Document 3Q53nOdDRxrVNqzVMxOXvJeVy

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE HARRY DOUGHERTY and GRACE DOUGHERTY, his wife, et al., Plaintiffs, vs. KEENE CORP., et al., Defendants. DEFENDANT""4ANVILLE CORPORATION ^ J ASBESTOS DISEASE COMPENSATION_FDNBJS RESPONSE TO PLAINTIFFS1 INTERROGATORIES Defendant Manville Corporation Asbestos Disease Compensation Fund (hereafter "the Fund"), by and through its attorneys, PHILLIPS & SNYDER, P.A., hereby submits the following Responses to Plaintiffs' Interrogatories. PRELIMINARY MATTERS The Fund objects to these Interrogatories to the extent that they ask for information relating to the Defendant's involvement in the asbestos industry. The Fund has never been involved in the manufacture, sale or distribution of asbestos or asbestoscontaining products. Nevertheless, the Fund interprets these questions to relate to Manville Corporation, its predecessors, successors or subsidiaries (hereafter "related entities"). The Fund objects to these Interrogatories and Request for Production of Documents to the extent that they call for identification or production of documents entitled to protection as attorney client communication or attorney work product. Defendant reserves the right to amend these answers to the extent that new or different information becomes available. INTERROGATORY NO. 1: Describe in detail, with specificity and particularity each product mined, produced, manufactured or sold by the answering defendant or its predecessors in title or subsidiaries which contained asbestos for each year from 1936 until 1980; and for each such product describe: (a) Its chemical ingredients; WV-21183 (b) State the manner in which it was intended to be used, i.e., in the construction and/or insulation of buildings and/or equipment, etc.; (c) For each ingredient contained therein state: (i) The name or chemical composition of each substance, what harmful effects, if any are known, that it produces in man or mammals and whether it produces its harmful effects through ingestion, inhalation, absorption or a combination of these; (ii) When you determined and/or learned that the substance produced harmful effects and how such effects were produced; (iii) Identify each individual who participated in such determination and/or obtained such knowledge; (iv) Identify each document that refers, reflects or relates to any information pertaining to the properties of each of the ingredients and/or how the harmful effects are produced as well as your determination of those toxic effects and the manner by which they are produced; (v) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied; (vi) Which products or ingredients were mined which were manufactured and which were distributed by answering defendants. RESPONSE: For many decades, Manville Corporation or related entities engaged in the manufacture and sale of asbestos-containing products, as well as the mining, milling and sale of asbestos fiber. The H.W. Johns Company, a predecessor to Manville Corporation, first commenced business in 1858 and began manufacturing asbestos-containing products by at least 1900. Johns-Manville Products Corporation was organized in 1927 and was responsible for the manufacture of asbestos-containing products. Johns-Manville Sales Corporation, organized in 1929, was responsible for the sale of asbestos-containing products. The asbestos used in Manville products was either chrysotile, amosite or crocidolite. The characteristics of each of these fiber types are as follows: 2 FIBER TYPE - CHARACTERISTICS Chrvsotile Much of the chrysotile fiber sold or used by Manville Corporation or related entities were mined in Asbestos, Quebec by a Manville subsidiary, beginning in 1916. Chrysotile is a mineral in the serpentine group. Serpentine minerals are green, greenishyellow or greenish-gray ferromagrtesian hydrous silicate rock forming minerals having greasy or silky luster and a slightly soapy feel. Structural Occurence: In veins associated with serpentine Mineraloaical Association: Principally in altered peridotite adjacent to serpentine; in limestone near contact with basic igneous rocks; sometimes contains small amounts of magnetite Origin; Alteration and metamorphism of basic igneous rocks rich in magnesium silicates Essential Chemical Composition: Hydrous silicate of magnesium Theoretical Formula; 3MgO, 2Si02, 2H20 Theoretical Chemical Composition: MgO: 43.6%, Si02: 43.4%, H20: 13.0% Usual Range of Actual Chemical Composition: MgO: 38.5 - 44.0%, Si02: 38 - 43.5%, H20: 12 - 16%, FeO: 0.3 - 5.5%, Fe203: 0 - 4.5%, A1203: 0.2 - 2.5% Crystal Structure: Fibrous and asbestiform (prismatic) Crystal System: Monoclinic (pseudo-orthorhombic) Color: White, gray, leek green, yellowish Luster: Silky Hardness: 2.5 - 4.0 Specific Gravity: About 2.5 Cleavage: 010 Perfect Optica1 Properties: Biaxial, positive birefrigence, small to moderate, parallel extinction Mean Refractive Index: 1.50 - 1.55 3 Fusibility: Fusible in minute splinters at 6; looses H20 at moderate temperatures Length: Usual maximum 1 1/2 - 3 inches Texture: Very fine and silky; finest of all varities Tensile Strength: High Curliness: Most pronounced Soinnabilitv: Best spinning fiber Hydration (combined asbestos : 10 - 16% H20; most highly hydrated Heat Resistance: Good, but becomes brittle and looses strength Acid Resistance: Solvable in HCL with separation of gel Petrographic: Parallel extinction; low refractive index; positive elongation. Blowpipe: Fusibility - 6; decomposed by HCL (fibers of silica sometimes) Features: Parallel extinction and H,0 content distinguished from tremolite; association with serpentine is characteristic Principal Uses: Finest textile uses; spinning fiber; insulations; paper; asbestos-cement products; shorts and fines Amosite Amosite fibers were imported, primarily from South Africa. Amosite is a ferro-anthophyllite amphibole. Structura1 Occurence: Lamellar, coarsely to finely fibrous and asbestiform Mineraloaical Association: In crystalline schists Origin: Metamorphic and non-ferro-magnesian minerals Essential Chemical Composition: Silicate of iron and magnesium; higher iron content than anthophyllite; may also contain Al, Ca and Na, a little H20 Theoretical Formula: (Fe, Mg)Si02) 1-5% H20 4 Theoretical Chemical Composition: MgO: 5.0%, FeO: 47.7 - 54.5%, Si02: 47.3 - 45.5% Usual Range of Chemical Composition; Si02: 49 - 53%, MgO: 1.0 7.0%, FeO: 34 - 44%, A1203: 2 - 9%, CaO and Na20: 0.5 - 2.5%, H20: 2.0 - 5.0% Crystal Structure: Prismatic lamellar to fibrous Crystal System: Orthorhombic Color: Ash gray, greenish or brownish Luster: Vitreous; somewhat pearly Hardness: 5.5 - 6.0 Specific Gravity: 3.1 - 3.25 Cleavage: 110 perfect Optical Properties: Biaxial, plus and minus extinction parallel Mean Refractive Index: 1.64+/Fusibilitv: Fusible at 6; looses H20 at moderate temperatures Length: Usual maximum 7 inches; range of 2 - 11 inches; longest of all varities Texture: Rather coarse, but somewhat pliable Tensile Strength: Good, but less than chrysotile Curliness: Fair, but generally straight Spinnability: Fair spinnability; inferior to chrysotile Hydration (combined H20): 1.0 - 4.7% Heat Resistance: Good, but becomes brittle and looses strength Acid Resistance: Insoluble Petrographic: Practically same as anthophyilite, except higher refractive index Blowpipe: Difficulty -- fusible, but some water in closed tube Features: Refractive index and specific gravity higher than anthophyilite; high iron content distinguishes from anthophyilite 5 Principal Uses; materials Some uses in textiles; insulations; building Crocidolite Crocidolite fibers were imported, primarily from South Africa. Crocidolite is a monoclinic amphibole. Structural Occurence: Usually fibrous, in iron-stone Mineralogical Association: quartzose schists Iron-rich siliceous argillite in Origin: Regional metamorphism Essential Chemical Composition: Silicate of sodium and iron (some combined water) Theoretical Formula: Na Fe (s'i03)2 . FeSi03; usually with some H20 Theoretical Chemical Composition: Fe203: 22%, FeO: 19.8%, Si02: 49.6%, Na20: 8.6% . Usual Range Of Actual Chemical Composition: Si02: 49 - 53%, Fe203: 17 - 20%, FeO: 13 - 20%, MgO: 0 - 3%, Na,0: 4 - 8.5%, H,0: 2.5 - 4.5% 22 Crystal Structure: Finely fibrous Crystal System: Monoclinic Color: Lavendar, blue, greenish Luster: Silky