Document 3J1G00EaR4om2NrQb4Kvnxb06

FILE NAME: General Cable (GC) DATE: 1991 DOC#: GC013 DOCUMENT DESCRIPTION: Legal - Defendant's Response to Plaintiff Interrogatories --V s .. bi*, 'MM RAY L. WONG PAUL J. KILLION MARY ELLEN LEMIEUX HANCOCK, ROTHERT & BUNSHOFT Four Embarcadero Center, lOth San Francisco, CA 94111-4168 Tlphon: (415) 981-5550 Floor Attorneys for Defendant GENERAL CABLE CORPORATION 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SOLANO 10 11 IN RE: SOLANO COMPLEX ASBESTOS ) 12 LITIGATION ) ) 13 _______________________________ ) 14 No. 2830 GENERAL CABLE'S RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES 15 16 17 18 if 19 20 21 22 23 24 25 26 27 28 HANC*OCKU.N3RNOOTFHTCT FOWK CMMACAOCHO CCHTCA sim? m * 9 A N FRANCISCO. CA (41ft)M1*SSM General Cable Corporation responds to plaintiffs' standard interrogatories in conjunction with Fontella Thomas, et al. v. Abex Coro., et al.. Solano County Superior Court Case No. 22089. I. PRELIMINARY STATEMENT General Cable Corporation ("General Cable") was incorporated in New Jersey in 1902 for the purpose of manufacturing wire and cable products. What later came to be known as its Power and Control Operation manufactured substantially all of its products containing asbestos. The Power and Control Operation, including its plants, employees, and research facilities, was sold to Pirelli Cable Corporation on March 31, 1978. Documents relating to the Power and Control Operation were also sold to the buyer. O O 1 Following a series of acquisitions and divestitures, 2 General Cable Corporation changed its name to GK Technologies on 3 April 25, 1979. Thereafter, GK Technologies was merged into a 4 1981 New Jersey corporation as part of a tax reorganization. 5 Immediately following the merger, the surviving corporation 6 changed its name to GK Technologies, Incorporated. 7 At the time of the name change in 1979, a Delaware 8 Corporation named General Cable Corporation was created to 9 protect the General Cable name. The Defendant named in this 10 action, the Delaware General Cable Corporation, has never 11 manufactured products containing asbestos. 12 without waiving any right or objection, these answers 13 are made upon information and belief with respect to the products 14 manufactured by the former Power and Control Operation of General 15 Cable Corporation, now named GK Technologies, Incorporated. For 16 purposes of these interrogatories the name General Cable is 17 intended to refer to the original 1902 New Jersey corporation 18 prior to its name change. 19 20 II- GENERAL OBJECTIONS 21 Defendant General Cable objects to plaintiffs' entire 22 set of interrogatories on the basis that the interrogatories 23 conflict with the provisions of the Code of Civil Procedure and 24 therefore are unenforceable as beyond the court's jurisdiction. 25 Code of Civil Procedure section 2030 sets forth the legislature's 26 governing provisions pertaining to interrogatories, and absent a 27 subsequent legislative enactment, cannot be overruled by a local 28 court rule. See Shadle v. City of Corona. 96 Cal.App.3d 173, 177 GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 2. O O 1 (1979)(where local rule conflicts with the Code of Civil 2 Procedure, then legislative enactment prevails as higher form of 3 law); Government Code section 68070. 4 Defendant General Cable further objects to plaintiffs' 5 entire set of interrogatories on the basis that General Cable 6 never received notice of an application for consolidated 7 discovery, was never provided an opportunity to appear at any 8 hearing on the motion for an order consolidating discovery and 9 has had no opportunity to be heard whatsoever with regard to that 10 order or to the form of discovery propounded under it. In 11 addition, General Cable has never stipulated to adoption of these 12 interrogatories by the Solano Superior Court. As such, General 13 Cable asserts that any obligation to respond to plaintiffs' 14 standard interrogatories is unenforceable under the Code of Civil 15 Procedure and is a denial of due process of law. 16 General Cable further objects to plaintiffs' entire set 17 of interrogatories on the basis that it exceeds the scope of 18 permissive discovery set forth in Code of Civil Procedure 19 section 2030 and is not accompanied by a declaration for 20 additional discovery. In addition, General Cable objects to 21 these interrogatories as not in compliance with Code of Civil 22 Procedure section 2030 because they are compound, disjunctive and 23 contain impermissive subparts. In addition, General Cable 24 objects to these interrogatories as overly broad and therefore 25 burdensome and oppressive. These interrogatories request 26 detailed information not reasonably calculated to lead to 27 admissible evidence, and which falls outside the scope of 28 GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 3. o o 1 Fontella Thomas, et al. v. Abex Coro., et al.. Solano County 2 Superior Court Case No. V22089. 3 4 III. SPECIFIC RESPONSES AND OBJECTIONS 5 Without waiving the foregoing objections, General Cable 6 responds as follows: 7 8 INTERfiOGATORy NO,a. 1 1 9 With respect to the individual verifying these answers on 10 your behalf, state the following: 11 a. their name; 12 b. their present business address; 13 c. their present job title; 14 d. their date of first employment with you, and the dates 15 and titles of each job position they have held while they were 16 employed by you. 17 ANSWER: 18 General Cable objects to this interrogatory on the 19 grounds that it is compound, disjunctive, contains impermissive 20 subparts and contains terms not defined in the question. Without 21 waiving the foregoing objections, General Cable responds as 22 follows: 23 a . Gerald Magarik 24 b. One Cragwood Road, S. Plainfield, NJ 07080 25 c. Director of Environmental Affairs 26 d. 7/2/79 - GK Technologies - Manager, Safety Program 27 1/28/80 - General Cable Company - Manager, Safety 28 & Health GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 4. O o 1 12/12/83 - General Cable Company - Manager, 2 Safety/Health & Environmental Affairs 3 12/8/86 - Penn Central Telecommunications - Risk 4 Manager 5 7/3/89 - Penn Central Telecommunications - 6 Director of Risk Management and Environmental 7 Affairs 8 1/1/90 - Penn Central Corporation - Director of 9 Environmental Affairs 10 INTERROGATORY NO. 2: 11 State whether YOU are a corporation. If so, state: 12 a. YOUR full corporate name; 13 b. the state of incorporation; 14 c. the date of incorporation; 15 d. the address of YOUR principal place of business; 16 e. if YOU are wholly-owned or if more than five (5) 17 percent of the ownership interest of YOUR COMPANY is owned by 18 another business entity, state that entity's name and principal 19 place of business. 20 ANSWER: 21 General Cable objects to this interrogatory on the 22 grounds that it is compound, disjunctive, contains impermissive 23 subparts and contains terms not defined in the question. Without 24 waiving the foregoing objections, General Cable responds as 25 follows: 26 a.-d. Please see the preliminary statement, 27 e. The G.K. Technologies, Incorporated {New Jersey) 28 / / / GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 5. O O 1 INTERROGATORY WO. 3: 2 Has THIS DEFENDANT ever been identified, know, or done 3 business under any other name? If so, please state such name or 4 names and the time period during which THIS DEFENDANT was so 5 known or identified. 6 answerl 7 General Cable objects to this interrogatory on the 8 grounds that it is compound, disjunctive, contains impermissive 9 subparts and contains terms not defined in the question. Without 10 waiving the foregoing objections, General Cable responds as 11 follows: 12 Please see the preliminary statement. 13 INTERROGATORY NO. 4 14 State whether YOU have ever been registered or qualified to 15 do business in the State of California. If so, state the date 16 YOU became qualified to conduct business in the State of 17 California. 18 ANSWER: 19 General Cable objects to this interrogatory on the 20 grounds that it is compound, disjunctive, contains impermissive 21 subparts and contains terms not defined in the question. Without 22 waiving the foregoing objections, General Cable responds as 23 follows: 24 This information is equally available to plaintiffs by 25 inquiry to the California Secretary of State. 26 INTERROGATORY NO. 5 27 Does THIS DEFENDANT currently have, or has THIS DEFENDANT 28 had a department, division, subdivision, branch or group GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 6. O O 1 responsible for the design, development, manufacture, testing and 2 use Of ASBESTOS-CONTAINING PRODUCT(S)? If so, state: 3 a. the name of each present or former corporate 4 department, division, subdivision, branch or group; 5 b. the IDENTITY of the person most knowledgeable about 6 such department, division, subdivision, branch or group. 7 M S W 5 R: 8 General Cable objects to this interrogatory on the 9 grounds that it is compound, disjunctive, contains impermissive 10 subparts and contains terms not defined in the question. General 11 Cable further objects to this interrogatory as overly broad and 12 therefore burdensome and oppressive. Without waiving the 13 foregoing objections, General Cable responds that it never had a 14 department specifically for the "design, development, 15 manufacture, testing and use of asbestos-containing products." 