Document 3Q0bEk5eD3QnNRDBr9vrx11Ly

FILE NAME: BF Goodrich (BFG) DATE: 1987 DOC#: BFG045 DOCUMENT DESCRIPTION: Legal - Response to Interrogatories IN THE COURT OF COMMON PLEAS SUMMIT COUNTY/ _OHIO - 0034C1 CLIFFORDPENGELLY/ ' * ) ) Plaintiff, ) ) vs. ) ) THE B. F.GOODRICH COMPANY, ) ) Defendant. ) CASE NO. CV 86 12 4267 JUDGE MORGAN NOTICE OF SERVICE Pursuant to Rule 5(D) of the Ohio Rules of Civil Procedure, notice is hereby given that on this 20th day of May, 1987, counsel for Defendant served responses to P l a i n t i f f 's Interrogatories and Request for Production of Documents upon A. Russell Smith, 159 S. Main Street, Suite 503, Akron, Ohio 44308, by regular U.S. mail, postage prepaid, on the date referenced above. ROETZEL & ANDRESS I Jef fjeVytf..^Cas-feo ^--- ZS-'^stTMarket Street Akron, Ohio 44308 (216) 376-2700 Attorney for Defendant CERTIFICATE OF SERVICE A copy of the foregoing Notice of Service has been sent by regular U.S. mail, postage prepaid, to A. Russell Smith, Esc., 159 S. M a i n Street, Suite 503, Akron, Ohio 44308, this 20th day of May, 1937. __ __________________ ' ' Jeffrey Casto '-- A t t o m e y 'at' Law * 2 PLAINTIFF'S | EXHIBIT I 10 1 u-a-fe IN THE COURT OF COMMON PLEAS SUMMIT COUNTY/ OHIO CLIFFORD PENGELLY/ Plaintiff/ . -vs- THE B. F. GOODRICH COMPANY/ Defendant. ) CASE NO. CV 86 12 4267 ) ) JUDGE MORGAN ) ) ) ) ) DEFENDANT'S RESPONSE TO ) P L A I N T I F F 1S INTERROGATORIES Defendant, THE B. F. G O O D R I C H COMPANY ("GOODRICH") responds to Plaintiff's Interrogatories in accordance with the Ohio Rules of Civil Procedure as follows: PRELIMINARY STATEMENT AND GENERAL OBJECTIONS In providing the following answers to Interrogatories, GOODRICH does not waive, and it expressly preserves, all of the defenses and objections set forth in GOODRICH'S Answer to this action, which defenses and objections are incorporated herein by reference. Without conceding that an action for discovery is valid or lawful against GOODRICH, such an action for discovery is limited to the relief expressly stated in the Complaint, namely "to identify the names and manufacturers of the various asbestos products used in Defendant's tire plants." The Interrcgarcries unrelated seek a grea- deal of information completely goal and jal f requested in the Complaint. GOODRICH objects to any and all interrogatories seeking informarle n other than ens names of manufacturers or suooliers of any asbestos used in GOODRICH'S Akron/ Ohio tire plants. The interrogatories assume that "talc" and "soapstone" contain asbestos. GOODRICH has no present information that tal or soapstone used at its Akron/ Ohio tire manufacturing plants contained asbestos. (Throughout these interrogatory responses and this proceeding/ the term "asbestos" will refer to "asbestos fibers" as that term is defined by the Occupational Safety and Health Administration in 29 C.F.R. 1 9 1 0 .1001(b).) Although GOODRICH is voluntarily providing information concerning talc/soapstone/ no inference should be drawn that any talc or soapstone used at its Akron/ Ohio tire plants contained any asbestos. References to any asbestos-containing materials at Defendant's Akron, Ohio tire plants should not be construed as an express or implied admission that any asbestos fibers were airborne, or if they were, that any human exposure resulted. Defendant objects to Plaintiff's Interrogatories to the extent that they call for information that is not available or accessible from its present employees, but which instead is obtainable from third persons not employed by GOODRICH and/or from records kept or compiled by persons not employed by GOODRICH. Under the Rules of Civil Procedure, Defendant is required only to provide information within its custody, possession or control, and Defendant has no obligation tc obtain information from persons not currently employed by it. Various products and processes of Defendant are confidential and trade secrets. Defendant objects to the discovery to the extent that it seeks disclosure of detailed operating practices, process information, and other information that is protected from disclosure. Defendant