illinois, New Jersey and Ohio Name changed to Johns-Manville Service Corporation - 1973 Merged into Johns-Manville Sales Corporation - 1975 7 Johns-Manville Do Brazil Isolantes Termicos, Limited Incorporated in Brazil Name changed from Johns-Manville do Brazil S/A Isolantes Termicos - 1977 Name changed to Manville Do Brazil, Limited - 1982 Johns-Manville Do Brazil S/A - Isolantes Termicos Incorporated in Brazil Name changed from Magnebras, S.A. - 1976 Name changed to Johns-Manville Do Brazil Isolantes Ltda - 1977 Termicos Johns-Manville Dutch Brand Products Corporation Incorporated in Delaware Name changed from Van Cleef Brothers, Inc. - 1955 Name changed to John Brand Corporation - 1970 Johns-Manville Equipment Corporation Incorporated in Delaware - 1961 Merged with Johns-Manville Sales Corporation - 1973 Johns-Manville, Inc. Name changed from H. W. Johns-Manville Company - 1920 Dissolved - 1927 Johns-Manville Insulation Contracting & Supply Company, Inc. Incorporated in New York Name changed from Asbestos Construction Company, Inc. Merged into Johns-Manville Sales Corporation - 1962 1960 Johns-Manville International Corporation Incorporated in Delaware - 1929 Authorized to do business in California, Florida, New York and Texas Merged into Manville Sales Corporation - Colorado, 1986 Delaware, Johns-Manville Italiana S.p.A. Incorporated in Italy Name changed from Silex S.p.A. - unknown Name changed to Manville Italiana S.p.A. - 1982 Johns-Manville Japan, Limited Incorporated in Japan Name changed from New Materials Kabushiki Kaisha - 1978 Name changed to Manville Japan, Limited - 1981 Johns-Manville Mexicana S.A. de C.V. Incorporated in Mexico Name changed from Johns-Manville de Ventas S.A. de C.V. ~ 1962 Name changed to Manville Mexicana S.A. de C.V. - 1982 8 Johns-Manville Mining and Trading Incorporated in Delaware - 1966 Merged into Johns-Manville Corporation - 1973 Johns-Manville (Overseas), Limited Incorporated in the Province of Ontario - 1958 Authorized to do business in Ontario Dissolved - 1981 Johns-Manville Products Corporation of California Incorporated in Delaware - 1956 Authorized to do business in California Merged into Johns-Manville Products Corporation - 1972 Johns-Manville Products Corporation Incorporated in Delaware Authorized to do business in AZ, KS, KY, LA, ME, MD, MA, MI, NY, NC, OH, OR, PA, TN, TX, Name changed from Johns-Manville - 1932 Merged with Johns-Manville Sales CA, CO, DE, MN, MS, MO, UT, VA, WA Corporation Corporation FL, IL, IN, NE, NV, NH, of Delaware - 1975 IA, NJ, Johns-Manville Products Corporation of Georgia Incorporated in Delaware - 1955 Merged into Johns-Manville Corporation - 1970 Johns-Manville Products Corporation of Massachusetts Incorporated in Delaware - 1939 Merged into Johns-Manville Products Corporation - 1972 Johns-Manville Products Corporation of Mississippi Incorporated in Delaware - 1958 Dissolved - 1966 Johns-Manville Products Corporation of Ohio Incorporated in Delaware - 1959 Dissolved - 1972 Johns-Manville Products Corporation of Oregon Incorporated - 1956 Merged into Johns-Manville Corporation - 1962 Johns-Manville Products Corporation of Pennsylvania Incorporated in Pennsylvania - 1940 Merged into Johns-Manville Sales Corporation - 1975 Johns-Manville S.A. Incorporated in Belgium Name changed from Beton et Mollith Divested - 1983 9 Johns-Manville Sales Corporation Incorporated in Delaware - 1929 Name changed to Manville Sales Corporation - 1985 Johns-Manville Service Corporation Incorporated in Delaware Name changed from Johns-Manville Construction Corporation - 1960 Name changed to Johns-Manville Development Corporation - 1973 Johns-Manville Sudamericana, Limitada Incorporated in Delaware Name changed from Johns-Manville Boley, Limited - 1955 Name changed to Manville Sudamericana, Limitada - 1982 Kingsey Falls Paper, Inc. (50% owned by Johns-Manville) Incorporated in Quebec - 1972 Authorized to do business in Quebec Sold - 1984 L. Grantham Corporation Incorporated in California Authorized to do business in California Name changed from Grantham Mines Corporation - 1969 Acquired in 1972 Merged into Johns-Manville Sales Corporation - 1978 Magnebras, S.A. Incorporated in Brazil - 1957 1973 - Acquisition Name changed to Johns-Manville Do Brazil, Termicos - 1976 S.A. - Isolantes Manvilglass, Limited Incorporated in Delaware - 1970 Authorized to do business in Delaware and Argentina Name changed to Thermocoustic Insulations, Limited - 1976 Manville Covering Company Incorporated - 1886 Merged into H. W. Johns Manufacturing Company - 1901 New Materials Kabushiki Kaisha Incorporated in Japan - 1959 Name changed to Johns-Manville Japan, Limited - 1972 Nicely Corporation (The) Incorporated - 1933 Dissolved - 1946 10 Revere Mills, Inc. Incorporated - 1964 Name changed to Revere, Inc. - 1965 Revere, Inc. Name changed from Revere Mills, Inc. - 1965 Merged into Crown Tuft Carpet, Inc.