15 INTERROGATORY NO. 6: 17 Has THIS DEFENDANT engaged in the MARKETing of ASBESTOS- 18 CONTAINING PRODUCT(S) comprised in whole or in part of amosite 19 asbestos fibers? If so, please state: 20 a. the trade, brand name and/or generic name of each type 21 of product; 22 b. the date(s) THIS DEFENDANT first MARKETed each type of 23 product; 24 c. the date(s) THIS DEFENDANT ceased MARKETing each type 25 of product; 26 d. a general description of the chemical composition of 27 each type of product, including: 28 GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 7. O O 1 (i) the type(s) and/or grade{s) of RAW ASBESTOS FIBER 2 contained in each type of product; 3 (ii) the quantitative percentage of the type(s) of RAW 4 ASBESTOS FIBER in each type of product; 5 (iii) any change(s) in the quantitative percentages of 6 the type(s) of RAW ASBESTOS FIBER in each type of product; 7 e. the NATURE of each type of product; 8 f. a description of any wording, markings and/or logo on 9 each type of product; 10 g. the recommended use(s) of each type of product, 11 including temperature limits; 12 h. the name(s) of the manufacturer(s) of each type of 13 product; 14 i. the name{s) and address(es) of the supplier(s) of the 15 amosite asbestos fiber used in each type of product; 16 j. the IDENTITY of the person(s) most knowledgeable 17 concerning the purchase of amosite asbestos fiber by THIS 18 DEFENDANT. 19 ANSWER; 20 General Cable objects to this interrogatory on the 21 grounds that it is compound, disjunctive, contains impermissive 22 subparts and contains terms not defined in the question. General 23 Cable further objects to this interrogatory as overly broad and 24 therefore burdensome and oppressive. These interrogatories 25 request detailed information not reasonably calculated to lead to 26 the discovery of admissible evidence and which falls outside the 27 scope of this litigation. Without waiving the foregoing 28 objections, General Cable responds as follows: No. GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 8. O O 1 INTERROGATORY NO. 7 2 Has THIS DEFENDANT engaged in the MARKETing of amosite 3 asbestos fiber? If so, please state: 4 a. the name and location of each amosite asbestos mine 5 which THIS DEFENDANT presently operates, has operated, or in 6 which THIS DEFENDANT has or had an ownership interest, including 7 the dates of such ownership, and the grade of amosite asbestos 8 fiber mined; 9 b. the date(s) THIS DEFENDANT first MARKETed amosite 10 asbestos fiber; 11 c. the date(s) THIS DEFENDANT ceased MARKETing amosite 12 asbestos fiber; 13 d. the grade(s) of such amosite asbestos fiber MARKETed by 14 THIS DEFENDANT. 15 ANSWER: 16 General Cable objects to this interrogatory on the 17 grounds that it is compound, disjunctive, contains impermissive 18 subparts and contains terms not defined in the question. General 19 Cable further objects to this interrogatory as overly broad and 2 0 therefore burdensome and oppressive. These interrogatories 21 request detailed information not reasonably calculated to lead to 22 the discovery of admissible evidence and which falls outside the 23 scope of this litigation. Without waiving the foregoing 24 objections, General Cable responds as follows: No. 25 INTERROGATORY NO. 8 26 Has THIS DEFENDANT engaged in the MARKETing of ASBESTOS- 27 CONTAINING PRODUCTS comprised in whole or in part of chrysotile 28 asbestos fiber? If so, please state: GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 9. O O 1 a. the trade, brand name and/or generic name of each type 2 of product; 3 b. the date(s) THIS DEFENDANT ceased MARKETed each type of 4 product; 5 c. the date(s) THIS DEFENDANT ceased MARKETing each type 6 of product; 7 d. a general description of the chemical composition of 3 each type of product, including: 9 (i) the type(s) and grade(s) of asbestos fiber 10 contained in each type of product; 11 (ii) the quantitative percentage of the types of 12 asbestos fiber in each type of product; 13 (iii) any change(s) in the quantitative percentages of 14 the type(s) of asbestos fiber in each type of product; 15 e. the NATURE of each type of product; 16 f. a description of any wording, marketing, and/or logo on 17 each type of product; 18 g. the recommended use(s) of each type of product, 19 including temperature limits; 20 h. the name of the manufacturer of each type of product; 21 i. the name(s) and address(es) of the supplier(s) of the 22 chrysotile asbestos fiber used in each type of product; 23 j. the IDENTITY of the person(s) most knowledgeable 24 concerning the purchase of chrysotile asbestos fiber by THIS 25 DEFENDANT. 26 M SHEB: 27 General Cable objects to this interrogatory on the 28 grounds that it is compound, disjunctive, contains impermissive GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 10. o o 1 subparts and contains terms not defined in the question. General 2 Cable further objects to this interrogatory as overly broad and i 3 therefore burdensome and oppressive. These interrogatories 4 request detailed information not reasonably calculated to lead to 5 the discovery of admissible evidence and which falls outside the 6 scope of this litigation. Without waiving the foregoing 7 objections, General Cable responds as follows: Yes. 8 a. Electrical wire and cable; 9 b. Unknown; 10 c. Unknown. 11 d. To the best of its knowledge, the only type of 12 asbestos utilized in General Cable wire and cable 13 that contained asbestos was chrysotile asbestos 14 fibers. 15 e. Electrical wire and cable. 16 f. No markings appeared on the wire and cable. 17 g. The conducting of electrical current. 18 h. General Cable Corporation. 19 i. Harco, Raybestos-Manhattan and possibly Johns- 20 Manville. 21 j. Currently unknown but discovery is continuing. 22 INTERROGATORY NO. 9: 23 Has THIS DEFENDANT engaged in the MARKETing of chrysotile 24 asbestos fiber? If so, please state: 25 a. the name of location of each chrysotile asbestos mine 26 which THIS DEFENDANT presently operates, has operated, or in 27 which THIS DEFENDANT has or had an ownership interest, including 28 GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 11. O O 1 dates of such ownership, and the grade of chrysotile asbestos 2 fiber mined; 3 b. the date(s) THIS DEFENDANT first MARKETed chrysotile 4 asbestos fiber; 5 c. the date(s) THIS DEFENDANT ceased MARKETing chrysotile 6 asbestos fiber; 7 d. the grade(s) of such chrysotile asbestos fiber MARKETed 8 by THIS DEFENDANT; 9 e. the recommended use(s) of each grade of such chrysotile 10 asbestos fiber, including temperature limits; 11 f. the name(s) and address(es) of the suppliers(s) of 12 chrysotile asbestos fiber to THIS DEFENDANT. 13 ANSWER: 14 General Cable objects to this interrogatory on the 15 grounds that it is compound, disjunctive, contains impermissive 16 subparts and contains terms not defined in the question. General 17 Cable further objects to this interrogatory as overly broad and 18 therefore burdensome and oppressive. These interrogatories 19 request detailed information not reasonably calculated to lead to 20 the discovery of admissible evidence and which falls outside the 21 scope of this litigation. Without waiving the foregoing 22 objections, General Cable responds as follows: No. 23 INTERROGATORY NO. 10: 24 Has this defendant engaged in the MARKETing of ASBESTOS- 25 CONTAINING PRODUCTS comprised in whole or in part of crocidolite 26 asbestos fiber? If so, please state: 27 a. the trade, brand name and/or generic name of each type 28 of product; GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 12. 1 b. the date(s) THIS DEFENDANT first MARKETed each type of 2 product; 3 c. the date(s) THIS DEFENDANT ceased MARKETing each type 4 of product; 5 d. a general description of the chemical composition of 6 each type of product, including: 7 (i) the type(s) and grade(s) of asbestos fiber 8 contained in each type of product; 9 (ii) the quantitative percentage of the type(s) of 10 fiber in each type of product; 11 (iii) any change(s) in the quantitative percentages of 12 the type(s) of asbestos fiber in each type of product; 13 e. the NATURE of each type of product; 14 f. a description of any wording, markings and/or logo on 15 each type of product; 16 g. the recommended use(s) of each type of product, 17 including temperature limits; 18 h. the name of the manufacturer of each type of product; 19 i. the name(s) and address(es) of the supplier(s) of the 20 crocidolite asbestos fiber used in each type of product; 21 j. the IDENTITY of the person(s) most knowledgeable 22 concerning the purchase of crocidolite asbestos fiber by THIS 23 DEFENDANT. 24 ANSWER: 25 General Cable objects to this interrogatory on the 26 grounds that it is compound, disjunctive, contains impermissive 27 subparts and contains terms not defined in the question. General 28 Cable further objects to this interrogatory as overly broad and GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 13. o o 1 therefore burdensome and oppressive. These interrogatories 2 request detailed information not reasonably calculated to lead to 3 the discovery of admissible evidence and which falls outside the 4 scope of this litigation. Without waiving the foregoing 5 objections, General Cable responds as follows: No. 6 INTERROGATORY NO. H i 7 Has THIS DEFENDANT engaged in the MARKETing of crocidolite 8 asbestos fiber? If so, please state: 9 a. the name of location of each crocidolite asbestos mine 10 which THIS DEFENDANT presently operates, has operated, and/or in 11 which THIS DEFENDANT presently operates, has or had an ownership 12 interest, including the dates of such ownership, and the grade of 13 asbestos fiber mined; 14 b. the date(s) THIS DEFENDANT first MARKETed crocidolite 15 asbestos fiber; 16 c. the date(s) THIS DEFENDANT ceased MARKETing crocidolite 17 asbestos fiber; 18 d. the grade(s) of such crocidolite asbestos fiber 19 MARKETed by THIS DEFENDANT; 20 e. the recommended use(s) of each grade of such 21 crocidolite asbestos fiber, including temperature limits; 22 f. the name(s) and address(es) of the supplier(s) of 23 crocidolite asbestos fiber to THIS DEFENDANT. 