objects to the discovery to the extent that it seeks to discover any privileged information, including, but not necessarily limited to, information protected by the attorney/client or work product privilege. Furthermore, GOODRICH objects to any interrogatories which request information concerning any of its plants in Summit County where Plaintiff did not work during his employment with Defendant since Mr. Pengelly is only entitled to discover the identity and names of manufacturers of various asbestos products in the specific work areas where he was employed. Without waiving the foregoing objections and defenses, GOO DRICH is voluntarily providing these responses and will make available to Plaintiff's counsel for inspection copies of non privileged documents, as indicated in the responses to individual interrogatories. All of the foregoing defenses and objections will be deemed incorporated by reference in these voluntary responses. INTERROGATORIES 1. State individual who the defendant. the name, is answering address, and job title of the these interrogatories on behalf of ANSWER : Jeffrey J. C a s to, Esq. Roetzel & Andress 75 E. Market Street Akron, Ohio 44308 The underlying information was compiled principally by: ! S. D. Henning The Uniroyal Goodrich Tire Company 600 S. Main Street Akron, Ohio 44397 A verification statement on behalf of Uniroyal Goodrich is attached to the end of these responses. 2. State the name and address of each of defendant's plants in the Summit County, Ohio area where tires have been manufactured and as to each plant, state the years during which tires were manufactured. ANSWER : The BPGoodrich Company 500 S. Main Street Akron, Ohio 44318 1895-1987 3. Identify defendant's tire plants in the Summit County, Ohio area which contained pipes or lines which were insulated with asbestos products. I ANSWER : ; All plants had pipes or lines insulated with asbestos- , containing materials. 1 4. State the names and addresses of all contractors known to have installed or supplied products containing asbestos to ! defendant's tire plants in the Summit County, Ohio area. ANSWER :* Goodrich does nor presently have available the names of any contractors who may have either installed or supplied products containing asbestos to defendant's tire plants in the Summit County, 2 'r .iz area. 5.- Does Che defendant maintain any records which would enable ic Co identify che names and/or matrufaccurers of produces containing asbestos which have been installed and/or supplied eo defendant's tire plants In ehe Summit County, Ohio area. . ANSWER: No records . responsive to this interrogatory have been located. 6 . If che answer to the foregoing interrogatory is in the affirmative, please state: - A. The identify and nature of che records kept. B. The name, address, and job t i d e of the custodlanCs) of said records. - ANSWER: n /A I Ii I! ! * -- 'U* * tea Ztm k *:::cm 3-*- *** * 7. State whether Che defendane used "soapscoue" for any in Che cire manufacturing planes in ics Sunaaic County, Ohio, area p between 1939.and ehe present dace. . ANSWER: Yes, assuming soapstone is the same proc referred to in the answer to Interrogatory No. 8 . 3. If Che answer Co Che foregoing interrogatory is in eh affirmative, scaee che various purposes for which soapstone would o in connection wich che cire manufacturing process. ANSWER: The terms "soapstone" and "talc" are o: used interchangeably. In general, talc and soapstone are common names for the platy form of the same generic mine: hydrous magnesium silicate, and talc usually refers to a r finely ground or highly processed form of the mine: " S o apstone/talc" was used as a '"de-tackifier", i.e., to c r u b b e r products to prevent them f rom sticking together du: intermediate processing operations. I iIII ! J W t 1C J . c* *:c (i :::c. 9. Scace Che name and address of each manufacturer and supplier of soapstone to defendant's tire manufacturing plants In the Summit Councv. Ohio, area from 1939 to Che present, and as to each such manufacturer or * supplier, scace: A. The name of each soapstone product and the name and address of its manufacturer. 