to dull Hardness: 4 Specific Gravity; 3.2 - 3.3 Cleavage: 110 perfect Optical Properties: Biaxial, plus or minus extinction - inclined Mean Refractive Index: About 1.7 Fusibility: Fuses with intumescence at 3; most readily fusible of all varities Length: Usual maximum 1 1/2 -- 3 inches Texture: Medium fine to coarse; tough 6 Tensile Strength; Highest of all varities Curliness: Fair, not equal to chrysotile Soinnabilitv; Fair spinnability; inferior to chrysotile Hydration (combined ; 2.55 - 4.15% Heat Resistance: Poor; lowest of all varities Acid Resistance: chemicals Qualitatively insoluble; fairly resistant to Petrographic: Strongly pleochroic (deep blue, blue, yellow green) Blowpipe1: Readily fusible at 3; gives strong sodium flame Features: Blue color and low fusibility; distinguished from all other asbestos varieties; high refractive index and high pleochrosim serve to identify Principal Uses: To some extent in textiles; insulations; building materials FIBER GRADING After the natural chrysotile fiber is extracted from the mined ore, it is separated into fiber grade according to size. A former subsidiary of Manville, Johns-Manville Canada, Inc., tested and graded chrysotile asbestos by a method instituted by the Quebec Asbestos Mining Association* which gained worldwide acceptance as a standard for the classification and evaluation of chrysotile fiber. The identification of fiber grades employed the use of a number followed by a letter; i.e.: 3T, 4T, 5R, 6D, or 7M, etc. The number classified the fibers into broad groups with "3" representing the longest fibers, progressing to "7" representing the shortest fibers. The letter was used to more precisely classify fiber length within each numbered group. The letter "A" represented the longest grade progressing to "Z" which represented the shortest grade within each numbered group. The texture was further identified by adding a two digit numerical suffix to the standard grade length designation. The textural numbers started at "SO" meaning very crudy, decreasing to '02" which means very well opened. For example, in the 6D grade length, Manville provided fibers having the following texture differences. ' 7 6030 6D24 6D20 6D12 6004 6 DO 2 very crudy crudy semi-crudy open well open very well open In the case of group seven fiber grades, the textural numbers were used to express the bulk and absorption properties. The high numbers such as "19n and "IS" indicated grades having low bulk and absorption, decreasing to "02" which represented grades having very high bulk and absorption. Several other characteristics were identified which also affect the suitability of asbestos for any given application. The Quebec Asbestos Mining Association, in conjunction with other relevant organizations, adopted a series of test procedures designed to measure these properties. These tests were used regularly to monitor the quality of the grades being produced for specific applications. PRODUCT DIRECTORIES The Fund has in its possession Manville Corporation product directories from 1959 through 1986. These directories provide information relative to various product lines, construction of the product, popular uses, responsible sales division or department, various operating divisions, various plants with their respective products, products with a registered tradename, generic product names and competitive product names. Product names listed in all capital letters in these directories are tradenames. Such directories will be made available for inspection and copying at the records repository maintained by the Trust in Denver, Colorado, at a time convenient to the parties. In addition to the documents which will be specifically identified and produced at that time, there may be additional documents responsive to this Interrogatory among the general collection of documents in the repository. This collection of documents will be made available to Plaintiff for review at a time agreed upon by the parties. Exhibit A attached hereto is a list of asbestos-containing thermal insulation or shipyard products which were produced, manufactured or distributed by Manville Corporation or related entities. This listing includes the product name, product type, fiber type, percent fiber by weight, date manufactured, date labeled and date discontinued. Tradenames are listed in capital letters. 8 PRODUCTS DESCRIPTIONS AND USES SHEETS AND BLOCKS 85% Magnesia - A high temperature insulation, composed of carbonate of magnesia and asbestos fiber, for service up to 600 degrees F. ASBESTOCEL - An inexpensive insulation constructed of alternating layers of plain and corrugated asbestos paper for temperatures up to 300 degrees F. Air-Cell - Very similar to ASBESTOCEL, constructed of alternating layers of plain and corrugated asbestos paper. Asbestos "Navv Brand11 FIRE FELT - A special grade of insulation, particularly adapted for marine work, or wherever a light weight insulation may be required. Asbestos FIRE FELT - Insulating material made from felted and molded asbestos fiber for temperatures up to 1000 degrees F. Asbestos Molded Blocks - Composed of a mass of felt-like asbestos fibers closely cemented together with a non-conducting compound. Asbestos Sponge (Felted. Sectional. Molded) - An insulation made of layers of thin felt, composed of asbestos fiber and particles of finely ground spongy material forming and extremely cellular felt, built up like a book in laminated form, thereby confining a large volume of minute dead air cells in the felt and between the layers; for temperatures up to 700 degrees F. EQUALITY - A material consisting of 50% carbonate of magnesia combined with asbestos and other fire-proof materials. It is especially manufactured to meet government specifications. Flexible MIN-K - A fibrous insulating material designed principally for use on rockets, missiles, and jet aircraft; can withstand high heat and has an extremely low thermal conductivity. High Temperature Insulation - Composed of a refractory material base of high insulating value combined with asbestos fiber and some carbonate of magnesia. MAGNO - consists of 35% carbonate of magnesia combined with asbestos fiber and Other insulating materials. It is particularly adaptable for insulating heating systems and is specified by U.S. and state governments for this purpose. MIN-K 1301 - A molded fibrous insulating material designed principally for use on rockets, missiles, and jet aircraft; can withstand high heat (1300 degrees F) and has an extremely low thermal conductivity. 9 MIN-K 2000 - See MIN-K 1301; can withstand heat to 2000 degrees F. MIN-K 500 - See MIN-K 1301; can withstand heat to 500 degrees F. o SONITE - Made of MIN-K insulation and used by the U.S. Navy as an underwater sound insulation. SUPEREX 1900 - A high temperature insulation for service up to 1900 degrees F made from asbestos fiber, diatomaceous silica, and other insulating materials. SUPEREX 2000 - A high temperature insulation for service up to 2000 degrees F; replacement product for SUPEREX 1900, with asbestos removed by 1973. SUPEREX-M - A high temperature insulation for service up to 1600 degrees F made from asbestos fiber, diatomaceous silica, and other insulating materials; replaced by asbestos free SUPEREX 1600 in 1973. SUPEREX SG - A block of SUPEREX insulation bonded to a fiberglass blanket. Silicated THERMOBESTOS - Dry granular sodium silicate added to THERMOBESTOS. See THERMOBESTOS. Super FIRE FELT - A lighter weight variation of Asbestos FIRE FELT; temperature limit of 700 degrees or 1000 degrees F, depending on construction. ` THERM-O-BESTOS - A waterproofed asbestos material of high insulating value used for billing underground conduit systems designed to house hot lines. THERMOBESTOS - A high temperature insulation, made from lime, diatomaceous silica, and asbestos fiber, for service up to 1200 degrees F. Thermo FIRE FELT - Similar to Asbestos FIRE FELT, except that it has a cellular asbestos structure completely enclosed in the center of the sheet, giving it increased efficiency and resiliency; for temperatures up to 1000 degrees F. VITRIBESTOS - Made of asbestos felts which have been corrugated and built up to form a cellular sheet, then vitrified to make them more resistant to moisture and high temperature. The vitrified product has lower insulating value than untreated products. Used for lining smokestacks and flues, building theater curtains, and wherever a strong, stiff product is required that will resist temperatures up to 800 degrees F. Vitro FIRE FELT - similar to Thermo FIRE FELT except that the cellular asbestos structure is vitrified to increase rigidity. 