24 ANSWER: 25 General Cable objects to this interrogatory on the 26 grounds that it is compound, disjunctive, contains impermissive 27 subparts and contains terms not defined in the question. General 28 Cable further objects to this interrogatory as overly broad and GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 14. O o 1 therefore burdensome and oppressive. These interrogatories 2 request detailed information not reasonably calculated to lead to 3 the discovery of admissible evidence and which falls outside the 4 scope of this litigation. without waiving the foregoing 5 objections, General Cable responds as follows: No. 6 INTERROGATORY NO. 12: 7 Does or did THIS DEFENDANT have a controlling ownership 8 interest in any COMPANY which MARKETed ASBESTOS-CONTAINING 9 PRODUCT(S)? If so, please state: 10 a. the name of such COMPANY; 11 b. the date of incorporation of such COMPANY; 12 c. the state of incorporation of such COMPANY 13 d. the date such interest was acquired; 14 e. the date such interest was changed or terminated, if 15 applicable; 16 f. the name and location of each facility of such COMPANY; 17 g. the name of each type of ASBESTOS-CONTAINING PRODUCT(S) 18 manufactured, processed, and/or assembled by such COMPANY. 19 ANSWER: 20 General Cable objects to this interrogatory on the 21 grounds that it is compound, disjunctive, contains impermissive 22 subparts and contains terms not defined in the question. General 23 Cable further objects to this interrogatory as overly broad and 24 therefore burdensome and oppressive. These interrogatories 25 request detailed information not reasonably calculated to lead to 26 the discovery of admissible evidence and which falls outside the 27 scope of this litigation. Without waiving the foregoing 28 objections, General Cable responds as follows: No. GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 15. 1 INTERROGATORY NO. 13: 2 Does or did THIS DEFENDANT have a controlling ownership 3 interest in any COMPANY that MARKETed RAW ASBESTOS FIBER? If so, 4 please state: 5 a. the name of such COMPANY; 6 b. the date of incorporation or character of such COMPANY; 7 c. the state or country of incorporation of such COMPANY; 8 d. the date such interest was acquired; 9 e. the dates such interest changed or terminated, if 10 applicable; 11 f. the name and location of each asbestos mine owned by 12 such COMPANY; 13 g. the grade and type of RAW ASBESTOS FIBER mined at each 14 mine. 15 ANSWER: 16 General Cable objects to this interrogatory on the 17 grounds that it is compound, disjunctive, contains impermissive 18 subparts and contains terms not defined in the question. General 19 Cable further objects to this interrogatory as overly broad and 20 therefore burdensome and oppressive. These interrogatories 21 request detailed information not reasonably calculated to lead to 22 the discovery of admissible evidence and which falls outside the 23 scope of this litigation. Without waiving the foregoing 24 objections, General Cable responds as follows: No. 25 INTERROGATORY NO. 14: 26 Has THIS DEFENDANT warehoused any RAW ASBESTOS FIBER or 27 ASBESTOS-CONTAINING PRODUCT(S) in the State of California? If 28 so, please state: ;h t ENTI* CA GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 16. o O 1 a. the address of warehouse facility; 2 b. the year(s) THIS DEFENDANT utilized each facility; 3 c. the IDENTITY of the custodian of warehousing records. 4 5 ANSWER: 6 General Cable objects to this interrogatory on the 7 grounds that it is compound, disjunctive, contains impermissive 8 subparts and contains terms not defined in the question. General 9 Cable further objects to this interrogatory as overly broad and 10 therefore burdensome and oppressive. These interrogatories 11 request detailed information not reasonably calculated to lead to 12 the discovery of admissible evidence and which falls outside the 13 scope of this litigation. Without waiving the foregoing 14 objections, General Cable responds that General Cable never 15 warehoused raw asbestos fiber in California or in any state. As 16 of May 5, 1970, General Cable maintained California distribution 17 centers in Colusa, Los Angeles, Pomona, San Francisco and Sanger 18 and one or more of these centers may have warehoused asbestos- 19 containing wire and cable although the whereabouts of records to 20 confirm or refute this are unknown. 21 INTERROGATORY NO. 15i 22 Has THIS DEFENDANT owned or operated facilities anywhere in 23 the United States in which ASBESTOS-CONTAINING PRODUCT(S) have 24 been manufactured, processed and/or assembled? If so, pleased 25 state: 26 a. the address of each such facility including city and 27 state. 28 ANSWER,; GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 17. o o 1 General Cable objects to this interrogatory on the 2 grounds that it is compound, disjunctive, contains impermissive 3 subparts and contains terms not defined in the question. General 4 Cable further objects to this interrogatory as overly broad and 5 therefore burdensome and oppressive. These interrogatories 6 request detailed information not reasonably calculated to lead to 7 the discovery of admissible evidence and which falls outside the 8 scope of this litigation. Without waiving the foregoing 9 objections, General Cable responds as follows: 10 a. As of May 5, 1970, General Cable maintained the 11 following manufacturing facilities in the United 12 States: Kingman, AZ; Hot Springs, AK; Colusa, 13 Goleta, Lindsay, San Carlos and Sanger, CA; 14 Denver, CO; St. Petersburg, Tampa, FL; Dixon, 15 Montecello, IL; Muncie, IN; Baltimore, Elkton, 16 Frederick, MD; Williamstown, MA; Cass City, 17 Corunna, Niles, Quincy, MI; Brandon, MS; St. 18 Louis, MO; Bayonne, Garwood, Hackensack, New 19 Brunswick, Perth Amboy, NJ; Coplague, Rome, NY; 20 Abbeville, SC; Memphis, TN, Bonham, TX; Pownae, 21 VT; Buena Vista, VA. 22 Whether or not any or all of these facilities involved 23 the manufacture of asbestos-containing products" is currently 24 unknown. 25 INTERROGATORY NO. 16: 26 If THIS DEFENDANT owned or operated facilities in which 27 ASBESTOS-CONTAINING PRODUCT(S) have been manufactured, processed 28 and/or assembled, please state: GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 18. O O 1 a. the date said facilities began operation; 2 b. the date said facility ceased operation; and 3 c. the name of each type of ASBESTOS-CONTAINING PRODUCT(S) 4 manufactured, processed or assembled at each such facility. 5 ANSWER: 6 General Cable objects to this interrogatory on the 7 grounds that it is compound, disjunctive, contains impermissive 8 subparts and contains terms not defined in the question. General 9 Cable further objects to this interrogatory as overly broad and 10 therefore burdensome and oppressive. These interrogatories 11 request detailed information not reasonably calculated to lead to 12 the discovery of admissible evidence and which falls outside the 13 scope of this litigation. Without waiving the foregoing 14 objections, General Cable responds as follows: Please see the 15 response to Interrogatory No. 15, incorporated herein by 16 reference. 17 INTERROGATORY NO. 17: 18 Has THIS DEFENDANT purchased or otherwise acquired any 19 rights to the manufacture of ASBESTOS-CONTAINING PRODUCT(S) from 20 another COMPANY? If so, please state: 21 a. the date of purchase or acquisition of such rights; 22 b. the trade, brand, and/or generic name of such ASBESTOS- 23 CONTAINING PRODUCT(S); 24 c. the name and location of any COMPANY from which such 25 rights were purchased or acquired; 26 d. the IDENTITY of the custodian of records of such 27 purchase(s) or acquisition{s). 28 / / / GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 19. 1 ANSWER: 2 o o General Cable objects to this interrogatory on the 3 grounds that it is compound, disjunctive, contains impermissive 4 subparts and contains terms not defined in the question. General 5 Cable further objects to this interrogatory as overly broad and 6 therefore burdensome and oppressive. These interrogatories 7 request detailed information not reasonably calculated to lead to 8 the discovery of admissible evidence and which falls outside the 9 scope of this litigation. Without waiving the foregoing 10 objections, General Cable responds as follows: Unknown but 11 discovery is continuing. 12 INTERROGATORY NO. 18: 13 Has THIS DEFENDANT applied for and/or received any patent(s) 14 for any patent(s) for any ASBESTOS-CONTAINING PRODUCT(S)? If so, 15 state for each such ASBESTOS-CONTAINING PRODUCT(S): 16 a. the product for which each patent was applied and/or 17 issued; 18 b. the date(s) of application; 19 c. the date{s) of issuance of the patent(s), if granted; 20 d. the date(s) of renewal, if any; 21 e. the patent number(s); 22 f. the name of the individual or COMPANY to whom each 23 patent was issued; 24 g. the IDENTITY of the custodian of patent records of THIS 25 DEFENDANT. 26 ANSWER: 27 General Cable objects to this interrogatory on the 28 grounds that it is compound, disjunctive, contains impermissive GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 20. I 1 subparts and contains terms not defined in the question. General 2 Cable further objects to this interrogatory as overly broad and 3 therefore burdensome and oppressive. These interrogatories 4 request detailed information not reasonably calculated to lead to 5 the discovery of admissible evidence and which falls outside the 6 scope of this litigation. Without waiving the foregoing 7 objections, General Cable responds as follows: This information 8 is equally available to plaintiffs by inquiry to the United 9 States Patent and Trademark Office in Washington D.C.. 10 INTERROGATORY NO. 19: 11 Has THIS DEFENDANT registered any trademark(s) for any 12 ASBESTOS-CONTAINING PRODUCT(S)? If so, state for each such 13 ASBESTOS-CONTAINING PRODUCT(S): 14 a. the product for which trademark was registered; 15 b. whether the registration was State or Federal; 16 (i) if State, name the State; 17 c. the date(s) of registration; 18 d. the term(s) thereof; 19 e. the date(s) of renewal; 20 f. the name of the individual or COMPANY to whom each 21 trademark was registered; 22 g. the IDENTITY of the custodian of such trademark records 23 Of THIS DEFENDANT . 24 ANSWER: 25 General Cable objects to this interrogatory on the 26 grounds that it is compound, disjunctive, contains unpermissive 27 subparts and contains terms not defined in the question. General 28 Cable further objects to this interrogatory as overly broad and :*t ENTEN A GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 21. 