3. The daces during which said product was supplied to the defendant and the defendant's plants to which it was supplied. C. The quantities purchased and Che intervals at which said quantities were purchased. D. Whether Che soapstone contained asbestos. ANSWER: T h e records r e t e n t i o n policy of Uniroyal Goodrich provides for the maintenance of purchasing records for the past six years plus current. According to our records, the following companies were approved as vendors but purchases were not necessarily made from all of these vendors. American Chemet Corp. 105 W. Madison Street Chicago, Illinois Cohutta Talc P.O. Box 363 Dalton, Georgia Eastern Magnesia Talc Co. Subsidiary of Engelhard Mineral & Chemical Corp. Menlo Park Edison, NJ 08817 (Distributed by C. ?- Hall, 4460 H u dson Drive, Stow, OH) International Talc Co. 90 West Street New York, NY Milwhite Co. P.O. Box 15038 Houston, TX 77020 Southern Talc (Georgia Talc) P.O. Drawer F Chatsworth, Georgia 30705 C. 3oaC { 4 SowasvtT rtr W C 103 : *C**3C4 \ zzet i a*. B. T his information cannot be obtained without an exhaustive review of Goodrich's records. Accordingly, Goodrich is willing/ at their option/ to either permit Plaintiffs access to review appropriate records to ascertain the information requested under a suitable protective order or Goodrich will review their records and provide the information requested upon pre-payment of the costs involved with the document search and retrieval. C. See answer to subpart B. D. To the best of our knowledge/ talc and soapstone supplied to Goodrich's tire manufacturing plants were asbestos-free. 10. State whecher che defendant used ''talc" for any reason in its tire manufacturing plants in the Summit County, Ohio area at any time between 1939 and the present. ANSWER: See Answer to Interrogatory No. 7. 11. If the answer to the foregoing interrogatory is in the affirmative, state the various purposes for which calc would be used in connection with che tire manufacturing process. ANSWER: See Answer to Interrogatory No. 8. i 1 i C. 3 3e< 4 ** i*cr* lU*t *.03 c*. ;- 3 -- ;ce *c ;;:c i-* k m * -5- 12. Staee the naae and address of each manufacturer and su of Calc eo defendant's tire manufacturing plants In the Summit County, Oh area from 1939 Co Che present > and as to each such manufacturer or suppii state: ~ ' A. The name of each calc product and the name and address of Its manufacturers. ' B. The daces during which said product was supplied to the defendant and Che defendant's planes to which It was supplied. C. The quantities purchased and the intervals at which said quantities were purchased. D. Whether the calc contained asbestos. ANSWER: See Answer to Interrogatory No. 9. I & Soiss** SOa** iwe 5*. eJi * sec v* 13. State the name, the address, and the job title of eh individual(s) in the employ of Che defendant who are nose knowledgeable regarding ehe names and manufaceurers of produces containing asbestos which were present in defendant's elre plants in ehe Summit County, Ohio, area from 1939 to ehe present. , ANSWER: James Vanorsdel Manager, Technical Department, Aircraft Tires The BFGoodrich Company 500 S. Main St. Akron, Ohio 44318 Harold W. Dietz Director of Health & Environmental Services The BFGoodrich Company 3925 Embassy Parkway Akron, Ohio 44313 14. State ehe name and ehe address, and the job title of individual(s) in ehe employ of ehe defendane who are mose knowledgeable regarding the names and manufaceurers of produces containing asbestos which were presene in defendane's cire planes in the Summit County, Ohio area prior eo 1939. . ANSWER: See answer to Interrogatory No. 13. i ivCo*c ZZ2t 3*4 I -3- 15. State Che name, address, and job eiele of chose individuals who have been in che employ of che defendant whose principal responsibillc* was eo manage or supervise shipping and receiving ac defendant's cire planes in the Surpaie County, Ohio, area from 1939 to the present, (If not all names are known, please identify those which are known, together with the years served in that capacity and at which plane.) ANSWER: objection. See introductory statement. in