10 SECTIONAL PIPE INSULATION 85% Magnesia - See 85% Magnesia under SHEETS AND BLOCKS. ANTI-SWEAT -- Made from water-proof insulating paper and wool felt, it prevents condensation from cold water pipes by insulating the pipe from warm air. AQUA Covering - Solid laminations of wool felt one-half inch thick with one layer of asbestos paper. See Wool Felt Sectional Pipe Insulations. ASBESTOCEL - See ASBESTOCEL under SHEETS AND BLOCKS r in this design, the air channels run around the pipe instead of lengthwise, which prevents the circulation of air. Air-Cell - See Air-Cell under SHEETS AND BLOCKS: in this design, the air channels run lengthwise, parallel to the pipe. Asbestos "Naw Brand11 FIRE FELT Covering - See Asbestos "Navy Brand" FIRE FELT under SHEETS AND BLOCKS. Asbestos Air-Chamber Covering - Formed by layers of fire-proof Asbestos Lining Felt, Hair Felt, Asbestos Sheating, and Canvas. An additional layer of Hair Felt and Asbestos Sheating form Double Air Chamber. Asbestos Combination Spiral Pipe Insulation - Consists of a layer of CEILINITE (see under PAPER. FELTS. BLANKETS1 over which is wrapped a layer of asbestos listing. Used on irregular runs of pipe, or where severe vibration is encountered, as an automobile exhaust pipes and on locomotives; temperature limit of 1000 degrees F. Asbestos FIRE FELT Covering - See Asbestos FIRE FELT under SHEETS AND BLOCKS. Asbestos Molded Sectional Covering - See Asbestos Molded Blocks under SHEETS AND BLOCKS. Asbestos Sectional Covering - composed of a fire-proof non conducting lining of asbestos, surrounded by alternate layers of asbestos and non-conducting felt. Asbestos Soonae (Felted, Sectional. Molded^ - See Asbestos Sponge under SHEETS AND BLOCKS. Asbestos and Hair Felt Removeable Covering - A form of Air Chamber Covering composed of standard hair felt with an inner layer of asbestos fiber of equal thickness, the whole enclosed in a strong 11 wrapper or case of wool sheathing and a lining of asbestos sheathing. Asbestos Hair Felt Covering - Consists of layers of Asbestos Hair Felt, composed of long fiber asbestos and cattle hair, built up on the pipe. CHAMPION Sectional Covering - Solid laminations of wool felt threequarters of an inch thick with one layer of asbestos paper. See Wool Felt Sectional Pipe Insulations. EQUALITY - see EQUALITY under SHEETS AND BLOCKS. EUREKA Covering - Made of one-quarter inch asbestos felt on the inside of the section, and the balance (three-quarters of an inch) of alternate layers of asbestos and wool felt. EXPRESS Covering - Solid laminations of wool felt three-quarters of an inch thick with one layer of asbestos paper. See Wool Felt Sectional Pipe Insulations. Fine Corrugated ASBESTOCEL - Similar to ASBESTOCEL, except the corrugations are smaller; however, there are 50% more laminations per inch of thickness and the additional small enclosed air cells provide greater efficiency. High Temperature Insulation - See High Temperature Insulation under SHEETS AND BLOCKS. INDENTED - Made up of several layers of pure indented Asbestos Felt, wire stitched together; the indentations cause air spaces to be formed between the layers, improving insulating efficiency. MAGNO - see MAGNO under SHEETS AND BLOCKS. METAL-ON - THERMOBESTOS pipe insulation with a factory applied jacket of aluminum; joints are sealed with special aluminum "snapstraps" and metal bands. NATIONAL Sectional Covering - Composed of corrugated soft wool felt, lined on the inside and alternated for three layers with asbestos lining felt; an economical covering for use on low pressure steam lines. PERFECTION Sectional Covering - Composed of one-half inch indented wool felt wrapped around one-half inch molded asbestos. STANDARD Sectional Covering - Solid laminations of wool felt one inch thick with an interlining of two layers of asbestos paper. See Wool Felt Sectional Pipe Insulation. SUPEREX 1900 - See SUPEREX 1900 under SHEETS AND BLOCKS. 12 SUPEREX-M - See SUPEREX-M under SHEETS AND BLOCKS. Safety Blow-Off Covering - Protects boiler blow-off pipes against corrosion by hot gases and prevents explosions resulting from sudden changes of temperature when operating boilers. Silicated THERMOBESTOS - See Silicated THERMOBESTOS under SHEETS AND BLOCKS. THERM-O-BESTOS - See THERM-O-BESTOS under SHEETS AND BLOCKS. THERMOBESTOS - See THERMOBESTOS under SHEETS AND BLOCKS. VITRIBESTOS Covering - See VITRIBESTOS under SHEETS AND BLOCKS. Wool Felt Sectional Pipe Insulations - An inexpensive insulation made of wool felt and asbestos paper. See STANDARD, EXPRESS, CHAMPION, and AQUA for more detail. ASBESTOS MILLBOARD ASBESTOS MILLBOARD (All Grades) - Made of asbestos fiber and suitable binders, this is recommended where relatively thin sheets or boards are required for protection against fire, heat, and acid fumes. Used as a fireproof lining for floors, partitions, ceilings, and elevator shafts. Also used in ranges, stoves, grates, etc. Made in various degrees of hardness and temperature resisting properties. BOARD ASBESTOS EBONY - A densely pressed hard sheet of asbestos fiber and binding cements, impregnated with an insulating compound and used for switchboards, controller plates, switch bases, etc. Has high dielectric strength, insulation resistance, strength, and durability. DEKERAN - A mineral glaze surfacing with exceptional abrasion and stain resistance that is completely fireproof. Available on 3/16 Marine Veneer either plain or perforated. Flat Transite - Incombustible asbestos-cement sheets, resistant to corrosion and weather. MARIMET 45 - A calcium silicate structural - insulating board for feeding and conveying nonferrous metals up to 1800 degrees F. MARINITE - A composition of asbestos fiber, diatomaceous silica and lime formed with calcium silicate sheets which have structural strength, fire resistance, and insulating value; used as fire-safe wall partitions in ship construction and as a fireproof base for wood veneers; also used to construct industrial ovens and other insulating enclosures, for handling molten metals, as drying trays 13 in dielectric core drying ovens, for back-up of electrotype printing mats, and for fireproof doors. MARINITE 23 - The MARINITE panel with the best thermal insulating characteristics; recommended where strength and hardness are of secondary importance, in applications where the material is not subjected to direct abuse or where it serves as a core for veneering; the 23 indicates a density of 23 lbs. pcf. MARINITE 30 MARINITE 36 - The MARINITE panel that provides the best combination of structural strength, surface hardness, and insulating value; recommended for most applications; the 36 indicates a density of 36 lbs. pcf. MARINITE 65 - The MARINITE that is recommended where structural strength and surface hardness are of primary importance; the 65 indicates a density of 65 lbs. pcf. MOLTEN METAL MARINITE - A board insulation made of amosite fiber, diatomaceous silica, and an inorganic binder; it is an ideal material for feeding and conveying molten metals up to 1350 degrees F. Also available as heat treated MOLTEN METAL MARINITE. Marine Acoustical Unit - Square sections of perforated Marine Veneer with attached elements of sound-absorbing material; used for acoustical treatment in ship construction. Marine Veneer - Strong, flexible, fire-resistant sheets made of asbestos and cement; used for low-maintenance ceilings and wall facings on ships. Metal Veneered MARINITE PALLITE - Sheet material formed from asbestos fiber and inorganic binder; used in drying operations in ceramic plants. REEFERITE - An incombustible, corrosion-proof panel composed of a solid aluminum core faced on both sides with Marine Veneer. Submarine Bulkhead - Corrugated asbestos cement sheets used as bulkhead piling to control erosion along lakeshores and inland waterways. TRANSITE Acoustical Panel - A panel made of an asbestos-cement facing used in conjunction with a mineral fiber sound absorbing element. TRANSITE Core Plate - Smoothly sanded, hydrothermally cured asbestos-cement board especially compounded to properly support cores during drying or baking; widely used in the manufacture of castings of brass, aluminum, gray, iron malleable iron, and steel. 