1 therefore burdensome and oppressive. These interrogatories 2 request detailed information not reasonably calculated to lead to 3 the discovery of admissible evidence and which falls outside the 4 scope of this litigation. Without waiving the foregoing 5 objections, General Cable responds as follows: This information 6 is equally available to plaintiffs by inquiry to the United 7 States Patent and Trademark Office in Washington D.C.. 8 INTERROGATORY NO. 20: 9 Did THIS DEFENDANT contract with the General Services 10 Administration and/or other federal government agency for the 11 sale, anywhere in the United States, of RAW ASBESTOS FIBER 12 between 1930 and 1980? If so, state for each such sale: 13 a. the grade(s) and type(s) of RAW ASBESTOS FIBER; 14 b. the quantity; 15 c. the date(s) of delivery; 16 d. the location(s), including the address(es) of delivery; 17 e. the name(s) of the agency with which THIS DEFENDANT 18 contracted; 19 f. the date(s) of execution of such contract(s); 20 g. the IDENTITY of the custodian of such contract records 21 of THIS DEFENDANT . 22 ANSWER: 23 General Cable objects to this interrogatory on the 24 grounds that it is compound, disjunctive, contains impermissive 25 subparts and contains terms not defined in the question. General 26 Cable further objects to this interrogatory as overly broad and 27 therefore burdensome and oppressive. These interrogatories 28 request detailed information not reasonably calculated to lead to GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 22. O O 1 the discovery of admissible evidence and which falls outside the 2 scope of this litigation. Without waiving the foregoing 3 objections, General Cable responds as follows: No. 4 INTERROGATORY NO. 21: 5 Did THIS DEFENDANT contract with the General Services 6 Administration and/or other federal government agency for the 7 sale, anywhere in the United States, of ASBESTOS-CONTAINING 8 PRODUCT(S) between 1930 and 1980? If so,please state for each 9 such sale: 10 a. the type of product; 11 b. the quantity; 12 c. the date(s) of delivery; 13 d. the location(s), including the address(es) of delivery; 14 e. the name(s) of the agency with which THIS DEFENDANT 15 contracted; 16 f. the date(s) of execution of such contract(s); 17 g. the IDENTITY of the custodian of such contract records 18 Of THIS DEFENDANT. 19 ANSWER: 20 General Cable objects to this interrogatory on the 21 grounds that it is compound, disjunctive, contains impermissive 22 subparts and contains terms not defined in the question. General 23 Cable further objects to this interrogatory as overly broad and 24 therefore burdensome and oppressive. These interrogatories 25 request detailed information not reasonably calculated to lead to 26 the discovery of admissible evidence and which falls outside the 27 scope of this litigation. Without waiving the foregoing 28 objections, General Cable responds as follows: Yes. GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 23. O O 1 a. Electrical wire and cable. 2 b . -d. Unknown. 3 e. U.S. Navy 4 f.-g. Unknown. 5 INTERROGATORY NO. 22: 6 Does THIS DEFENDANT have any records of the MARKETing, 7 advertisement, or delivery of its RAW ASBESTOS FIBER and/or 8 ASBESTOS-CONTAINING PRODUCT(S) in or to NORTHERN CALIFORNIA? If 9 so, state: 10 a. the manner in which the records are kept (e.g., in 11 boxes, files, or microfilm, microfiche or computer tape or disk); 12 b. the location(s) and address(es) where such records are 13 maintained; 14 c. the IDENTITY of the custodian of such records. 15 ANSWER: 16 General Cable objects to this interrogatory on the 17 grounds that it is compound, disjunctive, contains impermissive 18 subparts and contains terms not defined in the question. General 19 Cable further objects to this interrogatory as overly broad and 20 therefore burdensome and oppressive, and vague as to the use of 21 "records". These interrogatories request detailed information 22 not reasonably calculated to lead to the discovery of admissible 23 evidence and which falls outside the scope of this litigation. 24 Without waiving the foregoing objections, General Cable responds 25 as follows: No. 26 INTERROGATORY NO. 23: 27 If THIS DEFENDANT has in its possession any records of the 28 MARKETing, advertisement, or delivery of its RAW ASBESTOS FIBER GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 24. 1 and/or ASBESTOS-CONTAINING PRODUCT(S) (including microfilm, 2 microfiche, computer tape or disk, or any other system in which 3 data is taken from other records), state whether THIS DEFENDANT 4 has retained the original DOCUMENTS from which the data entered 5 into these modes of storage was obtained. If THIS DEFENDANT has 6 not retained such original DOCUMENT, state: 7 a. the date(s) when and location(s) where the original 8 DOCUMENTS were disposed of; 9 b. the IDENTITY of the custodian of the original DOCUMENTS 10 at the time of their disposal. 11 ANSWER: 12 General Cable objects to this interrogatory on the 13 grounds that it is compound, disjunctive, contains impermissive 14 subparts and contains terms not defined in the question. General 15 Cable further objects to this interrogatory as overly broad and 16 therefore burdensome and oppressive. These interrogatories 17 request detailed information not reasonably calculated to lead to 18 the discovery of admissible evidence and which falls outside the 19 scope of this litigation. 20 INTERROGATORY NO. 24: 21 Does THIS DEFENDANT have in its possession any exemplar(s) 22 of advertisements or brochures describing its RAW ASBESTOS FIBER 23 and/or ASBESTOS-CONTAINING PRODUCT(S)? If so, please state: 24 a. the location of each exemplar; 25 b. the year(s) in which said exemplar(s) was utilized; 26 c. 27 / / / 28 / / / the IDENTITY of the custodian of such exemplar(s). GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 25. 1 ANSWER: 2 O O General Cable objects to this interrogatory on the 3 grounds that it is compound, disjunctive, contains impermissive 4 subparts and contains terms not defined in the question. General 5 Cable further objects to this interrogatory as overly broad and 6 therefore burdensome and oppressive. These interrogatories 7 request detailed information not reasonably calculated to lead to 8 the discovery of admissible evidence and which falls outside the 9 scope of this litigation. Without waiving the foregoing 10 objections, General Cable responds as follows: General Cable 11 does not have any exemplars of advertisements or brochures 12 describing raw asbestos fiber. 13 INTERROGATORY NO. 25: 14 State the following: 15 a. the address(es) where the corporate records of THIS 16 DEFENDANT (including minutes from the Board of Directors meetings 17 and corporation annual reports), are currently located; 18 b. the IDENTITY of the custodian of such records. 19 ANSWER: 20 General Cable objects to this interrogatory on the 21 grounds that it is compound, disjunctive, contains impermissive 22 subparts and contains terms not defined in the question. In 23 addition, the interrogatories are not reasonably designed to lead 24 to the discovery of relevant evidence. Without waiving the 25 foregoing objections, General Cable responds as follows: Please 26 see preliminary statement. 27 / / / / / / GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 26. O 1 INTERROGATORY NO. 26;_ 2 Describe the packaging or containers in which THIS DEFENDANT 3 sold and/or distributed RAW ASBESTOS FIBER, including 4 composition, dimension, shape and color. 5 ANSWER: 6 General Cable objects to this interrogatory on the 7 grounds that it is compound, disjunctive, contains unpermissive 8 subparts and contains terms not defined in the question. General 9 Cable further objects to this interrogatory as overly broad and 10 therefore burdensome and oppressive. These interrogatories 11 request detailed information not reasonably calculated to lead to 12 the discovery of admissible evidence and which falls outside the 13 scope of this litigation. Without waiving the foregoing 14 objections, General Cable responds as follows: Not applicable. 15 INTERROGATORY NO. 27: 16 Describe any logo, design, marking or printing, including 17 size and color, which appeared on the packaging or containers in 18 Which THIS DEFENDANT sold and/or distributed RAW ASBESTOS FIBER. 19 ANSWER: 20 General Cable objects to this interrogatory on the 21 grounds that it is compound, disjunctive, contains impermissive 22 subparts and contains terms not defined in the question. General 23 Cable further objects to this interrogatory as overly broad and 24 therefore burdensome and oppressive. These interrogatories 25 request detailed information not reasonably calculated to lead to 26 the discovery of admissible evidence and which falls outside the 27 scope of this litigation. Without waiving the foregoing 28 objections, General Cable responds as follows: Not applicable. GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 27. O O 1 INTERROGATORY NO. 28: 2 Describe the packaging or containers in which THIS DEFENDANT 3 sold and/or distributed ASBESTOS-CONTAINING PRODUCT(S), including 4 composition, dimension, shape and color. 5 ANSWER: 6 General Cable objects to this interrogatory on the 7 grounds that it is compound, disjunctive, contains impermissive 8 subparts and contains terms not defined in the question. General 9 Cable further objects to this interrogatory as overly broad and 10 therefore burdensome and oppressive. These interrogatories 11 request detailed information not reasonably calculated to lead to 12 the discovery of admissible evidence and which falls outside the 13 scope of this litigation. Without waiving the foregoing 14 objections, General Cable responds that this information may be 15 contained in General Cable*s product catalogs which will be made 16 available at a mutually agreeable time. 17 INTERROGATORY NO. 29: 18 Describe any logo, design, marking or printing, including 19 size and color, which appeared on the packaging or containers in 20 which THIS DEFENDANT sold and/or distributed ASBESTOS-CONTAINING 21 PRODUCT(S). 