addition, this interrogatory seeks information which is unnecessary, duplicative and burdensome. Without waiving the foregoing objection, Goodrich does volunteer that the following individual had responsibility relevant to shipping and/or receiving: Bruce Kline Manager, Receiving and Shipping The BFGoodrich Company ' 500 S. Main Street Akron, Ohio 44318 16. State whether any products containing asbestos (including, but not limited to, insulating material, talc, soapstone, aprons, trays for hot knives, etc.) were present in the vicinity of employees working in the stock mixing process at defendant's tire plants in che Summit County, Ohio, area between 1939 and the present. ANSWER: Y e s . I w<*c. S S o * k Zc Sc*t V3J m JC4 : : : c <4  17. If che answer co the foregoing interrogatory is in the affirmative, state: A. The type of asbestos product used (e.g., pipe insulation soapstone, etc.). ~ ' B. The purpose for which it was used. C. The name and manufacturer of said product(s) . 0. The plantCs) at which said product was used and che years during which it was used. ANSWIS: A. Steam pipe insulation. Talc (soapstone) B. Talc was used as a d e - t a c k i f i e r . That is to say that it was used to keep rubber products from sticking together. Steam pipes-were insulated with asbestos-containing insulation. C. See answer to No. 9 for suppliers of talc. D. 500 S. Main Street Akron, Ohio 44318 13. State whether any products containing asbestos (including, but not limited to, insulating material, calc, soapstone, aprons, trays for hoc knives, etc.) were present in the vicinity of employees working in che dipping, heating, treating, tensioning, and calendaring process at defendant's tire plants in che Summit County, Ohio, area, between 1939 and che present. ANSVEB: Yes. . 19. If ch'e answer co che foregoing interrogatory is in affirmative, state: A. The type of asbescos produce used Ce.g., pipe insul . soapscone, eec.). - - B. The purpose for which ic was used. C. The name and manufsecurer of said produce(s). D. The plantCs) at which said produce was used and ehe during which ic was used. ANSWER: See answer to Interrogatory No. 17. 20. Scare whether any products containing asbescos Cine but not limited to, insulating material, talc, soapstone, aprons, for hot knives, etc.) were present in che vicinity of employees wo in Che waste and defective control department at defendant's tire ; in the Summit County, Ohio, area between 1939 and the present. To our knowledge, Goodrich did not have a "waste defective control department." i r j Jmit, *caf 1 * J"C* 1C 3 ***''!' >*C tree * i i 21. If Che answer to che foregoing interrogatory is ia the affirmative, state: A. The type of asbestos product used Ce*g* pipe insulation, soapstone, etc.). B. The purpose for which it was used. C. The name and manufacturer of said produccCs). D. The ?laat(s) at which said product was used and the years during which it was used. AUSWE3: n /A 22. State whether any products containing asbestos Cincluding, but not limited to, insulating material, calc, soapstone, aprons, trays for hoc knives, etc.) were present ia che vicinity of employees working in che tuber process (.tread extrusion, weighing, cooling, and cutting)^ at defendant's tire plants in the Summit C o u n t y , Ohio, area between 1939 and the present. AUSiiEl: Y e s . iwi* sc a X 23. If che answer Co Che foregoing interrogatory is in ehe affirmative, scace: -- . A. The cype of as&escos produce used (e.g., pipe insulation, soapscone, etc.). B. The purpose for which ic was used. . C. The name and manufacturer of said produce(s). D. The plancCs) at which said product was used and che years during which ic was used. ANSVZR: See answer to Interrogatory No. 17. 