14 Veneered MARINITE FINISHES AERTITE - An asphalt-asbestos coating for troweling over the outside of boiler walls. INSULKOTE ET - A non water-vapor barrier, non-burning, weather proof coating for use over insulation where "breathing" is required. INSULKOTE SG AND ST - Weatherproofing and vapor barrier coatings for insulations on refrigerated equipment. INSULKOTE SG is an excellent anti-corrosion coating. PAPER. FELT. BLANKETS #50 Asbestos Weatherproofing Felt - An asphalt-saturated asbestos felt used in waterproofing asphalt for work below grade. #12 Asbestos Paper Tape - Paper tape made from 12 lb. asbestos paper, it is felted, composed of asbestos fiber and binder. It comes in 2 or 3 inch rolls, and is used to wrap duct joints and in many other applications. 15A Asbestos Jacket - A lightweight asphalt-saturated asbestos finishing felt. 45A Asbestos Jacket - An asphalt saturated asbestos felt with a sand finish; a heavy, long life weatherproofing jacket. 7700 Coated Asbestos Jacket - An asphalt-saturated and coated asbestos felt with a smooth outer surface, it is designed to be given a field coating of asphalt. ARMATURO Asbestos Paper - An asbestos paper integrally reinforced with cotton-scrim cloth; used as an insulation in electrical equipment; temperature limit is 500 degrees F. ARP-40 - Asbestos reinforced plastic used as the facing of MINKLAD INTERLOK and in other aircraft and missile applications; when furnished in tape form, called ARP Tacky Tape. ASBESTOCEL Paper - A corrugated paper formed of successive corrugations of an asbestos felt, held together by an asbestos fireproof backing. Asbestos Corded Sheathing - Consists of pure Asbestos Sheathing, to the surface of which are attached loosely twisted rolls of asbestos, forming a very strong fabric about one-quarter of an inch thick. It is particularly valuable as a fire-proof, non-conductive 15 covering for furnaces, furnace pipes, and other fire-heated surfaces, etc. Asbestos FIRE FELT - See Asbestos FIRE FELT under SHEETS AND BLOCKS. Asbestos FIRETARD - A f ire-retajrdant weatherproof jacket consisting of a sheet of asphalt-saturated asbestos felt cemented to a sheet of unsaturated asbestos felt; used on outdoor pipe insulation and small diameter vessels wherever fire hazards are present. Asbestos Felt - Composed entirely of pure asbestos, is fireproof, and possesses three times the strength of hair felt. Asbestos Jelly Rolls - Made of Asbestos Roll FIRE FELT, these are used to pack boiler and still-setting expansion joints. Asbestos Lining Felt - This material consists of pure Asbestos Sheathing, to one side of which is attached a layer of "flocked" or felted asbestos, forming a strictly fireproof, non-conducting lining for hair felt, protecting it from the injurious effects of heat when applied to steam pipes, boilers, etc. Asbestos Lining and Deadening Felt - Same as Asbestos Lining Felt; also used for lining floors, walls, etc., to deaden sound. Asbestos Locomotive Lagging - Composed of large strands or twisted rolls of pure asbestos, woven in a fine asbestos warp, and lined with a pure Asbestos Sheathing, forming a strong, matted, felt like material of great non-conducting power. Asbestos Pipe Blanket - Made of asbestos cloth, filled with asbestos fiber and quilted; for pipes, fittings and flanges where inspection is made frequently and necessitates removal of the insulation; the asbestos cloth used is special to suit each temperature and service condition up to 950 degrees F. Asbestos Roll FIRE FELT - See Asbestos FIRE FELT under SHEETS AND BLOCKS. Asbestos Sheathing Asbestos Sponge Felt - A thin felt, composed of asbestos fiber and particles of finely ground spongy material forming an extremely cellular felt for temperatures up to 700 degrees F. Asbestos Sponge Hair Felt - Composed of asbestos sponge and hair, it forms a good covering for steam pipes, boilers, mining purposes, etc.; it is very elastic, and owing to the large proportion of asbestos, is not liable to injury from steam heat. 16 Asbestos Turbine Blanket - Consists of high temperature felted mineral insulation fully enclosed in a wire inserted asbestos cloth for temperature exposure to 850 degrees F, or a stainless steel mesh for temperatures from 850 degrees F to 1100 degrees F. Asbestos and Hair Woven Felt - Similar to Asbestos Locomotive Lagging, but contains 25% hair; it is very elastic and practically fire-proof. CEILINITE - Made from Asbestos Roll FIRE FELT, reinforced on one side with asbestos cloth; used as an inter-lining, for fireproofing electrical apparatus such as switch boxes, and for similar purposes requiring a strong, flexible, fireproof felt; for temperatures up to 1000 degrees F. Commercial Grade Asbestos Paper - A standard asbestos paper varying in weight from 6 to 32 lbs. per 100 sq. ft. and in thicknesses from .015 to .0625 inches. Asbestos paper is formed from asbestos fiber and a suitable binder and used where an insulating material of minimum thickness is required. D.C. FLEXSTONE - A high quality asbestos felt, saturated and coated with asphalt on both sides; used to make weather-proof jackets for insulated pipe lines located outdoors. DOUBLEX Asbestos Paper - A paper made from asbestos and a lime silicate binder used by neon sign manufacturers to make templates or patterns; also used for pouring gates in foundries. Engineers Insulating Tape FIBROID Asbestos Paper - Used as an electrical insulation; made from asbestos paper and a binder, it can withstand temperatures up to 500 degrees F. High Temperature Flexible MIN-K Blankets - See Flexible MIN-K under SHEETS AND BLOCKS. High Strength FIBROID Asbestos Paper - See FIBROID Asbestos Paper; can be used for service up to 600 degrees F. Long Fiber Asbestos Paper - Made with high grade long asbestos fiber; for use as a thermal insulation, gasketing, or as a base sheet for saturating; minimum fiber content 88%. MICROBESTOS - A high grade chrysotile asbestos paper which can be readily saturated with various resins to provide a very uniform prepreg reinforcing material; for use in the manufacture of reinforced plastic products and in the oblative field. MIN-KLAD - A molded combination of MIN-K and asbestos reinforced plastic faces. 17 NIAGRITE - A felted asbestos tape for wrapping around electrical cables as fireproofing; usually reinforced with burlap or asbestos cloth. Non-Burn Asbestos Paper - A medium length fiber paper with high fiber content; suitable for continuous service at 400 degrees F. Standard Flexible MIN-K Blankets - See Flexible MIN-K under SHEETS AND BLOCKS. Super FIRE FELT - See Super FIRE FELT under SHEETS AND BLOCKS. THERMO FELT - An asbestos hair felt composed of 50% cattle hair and 50% asbestos, with a burlap center; used in steel passenger cars and street cars. THERMOMAT - A nonwoven long fiber asbestos felt saturated with phenolic resin; furnished as a molding compound in sheet or tape form; extremely resistant to high temperatures; used as a rocket motor liner and in other aviation and missile applications. THERMOTAPE - A flexible pipe insulation in strip or roll form made of an asbestos pad in a neoprene coated asbestos cloth jacket; used on locomotives and cars where sectional insulation can't be applied effectively. THERMOWRAP - A pipe insulation made up of a blanket of asbestos fibers held together by asbestos yarns and enclosed in a neoprenecoated asbestos jacket; primarily designed for steam lines on trains; High Temperature THERMOWRAP is designed for use on diesel exhaust lines and in similar high temperature situations. Welding Paper White Surface Asbestos Jacket - A pipe insulation jacket made from asbestos weatherproof felt. SEALING COMPOUNDS Sealing Compounds are plastic, putty-like materials for sealing out (or in) air, dust, moisture, etc. The products and their main sealing uses follow. ALBASEAL - Air conditioners, refrigeration equipment. AQUASEAL - Threaded or jacketed joints. BRANCHITE - Sewer Pipe connections. Body Sealer - Auto, truck, and trailer bodies. 