22 ANSWER: 23 General Cable objects to this interrogatory on the 24 grounds that it is compound, disjunctive, contains impermissive 25 subparts and contains terms not defined in the question. General 26 Cable further objects to this interrogatory as overly broad and 27 therefore burdensome and oppressive. These interrogatories 28 request detailed information not reasonably calculated to lead to GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 28. O O 1 the discovery of admissible evidence and which falls outside the 2 scope of this litigation. Without waiving the foregoing 3 objections, General Cable responds that this information may be 4 contained in General Cable's product catalogs which will be made 5 available at a mutually agreeable time. 6 7 INTERROGATORY NO. 30: 8 Does THIS DEFENDANT have any exemplar(s) of packaging or 9 containers in which its RAW ASBESTOS FIBER and /or ASBESTOS- 10 CONTAINING PRODUCT(S) were sold and/or distributed? If so, 11 state: 12 a. the location of each exemplar; 13 b. the year(s) in which said exemplar(s) was utilized; 14 c. the IDENTITY of the custodian of such exemplars. 15 ANSWER : 16 General Cable objects to this interrogatory on the 17 grounds that it is compound, disjunctive, contains impermissive 18 subparts and contains terms not defined in the question. General 19 Cable further objects to this interrogatory as overly broad and 20 therefore burdensome and oppressive. These interrogatories 21 request detailed information not reasonably calculated to lead to 22 the discovery of admissible evidence and which falls outside the 23 scope of this litigation. Without waiving the foregoing 24 objections, General Cable responds as follows: No. 25 INTERROGATORY NO. 31: 26 Did THIS DEFENDANT put warnings of asbestos-related health 27 hazards on bags of RAW ASBESTOS FIBER? If so, please state: 28 GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 29. O o 1 a. the wording of such warning(s), including size, 2 location and color; 3 b. whether the warning was put on a tag attached to the 4 bags; 5 c. the date such warning(s) was first used; 6 d. whether any change was made in the wording of such 7 warnings, the date(s) of such change, and the reasons for such 8 change. 9 ANSWER: 10 General Cable objects to this interrogatory on the 11 grounds that it is compound, disjunctive, contains impermissive 12 subparts and contains terms not defined in the question. General 13 Cable further objects to this interrogatory as overly broad and 14 therefore burdensome and oppressive. These interrogatories 15 request detailed information not reasonably calculated to lead to e the discovery of admissible evidence and which falls outside the 17 scope of this litigation. Without waiving the foregoing 18 objections, General Cable responds as follows: Not applicable. 19 INTERROGATORY NO. 32: 20 Did THIS DEFENDANT put warnings of asbestos-related health 21 hazards on the packaging or containers of ASBESTOS-CONTAINING 22 PRODUCT(S)? If so, please state: 23 a. the wording of such warning(s), including size, 24 location on the packaging or containers, and color; 25 b. the date such warning(s) was first used; 26 c. whether any change was made in the wording of such 27 warning(s), the date(s) of such change, and the reason(s) for 28 such change. GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 30. O O 1 ANSWER: 2 General Cable objects to this interrogatory on the 3 grounds that it is compound, disjunctive, contains impermissive 4 subparts and contains terms not defined in the question. General 5 Cable further objects to this interrogatory as overly broad and 6 therefore burdensome and oppressive. These interrogatories 7 request detailed information not reasonably calculated to lead to 8 the discovery of admissible evidence and which falls outside the 9 scope of this litigation. Without waiving the foregoing 10 objections, General Cable responds that no such warnings were 11 necessary because its products posed no asbestos health hazard 12 whatsoever. 13 INTERROGATORY NO. 33: 14 Has THIS DEFENDANT distributed any brochures or pamphlets 15 that contain warnings of any asbestos-related health hazards? If 16 so, please state: 17 a. the wording of such warning(s); 18 b. the method used to distribute such brochures or 19 pamphlets; 20 c. the date(s) such brochures or pamphlets were first 21 issued; 22 d. whether THIS DEFENDANT has exemplar(s) of such 23 brochures or pamphlets; 24 e. the IDENTITY of the custodian of such exemplar(s). 25 ANSWER: 26 General Cable objects to this interrogatory on the 27 grounds that it is compound, disjunctive, contains impermissive 28 subparts and contains terms not defined in the question. General GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 31. O O 1 Cable further objects to this interrogatory as overly broad and 2 therefore burdensome and oppressive. These interrogatories 3 request detailed information not reasonably calculated to lead to 4 the discovery of admissible evidence and which falls outside the 5 scope of this litigation. Without waiving the foregoing 6 objections, General Cable responds that it distributed no such 7 brochures or pamphlets because its products posed no asbestos 8 health hazard whatsoever. 9 INTERROGATORY NO. 34; 10 Did THIS DEFENDANT warn its employees and/or CONTRACT 11 UNIT(S), anywhere in the United States, that exposure to asbestos 12 could be hazardous to human health? If so, state: 13 a. whether copies of DOCUMENTS containing such warnings 14 exist; 15 b. the IDENTITY of the custodian of such DOCUMENTS. 16 ANSWER: 17 General Cable objects to this interrogatory on the 18 grounds that it is compound, disjunctive, contains impermissive 19 subparts and contains terms not defined in the question. General 20 Cable further objects to this interrogatory as overly broad and 21 therefore burdensome and oppressive. These interrogatories 22 request detailed information not reasonably calculated to lead to 23 the discovery of admissible evidence and which falls outside the 24 scope of this litigation. Without waiving the foregoing 25 objections, General Cable responds that its asbestos-containing 26 products posed no health hazard whatsoever. 27 / / / 28 / / / GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 32. O O 1 INTERROGATORY NO. 35; 2 State the IDENTITY of medical directors and/or industrial 3 hygienist retained by THIS DEFENDANT in the United States. 4 ANSWER: 5 General Cable objects to this interrogatory on the 6 grounds that it is compound, disjunctive, contains impermissive 7 subparts and contains terms not defined in the question. General 8 Cable further objects to this interrogatory as overly broad and 9 therefore burdensome and oppressive and because it improperly 10 seeks information protected by the attorney work-product 11 privilege. These interrogatories request detailed information 12 not reasonably calculated to lead to the discovery of admissible 13 evidence and which falls outside the scope of this litigation. 14 Without waiving the foregoing objections, General Cable responds 15 that it retained no medical directors or industrial hygienists. 16 In 1972 or 1973, a ''safety1* department was created under the 17 Industrial Relations Division. Discovery is continuing as to the 18 identity of the person or persons in charge of the "safety" 19 department. 20 INTERROGATORY NO. 36; 21 Has any employee of THIS DEFENDANT testified by deposition 22 on behalf of THIS DEFENDANT in a third-party case, brought in the 23 United States, wherein the plaintiff has alleged an asbestos- 24 related injury? If so, for each such third party case, please 25 state: 26 a. the caption and case number; 27 b. the court of filing including state and county; 28 c. the date of the deposition; GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 33. O O 1 d. 2 ANSWSll the name and address of plaintiff's counsel of record. 3 General Cable objects to this interrogatory on the 4 grounds that it is compound, disjunctive, contains impermissive 5 subparts and contains terms not defined in the question. General 6 Cable further objects to this interrogatory as overly broad and 7 therefore burdensome and oppressive. These interrogatories 8 request detailed information not reasonably calculated to lead to 9 the discovery of admissible evidence and which falls outside the 10 scope of this litigation. In addition, General Cable objects to 11 this interrogatory on the grounds that it exceeds the scope of 12 permissive discovery set forth in Code of Civil Procedure section 13 2030 and is not accompanied by a declaration for additional 14 discovery and therefore is burdensome and oppressive. 15 INTERROGATORY NO. 37: 16 Has THIS DEFENDANT been a member of the following? 17 a. Asbestos Textile Institute (ATI); 18 b. Industrial Hygiene Foundation and/or Industrial Health 19 Foundation (IHF); 20 c. Mineral Wool Institute; 21 d. Industrial Mineral Insulation Manufacturers Institute ; 22 e. Magnesia Silica Insulation manufacturers Association; 23 f. National Insulation Manufacturers Association (NIMA); 24 g. Thermal Insulation Manufacturers Association (TIMA); 25 h. Asbestos Information Association (AIA); 26 i. Quebec Asbestos Mining Association (QAMA); 27 j. National Safety Council; 28 k. Asbestos Cement Producers Association; GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 34. O o 1 l. Refactories Institute; 2 m. any other organizations or associations of 3 manufacturers, miners, distributors, importers, labelers, 4 suppliers, and/or sellers of ASBESTOS-CONTAINING PRODUCT(S); 5 (i) please state the name(s) of such organizations or 6 associations. 