24. State whether any products containing as&estos (inducing hue not limited to, insulating material, talc, soapstone, aprons, trays hoc knives, etc.) were present in che vicinity of employees working in wire winding (head room) process at defendant's tire plants in che Sumni County, Ohio, area Between 1939 and che present. The use of talcs, etc. was avoided in this area. S|> ;<3c l C<S.3--. Cl** .Mt S3 e* :-- ici zszt : I 25. If Che answer Co che foregoing incerrogacory is in che affirmacive, scace: A. The cype of asbescos produce used (e.g., pipe insulacion, soapstone, ecc.). * B. The purpose for which ic was used. C. The name and manufacturer of said producc(s) . D. The planeCs) ac which said produce was used and che years during which ie was used. ANSWS3: N/A 25. SCace vhecher any produces concaining asbescos (including, hue noc limited Co, insulacing maesrial, calc, soapscone, aprons, trays ; for hoc knives, ecc.) were present in che vicinity of employees working : in Che maintenance department at defendant's tire plants in che Summit i County, Ohio, area between 1939 and the present. f j A3STC3: Since m a intenance employees performed work I at various parts of the plant, it is possible that they may ! have worked in the vicinity of materials containing asbestos. ! Whether maintenance employees were in the vicinity of asbestos- i containing materials would depend on the kinds of tasks ' performed. Maintenance employees occasionally did replacement of valve packings and gaskets, repair and replacement of steam lines and insulation. See other responses to Interrogatories for other tire manufacturing operations. & Coioa* Cw** *<** jrerg- Sm~c 10 3 X .* 27. If Che answer co the foregoing interrogatory is in the affirmative, state: A. The type of asbestos product used (e.g., pipe insulation, soapstone, etc.). 3. The purpose for which it was used. C. The name and manufacturer of said productCs). D. The planc(s) at which said product was used and the years during which it was used. ANSWER: A. See answer to Interrogatory No. 26 and response to other Interrogatories. B. See answers to other I n t e r r o g a t o r i e s . C. See answers to other I n t e r r o g a t o r i e s . D. See answers to other i n t e r r o g a t o r i e s . 23. State whether ar.y products containing asbestos (including but not limited co, 'insulating -material, calc, soapstone, aprons, trays hoc knives, etc.) were present in the vicinity of aaployees working in the stock cutting and splicing process at defendant's tire plants in tr.e Summit County, Ohio, area becveen 1939 and the present. ANSWER: See answer to Interrogatory No. 24. ow*c. "c+t ! sew* Kh sej c 29. If Che answer Co che foregoing ineerrogaeory is in che affiraaeive, scace: A. The cype of asbescos produce used (e.g., pipe insulacion, soapscone, ecc.). B. The purpose for which ie was used. C. The name and aanufaccurer of said produce(s) . D. The planeCs) ae which said produce was used and ehe years during which ie was used. ANSWER: N/A 30. Scace vhecher any produces ccncaining asbescos (including, hue aoc liaiced eo, iasulacing macerial, calc, soapscone, aprons, crays for hoc kaiwes, ecc.) were pTesene in ehe viciaicy of-employees working in ehe cire 5uilding ac defendanc's cire planes in ehe Smsaic Councy, Ohio, area beeween 1939 and che presenc. ANSWER: See answer to to Interrogatory No. 24. 3m * iC* * MA.M i**lf* iw.-t !*j : : : c i-n 31. If Che answer Co che foregoing lncerrogacory Is la che affirmative, scace: A. The C7?e of asbestos prodacc used (e.g., pipe insulation, soapstone, etc.). . B. The purpose for which it was used. C. The name and manufacturer of said product(s) . D. The plantCs) at which said product was used and the years during which it was used. ANSWER: N/A 32. State whether an7 products containing asbestos Ciaduding but not limited to, insulating material, talc, soapstone, aprons, -trays for hot knives, etc.) were present in the vicinity of employees working in the tire curing Cfaming and vulcanizing) process at defendant's tire plants in the Summit County, Ohio, area between 1939 and che presen ANSWER: Yes 33. If ehe ansver Co the foregoing interrogatory is in the ' affirmative, scace: A. The type of asbestos produce used (e.g., pipe insulaeion, soapstone, etc.)* B. The purpose for which it was used. C. The name and manufacturer of said product(s). ' D. The plantCs) at which said product was used and the years during which ic was used. ANSWER: A. Pipe insulation Talc B. Pipe insulation Transite type platen insulators Brake shoes that may have contained asbestos C. Information not available. 