- 1972 Seehaver Clay and Mineral Company Incorporated in California - 1946 Name changed to American Mineral Company - 1947 Silex S.p.A. Incorporated in Italy Name changed to Societa Anonima Immobiliare esari - 1940 Name changed to Johns-Manville Italiana S.p.A. - 1962 Societa Accomandita Semplice Silex Incorporated - 1940 Merged into Societa Anonima Immobiliare Cesari - 1940 Societa Anonima Immobiliare Cesari Incorporated in Italy - 1939 Name changed to Silex S.p.A. - 1940 Societe Anciens Establissements Hordot Cie., Succs. Incorporated - 1961 Name changed to Johns-Manville De and Chataignon, Flechet France S.A. - 1961 et Southern Johns-Manville Products Corporation Incorporated in Delaware Name changed from Johns-Manville Ceiling Corporation - 1973 Merged into Johns-Manville Sales Corporation - 1979 Table Mountain Asbestos Company, Incorporated - 1962 Dissolved - 1967 Inc. Thermocoustic Insulations, Limited Incorporated in Delaware Name changed from Manvilglass, Limited - 1976 Merged into Johns-Manville Sudamericana Limitada - 1976 Van Cleef Name Name Brothers, Inc. changed from Vee Cee Brothers, Inc. changed to Johns-Manville Dutch Brand Corporation - 1955 1947 Products Vee Cee Brothers, Inc. Incorporated - 1947 Name changed to Van Cleef Brothers, Inc. - 1947 11 Additionally, the names of any consolidation, merger or purchase of assets of any company by Manville Corporation or related entities can be obtained by a review of the Annual Reports of Manville Corporation and related entities, and the location of sales offices can be obtained from a review of corporate organizational charts. Copies of such reports and organizational charts are located at the records repository maintained by the Fund in Denver, Colorado, and will be made available for inspection and copying at a time agreed upon by the parties. RECORDS REPOSITORY All of the non-privileged documents in the possession, custody and control of the Fund which were obtained from Manville Corporation and which relate to asbestos litigation are located in a records repository in Denver, Colorado. The Fund assumed the management and operation of this repository on November 28, 1988, the date on which the Manville Corporation bankruptcy plan was consummated. The repository was originally set up and managed by Manville Corporation to house the documents which Manville retrieved and produced in previous litigation. In 1983, pursuant to an order entered by Judge Ira Brown of the Superior Court in the City and County of San Francisco, Manville Corporation was required to produce all non-privileged documents relevant to the coverage litigation which Manville Corporation had commenced against its insurance carriers. That litigation was brought to establish Manville Corporation's right to defense and indemnification for costs incurred in connection with the asbestos litigation. The insurance litigation was ultimately settled for sums in excess of $800 million. In order to comply with Judge Brown's order, Manville Corporation hired numerous paralegals and law clerks and undertook a massive and comprehensive review of the corporate records of the company which existed at various Manville facilities world wide. Manville spent literally millions of dollars to gather and maintain this collection of documents. Similarly, beginning in 1985, Manville Corporation was required to produce the vast majority of these same documents to representatives of the United States Department of Justice, in connection with Manville's actions against the United States. In those cases, Manville Corporation was claiming a right to indemnification or contribution for expenses incurred in the defense of asbestos health cases brought by workers employed in government owned or controlled shipyards. These documents are currently kept at the document repository referred to above. The repository is now maintained and operated by the Fund. 12 Manville Fund Document Categories The repository contains 19,317 boxes and 968 rolls of microfilm. These documents are grouped in nine categories: 01: 02: 03: 04: 05: 06: 07: 08: 09: Manville plant collection - 10,383 boxes Waukegan plant collection - 4,908 boxes Lompoc plant collection - 149 boxes World Headquarters (WHQ) collection - 3,417 boxes Microfilm from Manville WHQ - 492 rolls Microfilm from Manville WHQ - 361 rolls Documents sent by Local Counsel - 385 boxes Microfilm with Redacted Documents - 115 rolls Documents produced in January, 1989 - 73 boxes The Manville Plant collection (01) includes documents from the Manville, NJ plant; the Nashua, NH plant; the Billerica, MA plant; the Savannah, GA plant; the Laurinburg, NC plant; and the Fort Worth, TX plant. It also includes documents sent to the plant for storage from Manville General Headquarters prior to the early 1970s, when the Headquarters offices were located in New York. In addition, this collection includes documents from plants in the eastern United States which were closed prior to the 1980s. The Waukegan Plant collection (02) includes documents from the Waukegan, IL plant and the Oak Brook, IL office. The Lompoc Plant collection (03) includes documents from the Lompoc, CA plant. The World Headquarters (WHQ) collection (04) includes documents which were obtained from a number of locations, including: the Denison, TX plant; the Franklin, PA plant; the Green Cove Springs, FL plant; the Jeffrey Mine in Asbestos, Quebec, Canada; the Long Beach, CA plant; the Lompoc, CA plant; the Marrero, LA plant; the Manville offices in Montreal, Quebec, Canada; the Pompano Beach, FL plant; the Pittsburg, CA plant; the Stockton, CA plant; and the Waukegan, IL plant. The WHQ collection also includes documents obtained from the files maintained at the World Headquarters, including: the Asbestos Fiber Division; the Audio-Visual Department; Manville Contract Units; the Corporate Information Center; the Corporate Relations Department; the Engineering Department; the Executive offices; the Fiberglass Division; the Filtration and Minerals Division; the Finance Department; the Health, Safety, and Environment offices; the Holophane Division; the Industrial Products Division; the Labor Relations offices; the Legal Department; the Patent and Licensing offices; the Research and Development offices; Sales Offices; and Workers' Compensation records. 