7 ANSWER; 8 General Cable objects to this interrogatory on the 9 grounds that it is compound, disjunctive, contains impermissive 10 subparts and contains terms not defined in the question. General 11 Cable further objects to this interrogatory as overly broad and 12 therefore burdensome and oppressive. These interrogatories 13 request detailed information not reasonably calculated to lead to 14 the discovery of admissible evidence and which falls outside the 15 scope of this litigation. In addition, General Cable objects to 16 this interrogatory on the grounds that it exceeds the scope of 17 permissive discovery set forth in Code of Civil Procedure section 18 2030 and is not accompanied by a declaration for additional 19 discovery and therefore is burdensome and oppressive. Without 20 waiving the foregoing objections, General Cable responds that to 21 the best of its knowledge it has never been a member of any of 22 these organizations except the National Safety Council. General 23 Cable believes it has been a member of the National Safety 24 Council since 1947 or 1949. 25 INTERROGATORY NO. 38: 26 For each organization, association or other entity 27 identified in your Response to Interrogatory No. 37, please 28 state: GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 35. O O 1 a. the dates during which THIS DEFENDANT was a member; 2 b. the name(s) of any publication(s) received by THIS 3 DEFENDANT from such association or organization; 4 c. the name of such committee or subcommittee of which 5 THIS DEFENDANT was a member, and the dates of such committee or 6 subcommittee membership. 7 8 ANSWER: 9 General Cable objects to this interrogatory on the 10 grounds that it is compound, disjunctive, contains impermissive 11 subparts and contains terms not defined in the question. General 12 cable further objects to this interrogatory as overly broad and 13 therefore burdensome and oppressive. These interrogatories 14 request detailed information not reasonably calculated to lead to 15 the discovery of admissible evidence and which falls outside the 16 scope of this litigation. In addition, General Cable objects to 17 this interrogatory on the grounds that it exceeds the scope of 18 permissive discovery set forth in Code of Civil Procedure section 19 2030 and is not accompanied by a declaration for additional 20 discovery and therefore is burdensome and oppressive. Without 21 waiving the foregoing objections, General Cable responds as 22 follows: Please see response and objections to Interrogatory No. 23 38, incorporated herein by reference. 24 INTERROGATORY NO. 39: 25 Has THIS DEFENDANT received an DOCUMENT(S) containing 26 results or conclusions of any studies and/or tests conducted by 27 the Saranac Laboratory at the Trudeau Foundation relating to the 28 human health consequences of asbestos? If so, please: GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 36. O O 1 a. IDENTIFY all such DOCUMENT{S); 2 b. state the date upon which THIS DEFENDANT first received 3 such DOCUMENT(S); 4 c. the IDENTITY of the custodian of such DOCUMENT(S). 5 ANSWER: 6 General Cable objects to this interrogatory on the 7 grounds that it is compound, disjunctive, contains impermissive 8 subparts and contains terms not defined in the question. General 9 Cable further objects to this interrogatory as overly broad and 10 therefore burdensome and oppressive. These interrogatories 11 request detailed information not reasonably calculated to lead to 12 the discovery of admissible evidence and which falls outside the 13 scope of this litigation. In addition, General Cable objects to 14 this interrogatory on the grounds that it exceeds the scope of 15 permissive discovery set forth in Code of Civil Procedure section 16 2030 and is not accompanied by a declaration for additional 17 discovery and therefore is burdensome and oppressive. Without 18 waiving the foregoing objections, General Cable responds that it 19 does not have such documents. 20 INTERROGATORY NO. 40: 21 State whether THIS DEFENDANT has ever maintained a library 22 (or libraries) in the United States which contains books, 23 articles, periodicals, journals and/or reference materials that 24 relate to the subjects of asbestos, industrial hygiene, medicine, 25 safety, occupational disease and/or engineering. If so, state: 26 a. the date each such library was established; 27 b. the location of each such library; 28 GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 37. O O 1 c. the IDENTITY of each librarian or other person in Z charge of such library. 3 ANSWER! 4 General Cable objects to this interrogatory on the 5 grounds that it is compound, disjunctive, contains impermissive 6 subparts and contains terms not defined in the question. General 7 Cable further objects to this interrogatory as overly broad and 8 therefore burdensome and oppressive. These interrogatories 9 request detailed information not reasonably calculated to lead to 10 the discovery of admissible evidence and which falls outside the 11 scope of this litigation. In addition, General Cable objects to 12 this interrogatory on the grounds that it exceeds the scope of 13 permissive discovery set forth in Code of Civil Procedure section 14 2030 and is not accompanied by a declaration for additional 15 discovery and therefore is burdensome and oppressive. As of 16 1978, General Cable had twenty-one plants in fifteen states and 17 three countries and it is therefore impossible to respond to this 18 interrogatory. 19 INTERROGATORY NO. 41; 20 Has THIS DEFENDANT exchanged documents containing the 21 results of or communicated with any individual or other COMPANY 22 regarding tests and/or studies of the relationship between the 23 inhalation of asbestos fibers and development of disease(s)? If 24 so, please state: 25 a. each individual or COMPANY with whom the information 26 was exchanged or to whom it was communicated; 27 b. the date(s) of any such exchanges or communications; 28 c. the IDENTITY of the custodian of such documents. GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 38. 1 ANSWER; 2 General Cable objects to this interrogatory on the 3 grounds that it is compound, disjunctive, contains impermissive 4 subparts, contains terms not defined in the question and seeks 5 information protected by the attorney work product privilege. 6 General Cable further objects to this interrogatory as overly 7 broad and therefore burdensome and oppressive. These 8 interrogatories request detailed information not reasonably 9 calculated to lead to the discovery of admissible evidence and 10 which falls outside the scope of this litigation. In addition, 11 General Cable objects to this interrogatory on the grounds that 12 it exceeds the scope of permissive discovery set forth in Code of 13 Civil Procedure section 2030 and is not accompanied by a 14 declaration for additional discovery and therefore is burdensome 15 and oppressive. 16 i n t e r r o g a t o r y .NO^ A ,2; 17 Has any employee of THIS DEFENDANT testified before the 18 Occupational Safety and Health Administration, the National 19 Institute of Occupational Safety and Health, or any committee or 20 subcommittee of the United States Congress on the inhalation of 21 asbestos dust and the development of disease? If so, please 22 state: 23 a. the entity before whom such testimony was given; 24 b. the date(s) and location(s) of such testimony; 25 c. the IDENTITY of the individual(s) who so testified; 26 d. whether any DOCUMENTS were presented to the entity 27 before which testimony was given; 28 GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 39. 1 e. whether copies of d o c u m e n t s presented were retained by 2 THIS DEFENDANT ; 3 (i) if so, state the IDENTITY of the custodian of the 4 DOCUMENT(S). 5 ANSWER: 6 General Cable objects to this interrogatory on the 7 grounds that it is compound, disjunctive, contains impermissive 8 subparts and contains terms not defined in the question. General 9 Cable further objects to this interrogatory as overly broad and 10 therefore burdensome and oppressive. These interrogatories 11 request detailed information not reasonably calculated to lead to 12 the discovery of admissible evidence and which falls outside the 13 scope of this litigation. In addition, General Cable objects to 14 this interrogatory on the grounds that it exceeds the scope of 15 permissive discovery set forth in Code of Civil Procedure section 16 2030 and is not accompanied by a declaration for additional 17 discovery and therefore is burdensome and oppressive, without 18 waiving the foregoing objections, General Cable responds that, to 19 its knowledge, no such testimony has been given by any General 20 Cable employee. 21 INTERROGATORY NO. 43: 22 At any of the physical facilities identified in the response 23 to Interrogatory No. 15, has THIS DEFENDANT conducted, or caused 24 to be conducted, tests and/or studies of ambient asbestos dust 25 created during the manufacture, processing and/or assembling of 26 ASBESTOS-CONTAINING PRODUCT(S)? If so, please state: 27 a. each manufacturing facility, including location and 28 address, at which any test and/or study was conducted. GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 40. 1 b. the date of each such test and/or study; 2 c. the individual(s) or entity conducting each such test 3 and/or study; 4 d. whether THIS DEFENDANT has any documents containing the 5 results and/or conclusions of each such study; 6 e. the IDENTITY of the custodian of the documents. 7 ANSWER: 8 General Cable objects to this interrogatory on the 9 grounds that it is compound, disjunctive, contains impermissive 10 subparts and contains terms not defined in the question. General 11 Cable further objects to this interrogatory as overly broad and 12 therefore burdensome and oppressive. These interrogatories 13 request detailed information not reasonably calculated to lead to 14 the discovery of admissible evidence and which falls outside the 15 scope of this litigation. In addition, General Cable objects to 16 this interrogatory on the grounds that it exceeds the scope of i 17 permissive discovery set forth in Code of Civil Procedure section 18 2030 and is not accompanied by a declaration for additional 19 discovery and therefore is burdensome and oppressive. Without 20 waiving the foregoing.objections, General Cable responds that it 21 is unaware of any such studies. 