18 DUXSEAL - Wires and cables at duct entrances; general purpose. H-NAVASEAL - Electrical duct apertures aboard ship; a heat (H) resistant, practically incombustible sealer for Navy applications. HF-NAVASEAL - Electrical duct apertures aboard ship; a flame (HF) resistant, practically incombustible sealer applications. Industrial Vent Caulking heat and for Navy NODRSEAL - Refrigeration equipment and general purpose. stove Puttv - Ovens and hot-water heaters where it is not apt to be exposed to intense heat. TRANOSEAL - Oil filled electrical transformers. Type T NODRSEAL - Refrigeration equipment and general purpose. UNISEAL - General purpose. CEMENTS 0352 Cement - General utility short fiber cement, used by the plumbing and steamfitting trade for insulating heating boilers and pipe fittings; temperature limit 1000 degrees F. 300 Cement 301 Cement 302 Cement - An excellent finishing cement made from asbestos fibers and binding materials, it is light in weight and high in insulating value; temperature limit 1000 degrees F. 304 Cement - Insulating cement made from long fiber asbestos for covering surfaces liable to become red hot; temperature limit 1200 degrees F. 319 Semi-Refractorv Cement - A combined insulating and semi refractory cement used to protect block or brick insulation in flues, stacks, etc.; temperature limit 1600 degrees F. 329 Cement - A lagging cement for finishing over sheets and blocks, for insulating large heated surfaces and for irregular surfaces and fittings, where it is impossible to apply either sectional pipe covering or blocks. It is very light, full of confined air, elastic and spongy, and forms an excellent plastic non-conductor. 340 Cement - An insulating and finishing cement lower in covering capacity and price the 302 Cement; temperature limit 1000 degrees F. 19 352 Cement - General utility short fiber cement, used in large quantities by the plumbing and steamfitting trades for insulating heating boilers and pipe fittings; used as a finish over block insulation and in general applications; temperature limit 1000 degrees F. 364 Cement - A medium grade insulating cement; temperature limit 1000 degrees F. 400 Cement - A combination of asbestos and other material of high insulating value, ideal for general use where efficiency, strength, and durability are desired; temperatures limit 700 degrees F. 450 Cement - A mineral wool base insulating cement with excellent adhesion which permits it to be readily applied to surfaces too irregular to insulate with sheets or blocks; adheres to hot or cold surfaces but is not a finishing cement; temperature limit 1200 degrees - 1500 degrees F. 500 Cement - A cement composed of asbestos fiber and expanded mica which combines high covering capacity and heat resistance with good working qualities. Can be used at temperatures up to 1800 degrees F if entire reclaimability is not essential. Completely reclaimable at temperatures up to 1500 degrees F. Useful for irregular surfaces where block insulation is not adaptable, but not ordinarily used for finishing.. 678 Semi-Refractorv Cement - An air-setting, hydraulic cement which is a combination finishing and semi-refractory cement for use as a protective coating over block insulation linings exposed to the action of moving gases in flues, breechings, and stacks. Where erosive action is severe such as in pulverized coal units and particularly in area where the gases change direction sharply, the cement should be protected with temperature resistant metal; temperature limit 1900 degrees F. 85% Magnesia Cement - Composed of the same material as 85% Magnesia sectional and block insulation, it is essentially an insulating and not a finishing cement; temperature limit 600 degrees F. ASBESTILE Cement - A heavy bodied cement of asbestos fibers, asphalt, and other mineral ingredients; specifically designed for sealing flashings with a watertight bond. ASBESTOMENT - A refractory powder which when mixed with water produces an outer coating on the fireproofing of electrical cables; usually used with NIAGRITE. FIBROFIL - A mixture of diatomaceous silica and asbestos fibers; used as an insulating fill for irregular spaces. 20 FIREITE Furnace Cement - An asbestos compound for mounting, sealing, and repairing joints in stoves, boilers, furnaces, heaters, and ranges. Fibrous Adhesive - A strong silicate soda and asbestos fiber cement used for temporary bonding of insulation to brick, concrete, metal, or other surfaces as well as for bonding prefab fittings; temperature limit 500 degrees F. Fil Insul - A resilient fill composed of mineral fibers; used for insulating irregular surfaces. Heat Treating Cement - A ready-mixed refractory cement for use in the heat treating of high carbon steel parts; for temperatures up to 2500 degrees F. LAPTITE Cement - A heavy brushing fibrated cut-back asphaltic cement with a temperature limit of 140 degrees F. Used for sealing the laps of weatherproof insulating jackets. MX-3808 Asbestos Filler Navv 450 Cement - A specially formulated variation of 450 Cement to meet Navy specifications. SUPEREX Cement - The same material as used in SUPEREX sectional and block insulation; used with SUPEREX or THERMO-12 pipe and block insulation for patching, pointing up joints, and covering irregular shapes. SUPEREX Cement for Navv - A specially formulated variation of SUPEREX Cement to meet Navy specifications. THERMOBESTOS Cement - The same material used in THERMOBESTOS sectional and block insulation. THERMOMIX 700. 720. 770. 810 - Insulating cements designed for use in missile engines; these compounds contained a special heat resistant phenolic resin system of the dry type. AWARENESS/KNOWLEDGE Manville Corporation or related entities became aware of the confirmation of a relationship between asbestos exposure and the disease known as asbestosis in workers involved in the mining, milling and manufacturing operations in the early 1930s. This knowledge was acquired from published medical literature which discussed the relationship between asbestos exposure and asbestosis among workers involved in asbestos mining and milling and certain asbestos manufacturing operations, and as a result of claims filed by Manville's employees in 1929 and the early 1930s alleging injury due to exposure to excessive quantities of asbestos. 21 Manville Corporation or related entities first learned of a possible relationship between asbestos exposure and mesothelioma in approximately I960, when Dr. Wagner of South Africa published an article on this topic. Manville Corporation or related entities received a workers' compensation claim which alleged mesothelioma in 1962. Representatives of Manville Corporation or related entities first began to discuss a possible relationship between asbestos exposure and lung cancer in approximately 1943. However, for a number of years, there was no certain confirmation of a causal relationship. In 1955, Dr. Doll of Great Britain published an article on this topic, based on his epidemiological study of asbestos factory workers. Dr. Doll concluded that there was an increased incidence of lung cancer among those occupationally exposed to asbestos. Subsequent research has shown that lung cancer in those occupationally exposed to asbestos occurs primarily in persons who smoke cigarettes. RECORDS REPOSITORY All documents identified in response to this Interrogatory will be produced at the records repository maintained by the Trust in Denver, Colorado. In addition to the documents which will be specifically identified, there may be other responsive documents among the general collection of documents maintained by the Trust at the records repository in Denver, Colorado. All of the non-privileged documents in the possession, custody and control of the Fund which were obtained from the records of Manville Corporation and which relate to the asbestos litigation are located in a records repository in Denver, Colorado. The Fund assumed the management and operation of this repository on November 28, 1988, the date on which the Manville Corporation bankruptcy plan was consummated. The repository was originally set up and managed by Manville Corporation to house the documents which Manville retrieved and produced in previous asbestos litigation. In 1983, pursuant to an order entered by Judge Ira Brown of the Superior Court in the City and County of San Francisco, Manville Corporation was required to produce all non-privileged documents relevant to the coverage litigation which Manville