13 Finally, the WHQ collection also includes: asbestos health claims filed against Manville; bankruptcy related materials; documents from the historical records kept at Manville headquarters ("B-Level"); insurance loss runs and policies; local counsel files; legal department files; and miscellaneous asbestos-related documents. The Microfilm collections (05), (06) also contain documents which were located at World Headquarters. Generally,the same types of documents from the same departments and offices are included. However, at the time of the production in the insurance litigation, these documents were produced on film, usually because the documents were in active files which needed to be maintained for normal operations of the company. Records from the following collections were included in these microfilm collections: patents and licensing department; the Research and Development offices; the Lompoc plant; the Health, Safety, and Environment offices; and the records from the Englewood Cliffs, NJ sales offices; insurance department files; insurance policies; industrial hygiene surveys; administrative bulletins; asbestos medical articles; asbestos health depositions; asbestos health files; Manville Corporation general ledgers from 1919 to 1952; and growth plans from 1971 to 1980. In addition, some document collections produced to insurance companies are also located on film in these collections. The Local Counsel Boxes (07) collection includes documents from Manville's counsel in California, Illinois and New Jersey. The Microfilm collection with the redacted documents (08) contains documents from many locations previously mentioned. However, privileged portions of the documents have been redacted, and the redacted copy was filmed, so that the documents could be produced. The Boxes produced in January, 1989 (09) are documents which had originally been classified as privileged. All privileged documents were reviewed again in 1988 and 1989, and the documents in the 09 collection were determined at that time to be producible. Box Index A Box Index for the repository is provided to reviewers. It took six paralegals three months to index the boxes. The microfilm took an additional three months to index. The finished indices were then spot-checked for accuracy by a supervising paralegal with five years experience in the asbestos litigation. The form used to prepare the index was reviewed in advance by Selected Counsel for the Beneficiaries, a group of three plaintiff's attorneys appointed by the Trust's Board of Trustees to represent the Asbestos Litigation Group. Any changes suggested by these attorneys were incorporated into the form. 14 The index consists of twenty subject categories, twelve document types, and twelve time periods ranging from pre-1930 to post 1985, in five year increments. Each box and microfilm roll is indexed individually. A box may contain more than one type of document, subject area, or time period. The Box Index allows reviewers to: 1) establish priorities for their searches; and 2) eliminate large numbers of boxes with irrelevant documents. For example, many boxes contain nothing but sales invoices or payroll records. A reviewer interested in documents relating to knowledge of asbestos health hazards would be able to eliminate those boxes from his or her search on the basis of the Box Index alone. Reviewers may order a copy of the index so that they can identify the boxes which they wish to review prior to their arrival at the repository. Alternatively, the Fund will provide reviewers with a printout of all the information contained in the index. Finally, the Fund will conduct computer searches of the data base for reviewers who identify the categories in which they are interested. Review Procedures The repository is open to all parties to the asbestos litigation. An informational packet on the repository is provided to all parties who express an interest in the collection. It contains information regarding the hours of operation, rules regarding reviews, and procedures for scheduling visits to the repository. Generally speaking, the Fund has been able to accommodate the schedules of persons wishing to conduct a review, and access is often provided with less than one week's notice. Interrogatory No, 2: If Manville has, at any time, been engaged in the mining, manufacturing, producing, processing, compounding, converting, selling, merchandising, supplying, distributing, and/or