22 INTERROGATORY NO. 44: 23 Has THIS DEFENDANT conducted, or caused to be conducted, any 24 tests and/or studies on ambient asbestos dust levels at any 25 location or job site where its ASBESTOS-CONTAINING PRODUCTS were 26 utilized in the United Sates? If so, please state: 27 a. the location, including name and address, at which each 28 such test and/or study was conducted; GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 41. 1 b. the individual or entity conducting each such test 2 and/or study; 3 c. the date of each such test and/or study; 4 d. whether THIS DEFENDANT has any DOCUMENTS containing the 5 results and/or conclusions of each such test and/or study; 6 e. the IDENTITY of the custodian of these DOCUMENTS. 7 ANSW.gR,:, 8 General Cable objects to this interrogatory on the 9 grounds that it is compound, disjunctive, contains impermissive 10 subparts and contains terms not defined in the question. General 11 Cable further objects to this interrogatory as overly broad and 12 therefore burdensome and oppressive. These interrogatories 13 request detailed information not reasonably calculated to lead to 14 the discovery of admissible evidence and which falls outside the IS scope of this litigation. In addition, General Cable objects to 16 this interrogatory on the grounds that it exceeds the scope of 17 permissive discovery set forth in Code of Civil Procedure section 18 2030 and is not accompanied by a declaration for additional 19 discovery and therefore is burdensome and oppressive. Without 20 waiving the foregoing objections, General Cable responds that it 21 is unaware of any such studies. 22 INTERROGATORY NO. 45: 23 Did THIS DEFENDANT have any laboratory or other facility 24 anywhere in the United States at which it conducted, or caused to 25 be conducted, any tests and/or studies of its ASBESTOS-CONTAINING 26 PRODUCTS to measure the amount of asbestos dust generated by any 27 use for which such products were designed? If so, please state: 28 GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 42. 1 a. the location, including name and address, at which each 2 such test and/or study was conducted; 3 b. the individual(s) or entity conducting each such test 4 and/or study; 5 c. the date of each such test and/or study; 6 d. whether THIS DEFENDANT has any DOCUMENTS containing the 7 results and/or conclusions of each such test and/or study; 8 e. the IDENTITY of the custodian of such DOCUMENTS. 9 ANSWER;, 10 General Cable objects to this interrogatory on the 11 grounds that it is compound, disjunctive, contains unpermissive 12 subparts and contains terms not defined in the question. General 13 Cable further objects to this interrogatory as overly broad and 14 therefore burdensome and oppressive. These interrogatories 15 request detailed information not reasonably calculated to lead to 16 the discovery of admissible evidence and which falls outside the 17 scope of this litigation. In addition, General Cable objects to 18 this interrogatory on the grounds that it exceeds the scope of 19 permissive discovery set forth in Code of Civil Procedure section 20 2030 and is not accompanied by a declaration for additional 21 discovery and therefore is burdensome and oppressive. Without 22 waiving the foregoing objections, General Cable responds as 23 follows: No. 24 INTERROGATORY NO. 47: 25 Has THIS DEFENDANT notified in writing any individuals or 26 COMPANIES to whom it MARKETed RAW ASBESTOS FIBER and/or ASBESTOS- 27 CONTAINING PRODUCT(S), anywhere in the United States, of the 28 ;BI WTW GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 43. 1 potential relationship between exposure to asbestos and disease? 2 If so, please state: 3 a. the date(s) THIS DEFENDANT provided this information; 4 b. the means used for transmittal of such information; 5 c. whether THIS DEFENDANT has any copies of an DOCUMENTS 6 transmitting such information; 7 d. the IDENTITY of the custodian of such documents. 8 ANSWER: 9 General Cable objects to this interrogatory on the 10 grounds that it is compound, disjunctive, contains impermissive 11 subparts and contains terms not defined in the question. General 12 Cable further objects to this interrogatory as overly broad and 13 therefore burdensome and oppressive. These interrogatories 14 request detailed information not reasonably calculated to lead to 15 the discovery of admissible evidence and which falls outside the 16 scope of this litigation. In addition, General Cable objects to 17 this interrogatory on the grounds that it exceeds the scope of 18 permissive discovery set forth in Code of Civil Procedure section 19 2030 and is not accompanied by a declaration for additional 20 discovery and therefore is burdensome and oppressive. Without 21 waiving the foregoing objections, General Cable responds that no 22 such notice was necessary because its products posed no asbestos- 23 related health hazard whatsoever. 24 INTERROGATORY NO. 48: 25 Has THIS DEFENDANT required any individual(s) who MARKETed 26 its ASBESTOS-CONTAINING PRODUCT(S) to wear respirators or face 27 masks? If so, please state: 28 GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 44.  1 a. the job title(s), if known, of individual(s) required 2 to wear respirators or face masks; 3 b. thedate(s) on which THIS DEFENDANT first required the 4 wearing of respirators or face masks; 5 c. whether THIS DEFENDANT has any copies of DOCUMENTS 6 communicating such requirements; 7 d. the IDENTITY of the custodian of such DOCUMENTS. 8 bsss m i 9 General Cable objects to this interrogatory on the 10 grounds that it is compound, disjunctive, contains unpermissive 11 subparts and contains terms not defined in the question. General 12 Cable further objects to this interrogatory as overly broad and 13 therefore burdensome and oppressive. These interrogatories 14 request detailed information not reasonably calculated to lead to 15 the discovery of admissible evidence and which falls outside the 16 scope of this litigation. In addition, General Cable objects to 17 this interrogatory on the grounds that it exceeds the scope of 18 permissive discovery set forth in Code of Civil Procedure section 19 2030 and is not accompanied by a declaration for additional 20 discovery and therefore is burdensome and oppressive, without 21 waiving the foregoing objections, General Cable responds that no 22 such action was necessary because its products posed no asbestos23 related health hazard whatsoever. 24 INTERROGATORY NO. 49: 25 Does or did THIS DEFENDANT utilize or employ any CONTRACT 26 UNIT? If so, please state:; 27 a. the inclusive periods of time the CONTRACT UNIT(S) was 28 utilized or employed; GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 45. 1 c. whether THIS DEFENDANT has any documents showing the 2 location(s) of the job site(s) where the CONTACT UNIT(S) worked, 3 and if so, state the IDENTITY of the custodian of such DOCUMENTS. 4 M S W EEl 5 General Cable objects to this interrogatory on the 6 grounds that it is compound, disjunctive, contains impermissive 7 subparts and contains terms not defined in the question. General 8 Cable further objects to this interrogatory as overly broad and 9 therefore burdensome and oppressive. These interrogatories 10 request detailed information not reasonably calculated to lead to 11 the discovery of admissible evidence and which falls outside the 12 scope of this litigation. In addition, General Cable objects to 13 this interrogatory on the grounds that it exceeds the scope of 14 permissive discovery set forth in Code of Civil Procedure section 15 2030 and is not accompanied by a declaration for additional 16 discovery and therefore is burdensome and oppressive. Without 17 waiving the foregoing objections, General Cable responds as 18 follows: No. 19 INTERROGATORY NO. 50: 20 Has THIS DEFENDANT received any written communication or 21 other DOCUMENT, other than a claim for workers' compensation, 22 that any person was claiming injury as a result of exposure to 23 its RAW ASBESTOS FIBER and/or ASBESTOS-CONTAINING PRODUCT( S ) ? If 24 so, please IDENTITY the first such written communication or 25 DOCUMENT. 26 ANSWER: 27 General Cable objects to this interrogatory on the 28 grounds that it is compound, disjunctive, contains impermissive GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 46. 1 subparts and contains terms not defined in the question. General 2 Cable further objects to this interrogatory as overly broad and 3 therefore burdensome and oppressive and potentially involves 4 hundreds of lawsuits around the country. These interrogatories 5 request detailed information not reasonably calculated to lead to 6 the discovery of admissible evidence and which falls outside the 7 scope of this litigation. In addition, General Cable objects to 8 this interrogatory on the grounds that it exceeds the scope of 9 permissive discovery set forth in Code of Civil Procedure section 10 2030 and is not accompanied by a declaration for additional 11 discovery and therefore is burdensome and oppressive. 12 13 INTERROGATORY NO. 51: 14 Has any person filed a claim for asbestos-related injury 15 regarding THIS DEFENDANT against any workers* compensation 16 insurance carrier which provided coverage for THIS DEFENDANT? If 17 so, please state: 18 a. the date of such claim 19 b. the name of claimant; 20 c. the caption; 21 d. the case number; 22 e. the court in which the claim was filed; 23 f. the IDENTITY of the custodian of such documents. 