0. 500 S. Main Street Akron, Ohio 44318 3*i. State whether any products containing asbestos (including, but not limited to, insulating material, calc, soapstone, aprons, trays for hot knives, etc.) were present in Che vicinity of employees working in the cement house ac defendant's tire plants in the Summit County, Ohio, area between 1939 and the present. ANSWEE: Yes 3o*C 4 r** ( 5W? sej e* :~o 2^ ;:c i %  35. If Che answer co che foregoing interrogatory is in che affirmative, scace: A. The cype of asbestos product used (e.g., pipe Insulation, soapscone, etc.). B. The purpose foT which ic was used. C. The name and manufacturer of said producc(s) D. The plancCs) ac which said produce was used and che years during which ic was used. ANSWER: A. Pipe insulation Talc B. Used in antiblemish paints and as a detackifying agent/ also in the preparation of bladder release coatings. ' 36. Scace whether any products containing asbestos Ciacluding, but noc limited co, insulating material, calc, soapscone, aprons, trays for hoc knives, etc.) were presenc in che vicinity of employees working in che tire mold cleaning process ac defendant's cire plants in che Sesasic County, Ohio, area between 1939 and che presenc. ic l 3Ck3r JOJ zzzc ( -1* I 37. If che answer eo che foregoing interrogatory is i affirmative, state: A. The cype of asbestos product used (e.g., pipe insu soapstone, etc.). B. The purpose for which it was used. C. The name and manufacturer of said product(s). D. The plane(s) at which said product was used and th during which ie was used. ANSVZR: N/A 38. State whether any produces containing asbestos (: but not limited to, insulating material, talc, soapstone, apron for hoe knives, etc.) were present in che vicinity of employees in Che tire mold changing process at defendant's tire plants in Summit County, Ohio, area between 1939 and the present. AN3VZ3,: Yes. 39. If the answer to Che foregoing interrogatory is *a the affirmative, state: A. The type of asbestos product used (e.g., pipe insulation, soapstone, etc.). B. The purpose for which it was used. C. The name and manufacturer of said producc(s). D. The plant(s) at which said product was used and the years during which it was used. ANSWER: See a n s w e r to Interrogatory No. 33. 40. State whether any products containing asbestos (including, but not limited to, insulating material. Calc, soapstone, aprons, trays for hoc knives, etc.) were present in the vicinity of employees working at the banbury at defendant's tire plants in the Summit County, Ohio, area between 1939 and the present. ANSWER: Yes 3Q*t I & | JCU Ar(f } f Id** !=3 ! C"* 2--0 MIC * : s : c : : > if STATE WHETHER ANY PRODUCTS CONTAINING ASBESTOS (INCLUDING BUT NOT LIMITED TO/ INSULATING MATERIAL, TALC, SOAPSTONE, APRONS, TRAYS FOR HOT KNIVES, etc.) WERE .PRESENT IN THE VICINITY OP EMPLOYEES WORKING AT THE BANBURY AT DEPENDANT'S TIRE PLANTS IN SUMMIT COUNTY, OHIO AREA BETWEEN 1939 AND THE PRESENT. ANSWER: YES ANSWER: SEE ANSWER TO INTERROGATORY NO. 17 (A) STEAM PIPE INSULATION TALC (SOAPSTONE) (B) TALC WAS USED AS A DE-TACKIPIER. THAT IS TO SAY THAT IT WAS USED TO KEEP RUBBER PRODUCTS PROM STICKING TOGETHE STEAM PIPES WERE INSULATED WITH ASBESTOS-CONTAINING INSULATION. (C) SEE ANSWER TO No. 9 FOR SUPPLIERS OP TALC. (D) 500 SOUTH MAIN STREET, AKRON, Ohio 44318. 41 'If the answer to the foregoing interrogatory Is in ehe affirmative, state: A. The type of asbestos product used (e.g., pipe insulation, soapstone, etc.). - B. The purpose for which it was used. C. The name and manufacturer of said pToductCs). D. The plantCs) at which said product was used and the years during which it was used. ANSWER: See answer to Interrogatory No. 17 42. Did the defendant employ any individuals in its Summit County, Ohio, area tire plants between 1939 and the present, whose job responsibilities included installation and repair of insulating material, including asbestos. ANSWER: yes. 5c*c C*-< -- 311 SCC 43. If che answer Co che foregoing interrogatory is in . e affirmative, scace: " A. The name and address of said individual(s) and che y-.