otherwise placing in the stream of commerce asbestos, asbestos products and/or material containing asbestos, be specific in your answer and state: (a) The trade name(s) of the product(s); (b) The date you first mined, manufactured, produced, processed, compounded, converted, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce your asbestos, asbestos products and/or products containing asbestos; (c) The date your asbestos, asbestos products and/or materials containing asbestos were first placed upon the market; 15 (d) (e) (f) (g) (h) The inclusive dates of mining, manufacturing, producing, processing, compounding, converting, selling, merchandising, supplying, distributing and/or otherwise placing in the stream of commerce; A complete description of the product or products including the components of the product in percentage terms including specifically the percentage of each type of asbestos fiber (i.e., amosite, chrysotile and/or crocidolite) incorporated into the product; A description of the physical appearance of such product; A description of the intended uses of each such product; The specific nature and date of each alteration or change in the composition of the product since the initial date of mining, manufacturing, supplying, distributing, and/or otherwise placing in the stream of commerce. RESPONSE: See Exhibit A attached hereto for a list of asbestos containing insulation or shipyard products manufactured by Manville Corporation or related entities. This list includes the product name, product type, fiber type, percent of fiber by weight, years of production and the date labeled. Additionally, the Fund has in its possession product directories prepared by the Advertising and Public Relations Department from 1959 through 1986. These directories provide information regarding product lines, construction of the product, popular uses, responsible sales division or department, various operating divisions, the plants at which certain products were manufactured, products with a registered trademark, generic product names and competitive product names. The Fund also has in its possession eighty-three boxes of product literature and brochures. Much of this material came from the Manville Corporate Information Center which contained the corporate library materials for Manville Corporation or related entities. These documents will be produced at the records repository maintained by the Fund in Denver, Colorado at a time agreed upon by the parties. In addition to the documents which will be specifically identified and produced at that time, there may be additional documents responsive to this Interrogatory among the general collection of documents in the repository. This collection of documents will be made available to counsel for review. See Exhibit B attached hereto for descriptions and intended uses of the products listed in Exhibit A. 16 The specific composition of asbestos containing products manufactured by Manville Corporation or related entities was changed frequently over the years in order to meet the needs and demands of customers. In general, these changes would have been made on the recommendation of personnel in the Research & Development Department. In addition, minor changes in product formulations were often accomplished at the plant level, depending on the availability and characteristics of certain raw materials. Many of these changes are reflected by manufacturing documents and product specifications which are located in the records repository maintained by the Fund in Denver, Colorado. Manville also developed asbestos free replacement products for many of the asbestos containing products which were manufactured previously. For the most part, these replacement products differed substantially from the products which they replaced, and were not simply products from which asbestos was removed. No asbestos containing products have been manufactured by Manville since 1985. With respect to asbestos fiber, Manville Corporation or related entities divested their interest in asbestos mining and milling operations in 1983. Substitutes for thermal insulation asbestos containing products manufactured by Manville Corporation or related entities and the dates of substitution are as follows: Asbestos containing products SUPEREX-M SUPEREX-1900 Non-asbestos Products SUPEREX-1600 SUPEREX-2 000 Date Replaced 1971/73 1971/73 301 Cement 375 Cement 1971 450 Cement 460 Cement 1972/77 500 Cement 505 Cement 1972 THERMOBESTOS THERMO-12 1972/74 MARINITE 23, 36, & 65 MARINITE XL 1976 METAL-ON (THERMOBESTOS) METAL-ON (THERMO-12) 1972/74 SUPEREX--2 000 SUPEREX-200OAF 1972 (AF later dropped, making replacement product name SUPEREX- Molded MIN-K (500, 1301, 2000) Molded MIN-K (500, 1301, 2000) 1973/77 Flexible MIN-K Flexible MIN-K 1973/77 17 1 (High Temperature Std.) (High Temperature Std.) SONITE SONITE 1973/74 See also response to Interrogatory No. 1. Interrogatory No. 3: Please identify by location and product produced each plant in which products listed in your answer to Interrogatory No. 2 have been manufactured and/or assembled and the dates said plants have been in operation. RESPONSE; Manville Corporation or related entities manufactured