24 ANSWER: 25 General Cable objects to this interrogatory on the 26 grounds that it is compound, disjunctive, contains impermissive 27 subparts and contains terms not defined in the question. General 28 Cable further objects to this interrogatory as overly broad and GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 47. * X therefore burdensome and oppressive. These interrogatories 2 request detailed information not reasonably calculated to lead to 3 the discovery of admissible evidence and which falls outside the 4 scope of this litigation. In addition, General Cable objects to 5 this interrogatory on the grounds that it exceeds the scope of 6 permissive discovery set forth in Code of Civil Procedure section 7 2030 and is not accompanied by a declaration for additional 8 discovery and therefore is burdensome and oppressive. Without 9 waiving the foregoing objections, General Cable responds as 10 follows: No. 11 12 INTERROGATORY NO. 52: 13 Has any person filed a workers' compensation claim for 14 asbestos-related injury against THIS DEFENDANT? If so, please 15 state: 16 a. the date of such claim 17 b. the name of claimant; 18 c. the caption; 19 d. the case number; 20 e. the court in which the claim was filed; 21 f. the IDENTITY of the custodian of such documents. 22 M SWPBl 23 General Cable objects to this interrogatory on the 24 grounds that it is compound, disjunctive, contains impermissive 25 subparts and contains terms not defined in the question. General 26 Cable further objects to this interrogatory as overly broad and 27 therefore burdensome and oppressive. These interrogatories 28 request detailed information not reasonably calculated to lead to GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 48. 1 the discovery of admissible evidence and which falls outside the 2 scope of this litigation. in addition, General Cable objects to 3 this interrogatory on the grounds that it exceeds the scope of 4 permissive discovery set forth in Code of Civil Procedure section 5 2030 and is not accompanied by a declaration for additional 6 discovery and therefore is burdensome and oppressive. Without 7 waiving the foregoing objections, General Cable responds as 8 follows: No. 9 INTERROGATORY NO. 53: 10 Does THIS DEFENDANT have insurance available to cover 11 judgement(s) entered against it in asbestos-related personal 12 injury lawsuits? If so, please state: 13 a. the name and principal place of business of any 14 insurance carrier who has issued such policy of insurance; 15 b. the number and effective date of each policy; 16 c. the amount(s) of coverage of each policy; 17 d. the applicable dates of coverage; 18 e. any reservation of rights contained in each such 19 policy; 20 f. the amount of coverage presently exhausted under each 21 such policy; 22 g. the amount of coverage presently available under each 23 such policy; 24 h. whether limits contained in each such policy include 25 costs of defense. 26 ANSWER: 27 General Cable objects to this interrogatory on the 28 grounds that it is compound, disjunctive, contains impermissive GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 49. 1 subparts and contains terms not defined in the question. General 2 Cable further objects to this interrogatory as overly broad and 3 therefore burdensome and oppressive. These interrogatories 4 request detailed information not reasonably calculated to lead to 5 the discovery of admissible evidence and which falls outside the 6 scope of this litigation. In addition, General Cable objects to 7 this interrogatory on the grounds that it exceeds the scope of 8 permissive discovery set forth in Code of Civil Procedure section 9 2030 and is not accompanied by a declaration for additional 10 discovery and therefore is burdensome and oppressive, without 11 waiving the foregoing objections, General Cable responds that it 12 has bodily injury liability insurance coverage and it is 13 currently investigating the extent of its insurance coverage for 14 asbestos bodily injury claims, including the insurance carriers, 15 policies, policy periods and available limits. 16 INTERROGATORY NO. 54: 17 Has THIS DEFENDANT owned or operated any petroleum refining 18 facilities? If so, please state: 19 a. whether any ASBESTOS-CONTAINING PRODUCT(S) were 20 MARKETed on the premises of such refining facilities; 21 b. the location, including the name and address of all 22 such refining facilities; 23 c. the dates of operation of such refining facilities; 24 d. the types of ASBESTOS-CONTAINING PRODUCT(S) MARKETed on 25 such premises; 26 e. the names of the manufacturers of any ASBESTOS- 27 CONTAINING PRODUCT(S) MARKETed on such premises; 28 GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 50. 1 f. whether THIS DEFENDANT has documents identifying such 2 MARKETing; 3 g. the IDENTITY of the custodian of such documents. 4 ANSWER: 5 General Cable objects to this interrogatory on the 6 grounds that it is compound, disjunctive, contains impermissive 7 subparts and contains terms not defined in the question. General 8 Cable further objects to this interrogatory as overly broad and 9 therefore burdensome and oppressive. These interrogatories 10 request detailed information not reasonably calculated to lead to 11 the discovery of admissible evidence and which falls outside the 12 scope of this litigation. In addition, General Cable objects to 13 this interrogatory on the grounds that it exceeds the scope of 14 permissive discovery set forth in Code of Civil Procedure section 15 2030 and is not accompanied by a declaration for additional 16 discovery and therefore is burdensome and oppressive. Without 17 waiving the foregoing objections, General Cable responds as 18 follows: No. 19 i m B B a g A T O B K .NQ , M l 20 Has THIS DEFENDANT held a controlling ownership interest in 21 any COMPANY which owned or operated petroleum refining 22 facilities? If so, for the period(s) of time petroleum refining 23 facilities? If so, for the period(s) of time during which THIS 24 DEFENDANT held such interest, please state: 25 a. whether any ASBESTOS-CONTAINING PRODUCTS were MARKETed 26 on the premises of such refining facilities; 27 b. the location, including the name and address of all 28 such refining facilities; GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 51. 1 c. the dates of operation of such refining facilities; 2 d. the types of ASBESTOS-CONTAINING PRODUCTS MARKETed on 3 such premises; 4 e. the names of the manufacturers of any ASBESTOS- 5 CONTAINING PRODUCTS MARKETed on such premises; 6 f. whether THIS DEFENDANT has DOCUMENTS identifying such 7 MARXETing; 8 g. the IDENTITY of the custodian of such DOCUMENTS. 9 10 ANSWER; 11 General Cable objects to this interrogatory on the 12 grounds that it is compound, disjunctive, contains impermissive 13 subparts and contains terms not defined in the question. General 14 Cable further objects to this interrogatory as overly broad and 15 therefore burdensome and oppressive. These interrogatories 16 request detailed information not reasonably calculated to lead to 17 the discovery of admissible evidence and which falls outside the 18 scope of this litigation. In addition, General Cable objects to 19 this interrogatory on the grounds that it exceeds the scope of 20 permissive discovery set forth in Code of Civil Procedure section 21 2030 and is not accompanied by a declaration for additional 22 discovery and therefore is burdensome and oppressive. Without 23 waiving the foregoing objections, General Cable responds as 24 follows: No. 25 INTERROGATORY NO. 57; 26 Has THIS DEFENDANT contracted with any COMPANY for the 27 MARKETing of ASBESTOS-CONTAINING PRODUCT(S) on any premises owned 28 or leased by THIS DEFENDANT? If so, please state: GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 52. 1 a. the location, including name and address of such 2 premises; 3 b. the name and address of each such COMPANY; 4 C. the types of ASBESTOS-CONTAINING PRODUCT(S) 5 ANSWER: 6 General Cable objects to this interrogatory on the 7 grounds that it is compound, disjunctive, contains impermissive 8 subparts and contains terms not defined in the question. General 9 Cable further objects to this interrogatory as overly broad and 10 therefore burdensome and oppressive. These interrogatories 11 request detailed information not reasonably calculated to lead to 12 the discovery of admissible evidence and which falls outside the 13 scope of this litigation. In addition, General Cable objects to 14 this interrogatory on the grounds that it exceeds the scope of 15 permissive discovery set forth in Code of Civil Procedure section 16 2030 and is not accompanied by adeclaration for additional 17 discovery and therefore is burdensome and oppressive. Without 18 waiving the foregoing objections, General Cable responds as 19 follows: No. 20 DATED: May 21 22 , 1991 HANCOCK, ROTHERT & BUNSHOFT 23 By ___________ _ 24 Paul J. KJTllidn Attorneys for Defendant 25 GENERAL CABLE COMPANY 26 3776:\1076\026\ME L02O7.PLO] 27 28 GENERAL CABLE*S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 53. ! 1 ; j! t: P - I r I C A T 1 0 It I m currently the Director of Envlroneenta! Affairs for the Penn Contrai Corporation. I have read the above Responses of General Cable to Plaintiffs' Standard Interrogatories and know the contents thereof. The natters stated therein are true to the best of ay Infornation and belief. I declare under penalty of perjury under the laws of the State of California that the foregoing Is true and correct and that this daclaratlon was executed on Hay 8, 1991 at South Plainfield, New Jersey. 1 PROOF OP SERVICE 3Y K A I L 2 I declare that I aa over the age of 13 years and not a 3 party to this action; that ay business address is Four 4 Enbarcadero Center, Suite 1000, San Francisco, California, 94111. 5 On the date set out below, I served the foregoing 6 document, described as GENERAL CABLE'S RESPONSES TO PLAINTIFFS' 7 STANDARD U7T2RROGATORI.SS on the other parties in this action, 3 pursuant to the attached Service List, by placing a true copy 9 thereof enclosed in a sealed envelope, with postage fully prepaid 10 thereon, and deposited in the United States Mailbox at San 11 Francisco, California. 12 I declare under penalty of perjury under the lavs of 13 the State of California that the foregoing is true and correct. 14 Executed Kay 3, 1991 at San Francisco, California. 15 16 i/jUtnot. l/iAStJUVL, -- ____ DIANE VIVIAN DONNES 17 13 19 20 21 22 23 24 25 26 27 23 iK Mmcamrmo c* GENERAL CABLE'S OBJECTIONS TO PLAINTIFF'S STANDARD INTERROGATORIES 55.