-s during which said services were performed for che de;7 an B. The nacure of Che insulation work performed. C. The planes ac which said work was performed. D. The names and manufacturers of Che produces conCaining asbestos. ' E. The name, address, and job eicle of che individual in chi employ of che defendant who is mese knowledgeable regarding inscallacion or repair of asbescos containing produces by defendant's employees. ANSWER: Objection. See introductory statement. Further, this Interrogatory asks for information unrelated to any stated or legitimate objective of a Complaint for Discovery. In addition, this Interrogatory is overly burdensome. Without waiving said objection, Goodrich volunteers the following information: Richard Rhoten Area Engineer, Facilities Powerhouse The BFGoodrich Company 500 S. Main St. Akron, Ohio 44318 Dennis Oleksuk Manager, Akron Facilities The BFGoodrich Company 500 S. M ain Street Akron, Ohio 44318 44. Does che defandaaC maintain records which include ch floor .plans indicating where various tire producing processes (e.g., the banbury, che curing room, ecc.) were stationed in its Cire planes in the Summit Councy, Ohio, area. ANSWER: Some building floor plans retained; however, many have been destroyed. have been 45. Ix che answer to che foregoing interrogatory is in t affirmative, state che name, address, and job title of the individual ir. the employ of che defendant who is presently in custody of said floor plans. _ ANSWER: Jerry Meadows, Plant Engineer Aircraft Tires The BFGoodrich Company 500 S. Mai n Street Akron, Ohio 44318 46. State che name(s), address, and job title of che individual(s) presently in custody of plaintiff's work and medical records, including but not limited to, wage and assignment information, job performance and evaluation, and information regarding the identity of his supervisors or foremen. ANSWER: Objection, medical records of plaintiff. defendant has produced the 47, State whether the defendant, either through its own employees or independent contractors, has undertaken to remove insulation products containing asbestos from any of its tire plants ia the Summit County, Ohio, area since 1975. ANSWER: y eg . 4 ScwdSMi* scut"* J' ICC* W iC> C *4 43. If Che answer to che forgoing interrogatory is in the affirmative, state: A. The name and address of che enticy performing said removal. B. The time and place (including plant and specific loc ation) of said removal. C. The purpose for the removal. D. The name, description, and manufacturer of che products which were removed, if known. E. Whether the removal was conducted in accordance with E?A, OSHA or other guidelines (please specify) ANSWER: A. Holub Iron and Steel Akron/ Ohio The Ruhlin Company Akron/ Ohio The Beaver Excavating Company Canton/ Ohio Broadway Wrecking Company Cleveland, Ohio B. 1979 through 1985 at various buildings throughout the Akron tire manufacturing area. C. Demolition and partial removal of several buildings. * > CTE7T77CAT; ;? 5Ir v t :e I hereby terrify that a copy of the foregoing Interrogatories have been forwarded by regular 7.3. Mail this dav of Sa.zza.Ty, 153" D . Unknown E. All removal was in accordance wit h EPA regulations and the appropriate filings were made as required under 40 CFR Part 61 of U.S. E P A 1s .regulations on National Emission Standards for Hazardous Air Pollutants, Subpart B, Paragraph 61.22(d)(2). CERTIFICATE OF SERVICE This is to certify that a true copy of the foregoing document was served upon A. Russell Smith/ Esq./ 159 S. Main Street/ Suite 503/ Akron/ Ohio 44308 by regular U.S. mail, postage prepaid, this day of May, 1987. Je i-fr je y ^ fy '' C a s io iI II I i I .1 I VERIFICATION Sally Henning, being first duly sworn according to law, states that the Answers to the foregoing Interrogatories are true and correct based upon either her own personal knowledge or information supplied to her by others upon whom she reasonably relies. Sally Henning STATE OF OHIO COUNTY OF SUMMIT ) ) SS: ) SWORN TO before me and subscribed in my presence this _____ day of May, 1987. Notary Public t ! I I I J