asbestos containing products at the following locations: Johns-Manville High Street Billerica, Massachusetts (1940 to 1985) 01862 Johns-Manville Highway 75 Denison, Texas (1957 to 1982) Johns-Manville 2222 W. 5th Street Fort Worth, Texas (1952 to 1985) Johns-Manville P. O. Box 185 Green Cove Springs, (1965 to 1982) Florida Johns-Manville Laurinburg, North Carolina (1965 to 1980s) Johns-Manville Lawrence, Massachusetts (1964 to 1974) Johns-Manville 2500 Miguelito Road Lompoc, California (1928 to 1980s) 18 Johns-Manville 2420 East 223 Street Long Beach, California (1938 to 1982) 90810 Johns-Manville (Watson) Los Angeles, California (1929 to 1981) Johns-Manville Main Street Manville, New Jersey (1913 to 1985) 08835 Johns-Manville P. 0. Box 128 Marrero, Louisiana (1947 to 1980s) Johns-Manville P.0. Box 428 Marshville, North (1963 to 1969) Carolina Johns-Manville Nashua, New Hampshire (1907 to 1985) Johns-Manville P. O. Box 66 North Brunswick, (1947 to 1975) New Jersey Johns-Manville McLean Boulevard at 9th Avenue Patterson, New Jersey (1970 to 1975) Johns-Manville P. O. Box 591 Pittsburg, California (1926 to 1980s) 94565 Johns-Manville Middlefield Road Redwood City, California (1932 to 1955) Johns-Manville Savannah, Georgia (1956 to 1985) 19 Johns-Manville Sperry Road & Airport Way Stockton, California (1957 to 1982) Johns-Manville Tilton, New Hampshire (1948 to 1976) 03275 Johns-Manville P. O. Box 55 Waukegan, Illinois (1922 to 1985) 60085 Johns-Manville P. O. Box 190 Zelienople, Pennsylvania (1943 to 1973) 16163 To the best of the Fund's knowledge, the following asbestos containing products were among those manufactured at each facility listed below. Billerica Plant products included: Asbestocite Heat Treated Molten Metal Marinite Heat Treated Thermostone Imperial Marinite. Marimet 45 Marinite Marinite 23 Marinite 30 Marinite 36 Marinite 65 Metal Veneered Marinite Molten Metal Marinite Pallite Permatone Corrugated Transite Reeferite Terraceran Thermostone Veneered Marinite Denison Plant products included: Transite Pipe Fort Worth Plant products included: Asbestos Roofing Felts 20 Green Cove Springs Plant products included Transite Pipe Laurinburg Plant products included: Railroad Brake Shoes Rubber Rings Lompoc Plant products included: Diaseal M Fibra-Flo Precoat Celite 564 Precoat Sorbo-Cel Sil-O-Cel Hard Finish Cement Sil-O-Cel Plastic Insulating Cement Long Beach Plant products included: Metal On Thermobestos Block Thermobestos Insulating Cement Thermobestos Pipe Covering Transite Pipe Los Angeles Plant products included: 15A Asbestos Jacket 45A Asbestos Jacket Insulkote ET Manville Plant products included: 0352 Cement 12 lb. Asbestos Tape 15A Asbestos Jacket 45A Asbestos Jacket #50 Weatherproofing Felt 301 Cement 302 Cement 340 Cement 364 Cement 7700 Coated Asbestos Jacket 85% Magnesia Block 85% Magnesia Pipe Covering Aertite Albaseal Anti-Sweat Armaturo Asbestos Paper Asbestobord 21 Asbestocel Asbestos Cloth Asbestos Fire Felt Asbestos Firetard Asbestos Jelly Rolls Asbestos Paper and Rollboard Asbestos Pipe Blanket Asbesto-Sponge (felted, sectional, molded) Asbestos Roll Fire Felt Asbestos Rope Asbestos Sheet Asbestos Tape Asbestos Textiles Asbestos Tubing Asbestos Turbine Blanket Asbestos Welding Paper Automotive Friction Materials Body Sealer Branchtite Ceilinite Colorsil Commercial Grade Asbestos Paper Corrugated Transite Corspan D.C. Flexstone Doublex Asbestos Paper Duplex Asbestos Paper Duxseal Engineers Insulating Tape Facespan Fibrofil Cement Fibroid Asbestos Paper Fil Insul Cement Fine Corrugated Asbestocel Flexboard Flexible Min-K H-Navaseal HF Navaseal High Strength Fibroid Asbestos Paper High Temperature Flexible Min-K Blankets Industrial Vent Caulking Insulkote ET Insulkote SG Insulkote ST Laptite Cement Long Fiber Asbestos Paper Metal On Microbestos Paper Millboard 101 Millboard 102 Millboard 103 Millboard 104 22 Millboard 105 Millboard 106 Millboard 219 Millboard C Millboard XXX Min-K 500 Min-K 1301 Min-K 2000 Min-Klad Molded Packings MX-3803 Asbestos Filler Navy 450 Cement Niagrite Nodrseal Non-Burn Asbestos Paper Pan-O-Cel Plastiseal F Silicated Thermobestos Block Silicated Thermobestos Pipe Covering Sonite Standard Flexible Min-K Blankets Stove Putty Superex M Block Superex 1900 Block Superex Cement Superex Cement for Navy Superex M Pipe Covering Super Fire Felt Thermobestos Block Thermobestos Pipe Covering ThermoFire Felt Thermomat Thermotape Thermowrap Transhield Asbestos Felt Transite Pipe Transite Ridge Roll and Battens Transoseal Type T Nodrseal Uniseal Vitribestos Vitro Fire Felt Wet Strength Fibroid Asbestos Paper White Surface Asbestos Jacket Woven Asbestos Sheet Packing Marrero Plant products included: 15A Asbestos Jacket 7700 Coated Asbestos Insulkote ET Insulkote ST Jacket 23 Laptite Cement Transite Pipe Marshville Plant products included: Asbestos Textiles Nashua Plant products included: Aegean Armor-On Asbestocite Chemstone Colorceran Colorceran Edge Coating Colorchip Colored Marine Veneer Colorlith Colorlith Chalkboard Colorthin Dekeran Duplex Asbestos Paper Ebony Electrobestos Fireglaze Stonehenge Flat Transite Flexboard Flexboard "B" Imperial Walls & Beams Marine Acoustical Unit Marine Veneer Marinite 36 Marinite 