Corporation had commenced against its insurance carriers. That litigation was brought to establish Manville Corporation's right to defense and indemnification for costs incurred in connection with the asbestos litigation. The insurance litigation was ultimately settled for sums in excess of $800 million. In order to comply with Judge Brown's order, Manville Corporation hired numerous paralegals and law clerks and undertook 22 a massive and comprehensive review of the corporate records of the company which existed at various Manville facilities world wide. Manville spent literally millions of dollars to gather and maintain this collection of documents. Similarly, beginning in 1985, Manville Corporation was required to produce the vast majority of these same documents to representatives of the United States Department of Justice, in connection with Manville's actions against the United States. In those cases, Manville Corporation was claiming a right to indemnification or contribution for expenses incurred in the defense of asbestos health cases brought by workers employed in government owned or controlled shipyards. These documents are currently kept at the document repository referred to above. The repository is now maintained and operated by the Trust. Manville Trust Document Categories The repository contains 19,317 boxes and 968 rolls of microfilm, house in two separate warehouses. The larger of the two warehouses contains 15,293 boxes. The smaller warehouse contains 4,024 boxes and the microfilm collection. These documents are grouped in nine categories: 01: Manville plant collection - 10,383 boxes 02: Waukegan plant collection - 4,908 boxes 03: Lompoc plant collection - 149 boxes04: World Headquarters (WHQ) collection - 3,417 boxes 05: Microfilm from Manville WHQ - 492 rolls 06: Microfilm from Manville WHQ - 361 rolls 07: Documents sent by Local Counsel - 385 boxes 08: Microfilm with Redacted Documents - 115 rolls 09: Documents produced in January, 1989 - 73 boxes The Manville Plant collection (01) includes documents from the Manville, NJ plant; the Nashua, NH plant; the Billerica, MA plant; the Savannah, GA plant; the Laurinburg, NC plant; and the Fort Worth, TX plant. It also includes documents sent to the plant for storage from Manville General Headquarters prior to the early 1970s, when the Headquarters offices were located in New York. In addition, this collection includes documents from plants in the eastern United States which were closed prior to the 1980s. The Waukegan Plant collection (02) includes documents from the Waukegan, IL plant and the Oak Brook, IL office. The World Headquarters (WHQ) collection (04) includes documents which were obtained from a number of locations, including: the Denison, TX plant; the Franklin, PA plant; the Green Cove Springs, FL plant; the Jeffrey Mine in Asbestos, Quebec, 23 Canada; the Long Beach, CA plant; the Lompoc, CA plant; the Marrero, LA plant; the Manville offices in Montreal, Quebec, Canada; the Pompano Beach, FL plant; the Pittsburg, CA plant; the Stockton, CA plant; and the Waukegan, IL plant. The WHQ collection also includes documents obtained from the files maintained at the World Headquarters, including: the Asbestos Fiber Division; the Audio-Visual Department; Manville Contract Units; the Corporate Information Center; the Corporate Relations Department; the Engineering Department; the Executive offices; the Fiberglass Division; the Filtration and Minerals Division; the Finance Department; the Health, Safety, and Environment offices; the Holophane Division; the Industrial Products Division; the Labor Relations offices; the Legal Department; the Patent and Licensing offices; the Research and Development offices; Sales Offices; and Worker's Compensation records. Finally, the WHQ collection includes: asbestos health claims filed against Manville; bankruptcy related materials; documents from the historical records kept at Manville Headquarters ("BLevel1'); insurance loss runs and policies; local counsel files; legal department files; and miscellaneous asbestos-related documents. The Microfilm collections (05), (06) also contain documents which were located at World Headquarters. Generally,the same types of documents from the same departments and offices are included. However, at the time of the production in the insurance litigation, these documents were produced on film, usually because the documents were in active files which needed to be maintained for normal operations of the company. Records from the following collections were included in these microfilm collections: patents and licensing department; the Research and Development offices; the Lompoc plant; the Health, Safety, and Environment offices; and the records from the Englewood Cliffs, NJ sales offices; insurance department files; insurance policies; industrial hygiene surveys; administrative bulletins; asbestos medical articles; asbestos health depositions; asbestos health files; Manville Corporation general ledgers from 1919 to 1952; and growth plans from 1971 to 1980. In addition, some document collections produced to insurance companies are also located on film in these collections. The Local Counsel Boxes (07) collection includes documents from Heller, Ehrman, White & McAuliffe in California; Freeborn & Peters in Illinois; and Budd, Larner, Kent, Gross, Picillo & Rosenbaum in New Jersey. The Microfilm collection with the redacted documents (08) contains documents from many locations previously mentioned. However, privileged portions of the documents have been redacted, and the redacted copy was filmed, so that the documents could be produced. 24 The Boxes produced in January, 1989 (09) are documents which had originally been classified as privileged. All privileged documents were reviewed again in 1988 and 1989, and the documents in the 09 collection were determined to be producible. Box Index A Box Index for the repository is provided to reviewers. It took six paralegals three months to index the boxes. The microfilm took an additional three months to index. The finished indices were then spot-checked for accuracy by a supervising paralegal with five years experience in the asbestos litigation. The form used to prepare the index was reviewed in advance by Selected Counsel for the Beneficiaries, a group of three plaintiff's attorneys appointed by the Trust's Board of Trustees to represent the Asbestos Litigation Group. Any changes suggested by these attorneys were incorporated into the form. The index consists of 20 subject categories, 12 document types, and 12 time periods ranging from pre-1930 to post 1985, in 5-year increments. Each box and microfilm roll is indexed individually. A box may contain more than one type of document, subject area, or time period. The Box Index allows reviewers to: 1) establish priorities for their searches; and 2) eliminate large numbers of boxes with irrelevant documents. For example, many boxes contain nothing but sales invoices or payroll records. A reviewer interested in documents relating to knowledge of asbestos health hazards would be able to eliminate those boxes from his or her search on the basis of the Box Index alone. Reviewers may order a copy of the index so that they can identify the boxes which they wish to review prior to their arrival at the repository. Alternatively, the Fund will provide reviewers with a printout of all the information contained in the index. Finally, the Fund will conduct computer searches of the data base for reviewers who identify the categories in which they are interested. Review Procedures The repository is open to all parties involved in the asbestos litigation. An informational packet on the repository is provided to all parties who express an interest in the collection. It contains information regarding the hours of operation, rules regarding reviews, and procedures for scheduling visits to the repository. Generally speaking, the Fund has been able to accommodate the schedules of persons wishing to conduct a review, and access is often provided with less than one week's notice. 