65 Molded Ebony Molded Electrobestos Molded Unit Ohmstone Perforated Colored Marine Veneer Perforated Fiberboard "S" Perforated Flexboard Perforated Marine Veneer Quadro Santone Splitwood II Steam Cured Transite Stonehenge Submarine Bulkhead Textured Transite Transite Acoustical Panel Transite Core Plates, Pallets and Transite Core Plate Sheets Venetia Slip Jackets 24 North Brunswick Plant products included: Spirotallic Gaskets Patterson Plant products included: Die-Formed Rings Gaskets Pittsburgh Plant products included: 0352 Cement 6# Asbestos Felt Saturated for Pipe Covering 9# Asbestos Felt for Pipe Line 15A Asbestos Jacket 15# Pipeline Felt 23-1/2# Pipe Line Felt 301 Cement 302 Cement 319 Semi-Refractory Cement 400 Cement 45A Asbestos Jacket 450 Cement 50 Weatherproofing Felt 500 Cement #55 Asbestos Base Felt 678 Semi-Refractory Cement Aertite Coating Anti-Sweat Asbestile Asbestocel Asbestoment Type "S" Asbesto-Sponge Commercial Grade Asbestos Paper Corrugated Transite D.C. Flexstone Fibroid Asbestos Paper Fibrous Adhesive Flexboard Glasal Asbestos Cement Sheet Insulkote ET Insulkote SG Insulkote ST Kearsarge Laptite Cement Millboard Saturated Asbestos Felts for Ply and Pipe Covering Service Sheet No. 60 Transhield Asbestos Felt 25 Redwood City Plant products included: 85% Magnesia Block 85% Magnesia Cement 85% Magnesia Pipe Covering 85% Magnesia Pipe Covering for Copper Tubing Combination Pipe Covering (85% Magnesia and Superex) D.C. Flexstone End Lap Strips for Weatherproof Jackets Flat, Curved and Lagging Blocks (85% Magnesia and Superex) Magnesia Plastic Rough 85% Magnesia Sectional Pipe Covering, Segments and Block Rough Superex Sectional Pipe Covering, Pipe Blocks and Blocks Superex Block Superex Cement Superex Pipe Covering Superex Plastic Savannah Plant products include: Asbestos Roofing Felts Stockton Plant products included: Transite Pipe Tilton Plant products included: Fuel Cell Millboard Fuel Cell Paper Microbestos Millboard, Type 106 Quinorgo Quinorgobord Quinterra Quinterrabord Quintex Telgard Toasterbord TV Bord Waukegan Plant products included: 0352 Cement 12# Asbestos Tape 15A Asbestos Jacket 45A Asbestos Jacket #50 Weatherproofing 300 Cement 300 E Cement 301 Cement Felt 26 302Cement 304 Cement 319 Semi-Refractory Cement 340 Cement 364 Cement 400 Cement 450 Cement 500 Cement 678 Semi-Refractory Cement 7700 Coated Asbestos Jacket 85% Magnesia Block 85% Magnesia Cement 85% Magnesia Pipe Covering Aertite Anti-Sweat Aqua Covering Architectural Panels Asbestile Cement Asbestoboard Asbestocel Asbestoment Asbestos Fire Felt Asbestos Firetard Asbestos Sponge (felted, sectional and molded) Asbestos Textile Adhesive Asbestos Welding Paper Automotive Friction Materials Commercial Grade Asbestos Paper and Rollboard Corrugated Transite D.C. Flexstone Ebony Fibroid Asbestos Paper Fibrofil Fibrous Adhesive Fil Insul Cement Fine Corrugated Asbestocel Fireite Furnace Cement Flat Transite Flexboard Insulkote ET Insulkote SG Insulkote ST Kiefstone Laptite Cement Marine Veneer Millboard 101 Millboard 102 Millboard 103 Millboard 106 Millboard 106B Millboard 106C Millboard 106H 27 Millboard 202 Millboard 219 Millboard 766 Millboard Type A Millboard Type C Millboard XXX MX-3808 Asbestos Filler Navy 450 Cement Non-Burn Asbestos Paper Permatone S Rentone Ridge Roll Santone Sheet Packing Splitwood Super Fire Felt Superex 1600 Block Superex 1900 Block Superex 2000 Block Superex M Block Superex SG Block Superex Cement Superex Cement for Navy Superex M Pipe Covering Superex SG Pipe Covering Thermo Fire Felt Thermobestos Block Thermobestos Cement Thermobestos Pipe Covering Thermocore Transhield Asbestos Felt Transifoam Transite Pipe Transite Ridge Roll and Battens Transitop Vitro Fire Felt Zelienople Plant products included: Fireite Furnace Cement Heat Treating Cement Interrogatory No. 4: Please list the name and address of each business entity from whom you have received raw asbestos and the dates and amounts received. 28 RESPONSE: Manville Corporation or related entities used asbestos fiber obtained from a number of sources. For products which contained chrysotile, much of the fiber used was obtained from the Jeffrey Mine in Asbestos, Quebec, which was owned and operated by a Canadian subsidiary. In addition, Manville Corporation or related entities used fiber from their Coalinga Mine in California, Munro Mine in Ontario, Reeves Mine in Ontario and from their Rhodesian mines in southern Rhodesia. Manville also purchased asbestos from the Advocate Mine in Newfoundland, of which it was part owner. Other sources of chrysotile included: Advocate Mines, Ltd.; Bell Asbestos Mines, Ltd.; Calaveras Asbestos, Ltd.; Cassiar Asbestos Corporation, Ltd.; H.K. Porter Company; Marlime Chrysotile Asbestos Corporation, Ltd.; Metate Asbestos Corporation; Pacific Asbestos Corporation; and Rhodesian Asbestos, Ltd. Crocidolite and amosite fibers were imported into this country, primarily from South Africa. The suppliers included: Antony Gibbs & Company, Ltd.; Asbestos Investment (Pty), Ltd.; John Beith (S.A.) Pty.; Ltd.; British Metal Corporation; Cape Blue Mines (Pty), Ltd.; Central Asbestos Company, Ltd.; C. J. Petro & Company; Colonial Sugar Refining Company, Ltd.; Egnep (Pty), Ltd.; Flintkote Building Products Group; General Mining & Finance Corporation, Ltd. ; General Services Administration; Hooker Chemical Company; John Holt & Company; Norca Corporation; North American Asbestos Corporation; Raw Asbestos Distributors; S.A. Asbestos Trading (Pty), Ltd.; V/0 Soyuspromexport; Special Asbestos Company, Inc.; Turner & Newell, Ltd.; Turners Asbestos Fibres, Ltd.; and Watson, Geach & Company, Inc. All responsive documents in the possession, custody or control of the Fund will be produced at the records repository maintained by the Fund in Denver, Colorado. In addition to the documents which will be specifically identified and produced at that time, there may be additional documents responsive to this request among the general collection of documents in the repository. This collection of documents will be produced at a time agreed upon by the parties. See response to Interrogatory No. 1. Interrogatory No. 5: Does Manville have custody, possession or control of any samples of asbestos-containing products? If so: (a) Identify each such sample; (b) Identify the custodian of each such sample; (c) Identify the date on which each such sample was sold and/or distributed by Manville; (d) State whether or not each such sample was retrieved from the stream of commerce or was retrieved from warehouses or storage facilities of Manville; 29 (e) If it was retrieved from the stream of commerce, identify the person or company from whom it was retrieved; (f) If it was retrieved from in-house sources, i.e., warehouses, storage facilities, or sales representative of Manville, identify where and from whom it was received. RESPONSE: To the extent any such samples exist, they will be produced at the records repository maintained by the Fund in Denver, Colorado. Interrogatory No. 6: Does Manville have custody, possession, or control of any packages that presently or formerly packaged asbestos-containing products. If so: (a) (b) (c) (d) (e) (f) Identify each such package; Identify the custodian of each such package; Identify the date on which each such package was sold and/or distributed by Manville; State whether or not each such package was retrieved from the stream of commerce or was retrieved from warehouses or storage facilities of Manville; If it was retrieved from the stream of commerce, identify the person or company from whom it was retrieved; If it was retrieved from in-house sources, i.e., warehouses, storage facilities, or sales representatives of Manville, identify where and from whom it was received. RESPONSE: Samples of any such packages used by Manville Corporation or related entities and all responsive documents in the possession, custody or control of the Fund will be produced at the records repository maintained by the Fund in Denver, Colorado. In addition to the documents which will be specifically identified and produced at that time, there may be additional documents responsive to this request among the general collection of documents in the repository. This collection of documents will be produced at a time agreed upon by the parties. See response to Interrogatory No. 1. Interrogatory No. 7: Describe in detail the type of packages in which Manville sold, distributed or delivered asbestos, material containing asbestos, asbestos products and compounds in the Commonwealth of Virginia, listing: 30 (a) The date each type of package was used; (b) A physical description thereof, including the size of the package, color, and size of any lettering on the package, including warnings of any kind; and (c) A description of any printed material or trademarks that appeared on or in said package, including a verbatim statement of any warnings or cautions; and (d) The name(s) of the most knowledgeable person(s) concerning the packaging of the asbestos and asbestos products. RESPONSE: PRODUCT PACKAGING Asbestos containing pipe covering and block were placed in Kraft cardboard boxes. Asbestos cements were sold in multi-ply Kraft paper bags or heavy duty, polyethylene bags. Asbestos cloth was rolled, wrapped in laminated kraft paper, tied with tape or twine, and placed in burlap tubing. In later years, reinforced paper was used in place of burlap tubing. Asbestos yarns were wound on paper tubes and shipped in fiberboard cartons or wooden boxes. Depending on the specified size, asbestos tubing was either wound on spools or cut to specified lengths, and placed in fiberboard cartons. Asbestos tape was rolled, bound with twine, and placed in fiberboard cartons. Asbestos sheeting was rolled on tubes then wrapped in laminated kraft paper, tied with tape then placed in fiberboard cartons with paper lining between each roll. Larger sheets, which were individually wrapped in kraft paper, were placed in corrugated fiberboard cartons or placed in wooden crates. Printing on the cartons or bags usually included the J-M logo, the name "Johns-Manville", the product name, the size and the weight. Additional language may have been used from time to time. Some photographs and product literature are located at the document repository maintained by the Fund in Denver, Colorado, and will be produced at a time agreed upon by the parties. In addition, warning labels were placed on packaging of asbestos containing products beginning in 1964 as set forth below. Also, the Fund has in its possession finished product specifications and purchase specifications for various asbestos containing products which describe the packaging of each product in detail, any alterations thereto, and the physical description thereof, including placement of warning labels. These specifications will be produced at the records repository maintained by the Fund in Denver, Colorado, at a time agreed upon by the parties. 