25 In addition to the documents specifically identified, there may be other documents responsive to this interrogatory among the general collection of documents at the records repository. If any, this collection of documents will be made available to plaintiff for review. INTERROGATORY NO. 2: If any product identified in answer to Interrogatory No. l and was produced, manufactured and/or sold under a trade name, identify that trade name(s) and state the time period that each such product was sold under such trade name. RESPONSE: The Manville Corporation product directories identified in response to Interrogatory No. 1 indicate those products with a registered tradename. Such directories will be made available for inspection and copying at the records repository maintained by the Trust in Denver, Colorado at a time convenient to the parties. Further, all United States file histories are available to the public at the United States Patent and Trademark Office in Arlington, Virginia. INTERROGATORY NO. 3: For each product identified in answer to Interrogatory No. 1, state: (a) The address of each plant where it was manufactured, processed or packaged; (b) Whether you were the sole producer, manufacturer and/or distributor of the product and, if not: (i) The name and address of each other person, firm or other entity engaged in the production, manufacture and/or distribution of the product (including companies which rebranded for the answering defendant); (ii) Whether any other manufacturer produced the product by virtue of a franchise or license from you; (iii) The persons or firms who produced the product for distribution in the United States; (iv) The person or firms who produced the product for distribution in the State of Delaware. 26 (c) All products the answering defendant manufactured, mined or sold which it would relabel for others and the name of any entity such relabeling occurred for, including when, where and with whom defendant dealt with. (d) Any changes answering defendant made in the product or packaging for others of its products and any changes answering defendant requested be made in products or packaging of products others rebranded for the answering defendant; RESPONSE: Manville Corporation or related entities manufactured asbestos-containing products at the following locations: Johns-Manville High Street Billerica, Massachusetts (1940 to 1985) 01862 Johns-Manville Highway 75 Denison, Texas (1957 to 1982) Johns-Manville 2222 W. 5th Street Fort Worth, Texas (1952 to 1985) Johns-Manville P. O. Box 185 Green Cove Springs, Florida (1965 to 1982) Johns-Manville Laurinburg, North Carolina (1965 to 1985) Johns-Manville Lawrence, Massachusetts (1964 to 1974) Johns-Manville 2500 Miguelito Road Lompoc, California (1928 to 1985) Johns-Manville 2420 East 223 Street Long Beach, California 90810 (1938 to 1982) 27 Johns-Manville Los Angeles, California (1929 to 1981) Johns-Manville Main Street Manville, New Jersey (1913 to 1985) 08835 Johns-Manville P. 0. Box 128 Marrero, Louisiana (1947 to 1985) Johns-Manville Nashua, New Hampshire (1907 to 1985) Johns-Manville P. 0. Box 66 North Brunswick, New Jersey (1947 to 1975) Johns-Manville McLean Boulevard at 9th Avenue Patterson, New Jersey (1970 to 1975) Johns-Manville P. 0. Box 591 Pittsburg, California (1926 to 1985) 94565 Johns-Manville Middlefield Road Redwood City, California (1932 to 1955) Johns-Manville Savannah, Georgia (1956 to 1985) Johns-Manville Sperry Road & Airport Way Stockton, California (1957 to 1982) Johns-Manville Tilton, New Hampshire (1948 to 1976) 03275 28 Johns-Manville P. O. Box 55 Waukegan, Illinois 60085 (1922 to 1985) Johns-Manville P. 0. Box 190 Zelienople, Pennsylvania (1943 to 1973) 16163 To the best of Defendant's knowledge, the following products were among those manufactured at each facility listed. Most, but not necessarily all, of these products contained asbestos. Billerica Plant products included: Asbestocite Heat Treated Molten Metal Marinite Imperial Marinite Marimet 45 Marinite Marinite 23 Marinite 30 Marinite 36 Marinite 65 Metal Veneered Marinite Molten Metal Marinite Pallite Reeferite Thermostone Veneered Marinite Denison Plant products included: Transite Pipe Fort Worth Plant products included: Roofing Products Green Cove Springs Plant products included: Transite Pipe Laurinburg Plant products included: Railroad Brake Shoes Rubber Rings Lompoc Plant products included: Diaseal M 29 Fibra-Flo Precoat Sorbo-Cel Sil-O-Cel Hard Finish Cement Sil-O-Cel Plastic Insulating Cement Long Beach Plant products included: Metal On Thermobestos Block Thermobestos Insulating Cement Thermobestos Pipe Covering Transite Pipe Los Angeles Plant products included: 15A Asbestos Jacket 45A Asbestos Jacket Insulkote ET Manville Plant products included: 12 lb. Asbestos Tape 15A Asbestos Jacket 0352 Cement 301 Cement 302 Cement 304 Cement 319 Cement 340 Cement 364 Cement 45A Asbestos Jacket 450 Cement #50 Weatherproofing Felt 500 Cement 678 Semi-Refractory Cement 7700 Coated Asbestos Jacket 85% Magnesia Block 85% Magnesia Cement 85% Magnesia Pipe Covering Ace Panels Aertite Air-Cell Albaseal Anti-Sweat Aqua Covering Armaturo Asbestos Paper Asbestile Cement Asbestocel Paper Asbestos Fire Felt Asbestos Firetard Asbestos Jelly Rolls Asbestos Paper Tape #12 30 Asbestos Pipe Blanket Asbestos Roll Board Asbestos Roll Fire Felt Asbestos Sponge (felted, sectional, molded) Asbestos Turbine Blanket Asphalt Shingles Asbestos Welding Paper Body Sealer Brake Linings Branchtite Ceiling Tiles Ceilinite Champion Sectional Covering Clutch Facings Colorbestos Sheets Colorsil Commercial Grade Asbestos Paper Corrugated Transite Corspan D.C. Flexstone Doublex Asbestos Ppaper Duplex Asbestos Paper Duxseal Engineers Insulating Tape Expansion Strips Express Covering Facespan Fibrofil Cement Fibroid Asbestos Paper Fil Insul Cement Fine Corrugated Asbestocel Flat Transite FIexboard Flexible Min-K H-Navaseal HF Navaseal High Strength Fibroid Asbestos Paper High Temperature Flexible Min-K Blankets Industrial Tile Industrial Vent Caulking Insulkote ET Insulkote SG Insulkote ST Laptite Cement Long Fiber Asbestos Paper Metal On Microbestos Paper Millboard 101 Millboard 102 Millboard 103 Millboard 104 Millboard 105 31 Millboard 106 Millboard 219 Millboard C Millboard XXX Min-K 500 Min-K 1301 Min-K 2000 Min-Klad Moulded Packings MX-3803 Asbestos Filler Navy 450 Cement Niagrite Nodrseal Non-Burn Asbestos Paper Plastiseal F Pre-shrunk Wool Felt Rolled Roofing Roofing Paints and Putties Silicated Thermobestos Block Silicated Thermobestos Pipe Covering Sonite Standard Flexible Min-K Blankets Standard Sectional Covering Stove Putty Superex M Block Superex 1900 Block Superex 2000 Block Superex Cement Superex Cement for Navy Superex M Pipe Covering Superex 1900 Pipe Covering Superex 2000 Pipe Covering Super Fire Felt Thermobestos Block Thermobestos Cement Thermobestos Pipe Covering Thermoflex Thermomat Thermotape Thermowrap Transite Pipe Transoseal Type T Nodrseal Uniseal Vitribestos Welding Paper White Surface Asbestos Jacket Wool Felt Sectional Pipe Insulations Marrero Plant products included: 15A Asbestos Jacket 32 Insulkote ST 7700 Coated Asbestos Jacket Laptite Cement Transite Pipe Nashua Plant products included: Aegan Asbestos Ebony Asbestocite Chalkboard Chemstone Colorceran Colorceran Edge Coating Colored Marine Veneer Colorlith Colorlith Joint Cement Colorthin Dekeran Duplex Asbestos Paper Ebony Electrobestos Fireglaze Stonhenge Flat Transite Flexboard Flexboard "B" Imperial Walls & Beams Marine Acoustical Unit Marine Veneer Marinite 36 Marinite 65 Molded Ebony Molded Electrobestos Molded Unit Ohmstone Pallets & Slip Jackets Perforated Colored Marine Veneer Perforated Fiberboard "S" Perforated Flexboard Perforated Marine Veneer Quadro Steam Cured Transite . Stonehenge Submarine Bulkhead Terraceran Textured Transite Transite Acoustical Panel Transite Core Plates, Pallets and Slip Jackets Transite Core Plate Sheets North Brunswick Plant products included: 33 Spirotallic Gaskets Patterson Plant products included: Die-Formed Rings Gaskets Pittsburgh Plant products included: 0352 Cement #15 Finishing Felt #15 Waterproofing Felt 15A Asbestos Jacket 301 Cement 302 Cement 319 Semi-Refractory Cement 400 Cement 45A Asbestos Jacket 450 Cement 50 Weatherproofing Felt 500 Cement #55 Asbestos Base Felt 678 Semi-Refractory Cement Aertite Coating Asbestile Asbestos Base Flashing Asbestos Roofing Felt Commercial Grade Asbestos Paper D.C. Flexstone Fibroid Asbestos Paper Fibrous Adhesive Flexboard Flexstone Insulkote ET Insulkote SG Insulkote ST ' Laptite Cement