31 FIBER PACKAGING Manville Corporation or related entities first began to sell asbestos fiber in 1916. From that time through the early 1920s, fiber was packed by hand in jute bags. From the 1920s to the 1950s, the fiber was fed into spouts which poured fiber into jute bags. Dimensions of some of the jute bags used were as follows: 20" x 36" 23" X 40" 30" x 40" 32" X 40" 25 1/2" X 42" In addition to jute bags, the use of open mouthed, two or three ply kraft paper bags began in 1940. The standard dimensions of the open mouthed bags were 16 1/4" x 7 1/2". Beginning in the late 1940s, Manville Corporation or related entities began to use valve paper bags in addition to the open mouthed bags. This multi-walled bag was constructed of a specified number of plies, then completely sealed except for a sleeved opening on one corner, through which the fiber was injected. Dimensions of the valve bags ranged from 15" x 6 3/4" to 25" x 7 1/4". Manville Corporation or related entities first began to "pressure pack" fiber in the late 1940s. The pressure pack method allowed the fiber to be automatically weighed out, dropped into a chamber, and compressed into a block. By 1954, all fiber was pressure packed. Jute bags were no longer used after this date unless specifically requested by the customer. Two standard bags were used in conjunction with the pressure pack method: 1) the open mouthed multi-walled kraft paper bag, described above; and 2) the woven polyethylene bag. Pressure packed woven polyethylene bags were constructed of woven polyethylene filaments, which gave the bag strength and durability. The bags were coated on the outside with a polyethylene film to make it impervious to dust and moisture. The bag was then passed through a bag sealer, which automatically applied glue to the flaps and creased the bag together. These woven polyethylene bags may have been "palletized" for shipment by stacking and gluing several bags together to form a stable load for mechanical handling. The size of the mold and resulting package dimensions were related to the density of the fiber grade involved. Varied sizes of pressure packers were developed to accommodate ranges of fiber grades and included the following: 32 11" X 16" X 24" 10" X 16" X 24" 8" X 16" X 24" 7" X 16" X 30" In the 1970s, additional equipment was developed which was capable of producing high-density blocks of fiber measuring 9" x 12" x 16." These blocks had a density of 100 pounds per cubic foot, approximately twice the density of a standard pressure packed bag. Additionally, in 1972, Manville Corporation or related entities completed modifications of all pressure packaging equipment to allow production of a standard sized package with dimensions of 9" x 15" x 22 1/2." This new package accommodated fifty kilograms of fiber. Also in the 1970s, Manville Corporation or related entities began to use a newly developed multi-ply unsized kraft paper bag to package fiber which was used in wet papermaking processes. The entire bag could be thrown into the mix, without removing the fiber from the bag. Manville Corporation or related entities developed packing and shipping procedures designed to avoid damage to the bags during shipment. For example, when palletizing bags of fiber, various stacking arrangements were used to create a stable load. Some of the stacking practices implemented by Manville Corporation or related entities included the five bag pattern, three bag pattern, pinwheel pattern, two bag cross pattern and two bag pattern. Additionally, it was necessary to pack the fiber in a fashion which would accommodate the customer's unloading practices. Single decking was used when the customer was capable of handling the full height and weight of units. In this case, a pallet was placed under the bottom layer of the bags so that the mechanical equipment could pick up the entire load. Double decking was used when the customer was incapable of handling a full height and weight unit. In that case, the units which were prepared were approximately one half of the normal height and weight. The types of pallets used included cardboard deck sheets, cardboard deck sheets with stringer, single faced wood, double faced wood and polypropylene sheets. In order to prevent deterioration of the pallet load during transit and subsequent handling by the customer, Manville Corporation or related entities used adhesive to bond the bags together on the pallet. The adhesive was applied to the face of the bag. If the bags were palletized automatically, as were pressure packed bags, the adhesive was automatically applied by a spray gun. If the bags were palletized manually, the adhesive was applied by brush. 33