Transhield Asbestos Felt Redwood City Plant products included: 85% Magnesia Block 85% Magnesia Pipe Covering Magnesia Plastic Superex Block Superex Cement Superex Pipe Covering Superex Plastic Stockton Plant products included: Transite Pipe 34 Tilton Plant products included: Microbestos Quinorgo Quinterra Quintex Waukegan Plant products included: 0352 Cement 300 Cement 300 E Cement 301 Cement 302 Cement 304 Cement 319 Semi-Refractory Cement 352 Cement 364 Cement 400 Cement 450 Cement 500 Cement 678 Semi-Refractory Cement 85% Magnesia Block 85% Magnesia Cement 85% Magnesia Pipe Covering Aertite Anti-Sweat Aqua Covering Asbestile Cement Asbestoboard Asbestocel Asbestoment Asbestos Fire Felt Asbestos Millboard Asbestos Roll Board Asbestos Sponge (felted, sectional and molded) Asbestos Textile Adhesive Asbestos Welding Paper Champion Sectional Covering Cooling Tower Fill Commercial Grade Asbestos Paper Coublex Asbestos Paper Express Covering Fibroid Asbestos Paper Fibrofil Cement Fibrous Adhesive Fil Insul Cement Fine Corrugated Asbestocel Fireite Furnace Cement Flexboard Indented Sectional Covering 35 Insulkote ET Insulkote SG Insulkote ST Laptite Cement Marine Veneer Millboard 101 Millboard 102 Millboard 103 Millboard 106 Millboard 106B Millboard 106C Millboard 106H Millboard 219 Millboard 766 Millboard Type A Millboard Type c Millboard XXX MX-3808 Asbestos Filler Navy 450 Cement Non-Burn Asbestos Paper Pre-Shrunk Wool Felt Sheet Packing Silicated Thermobestos Block Silicated Thermobestos Pipe Covering Standard Sectional Covering Super Fire Felt Superex 1900 Block Superex 2000 Block Superex M Block Superex SG Block Superex Cement Superex Cement for Navy Superex 1900 Pipe Covering Superex 2000 Pipe Covering Superex M Pipe Covering Superex SG Pipe Covering Thermo Fire Felt Thermobestos Block Thermobestos Cement Thermobestos Pipe Covering Transhield Asbestos Felt Transite Pipe Vitro Fire Felt Welding Paper Wool Felt Sectional Pipe Insulations Zelienople Plant products included: Fireite Furnace Cement Heat Treating Cement 36 REBRANDING After reasonable inquiry and search, the Trust has determined that the following identifies by tradename asbestos products manufactured by other companies which were distributed by Manville Corporation or related entities. Raybestos-Manhattan, Nippon Asbestos of Tokyo and Atlas Asbestos Company manufactured asbestos cloth and asbestos tape marketed under the Johns-Manville logo from approximately 1969 through 1974. Additionally, in 1969, Manville or related entities entered into an agreement with Raybestos-Manhattan, Inc., whereby Manville agreed to market profile calendar brake linings manufactured by Raybestos-Manhattan, Inc. under the style designations HF, SF, and MF. Manville or related entities also sold Corrugated Transite, a roofing/sheet product made by GAF, from 1972 through 1977. The Fund has been unable to identify any other products which were sold by Manville Corporation or related entities but which were produced by other companies. INTERROGATORY NO. 4: For each product identified in answer to Interrogatory No. 1 state: (a) How the product was sold and/or distributed for use in the United States and/or the State of Delaware; (b) (i) Identify all persons, firms or other entities to whom these products were sold for distribution during the period 1936 to 1980; (ii) Identify all entities to which a sale was made from 1936 to 1980 in Delaware, Pennsylvania, New Jersey and Maryland between 1936 and 1980. (c) For each such person, firm or other entity identified in answer to subpart (b) above, state the following: (1) the specific product sold and/or distributed; (2) the quantity (i.e. boxes, linear feet) of the product sold and/or distributed; (3) the dates which these products were sold, shipped and delivered to each entity; 37 (d) Identify each individual who has any knowledge of these sales and/or distribution and state with specificity and particularity the substance of each individual's knowledge; (e) Identify and produce all documents which refer, reflect or relate to all sales and/or distribution of each such product to each such entity identified above. RESPONSE; The Trust is continuing to compile information responsive to this Interrogatory and will supplement as soon as possible. INTERROGATORY NO. 5: For each product identified in answer to Interrogatory No. 1 state whether you, your subsidiaries or predecessors in business engaged in any advertising program to promote the sale of that product and, if so state; (a) The name or description of each advertising media that you have used to promote the product during the period 1936 to 1980; (b) The name of each national magazine or periodical in which you have advertised the product during the period 1936 through 1980; (c) The date of each issue of such magazine or periodical in which such advertisement appeared; (d) The name and address of each newspaper in which it advertised the product during the period 1936 through 1980; (e) The date of each publication of each newspaper in which the advertisement appeared; (f) Identify and produce each document which refers, reflects or pertains to each such advertisement which was published in each such magazine, periodical and/or newspaper; (g) State whether the advertising of the product was handled by an agency and, if so, state the name and address of each advertising agency that handled any portion of the advertising of the product during the period 1936 through 1980. RESPONSE; Manville's corporate advertising function was created and centralized at Manville headquarters in approximately 1970. Prior to that time, advertising was handled by individuals within each operating division. From approximately 1970 until Manville ceased 38 the manufacture of all asbestos-containing products in 1985, the following advertising personnel were concerned directly with industrial insulation advertising and promotion: NAME & POSITION LAST KNOWN ADDRESS F. J. Solon, Jr., formerly Vice President, Advertising & Public Relations 8 Club Lane Littleton, CO 80123 James M. Sullivan, formerly Advertising Manager 1300 No. "L" Street, #195 Lompoc, CA 93436 Robert Feeney, formerly Advertising Manager 5812 South Laurel Place Littleton, CO 80120 Jeremiah J. Attridge, formerly Vice President, Corporate Marketing 23 West Ranch Trail Morrison, CO 80465 Larry Hall, formerly Senior Advertising Manager 4138 Blackhawk Lane Stratford, CT 06497 William P. Gibbons, formerly Director, Corporate Advertising 3479 East Easter Place Littleton, CO 80122 Robert F. Knapp, formerly Senior Vice President, Corporate Marketing & Growth Plan 5191 West Quarles Drive Littleton, CO 80123 Douglas O. Cooke, formerly Manager, Product Publicity (Deceased) In addition, for many years until the 1960s, Manville Corporation or related entities employed the advertising agency of J. Walter Thompson Agency, New York, NY. From the 1960s until 1970, the agency used was Cunningham & Walsh, Inc., 260 Madison Avenue, New York, NY. During 1970 and 1971, Manville employed the agency of Warner, Becking & Fenwick, 866 United Nations Plaza, New York, NY. During 1972 and 1973, all industrial advertising was handled by Broyles, Allebaugh & Davis, Inc., 31 Denver Technological Center, Englewood, Colorado. Manville or related entities may have placed product advertisements in the following publications, periodicals and/or magazines: Actual Specifying Engineer Air Conditioning. Heating & Refrigeration News Air Conditioning Refreiaeration Business 39 American Ceramic Society Bulletin American Society of Naval Engineers Membership Directory Appliance Manufacturing Architecture Record ASHRAE Journal ASNE Dav Program Brick & Clav Record Chemical Engineering Consulting Engineer Contractor Directory of Iron & Steel Engineers Fish Boat Heating/Combustion Eguipment News Heating/Piping/Air Conditioning Hydraulics & Pneumatics Hydrocarbon Processing Indoor Comfort News Industrial Convention Industrial Heating Industry Week Insulation/Circuits Insulation/Circuits Desk Manual Insulation/Circuits Directory Iron Ace Machine Design Marine Catalog & Buyers Guide 40 1976 Marine Directory Marine Engineering Maritime Reporter Materials Engineering Metal Building Review New Products News The Wholesale NHAW Convention Daily NICA Outlook Nuclear News Oil & Gas Journal Plant Engineering Plastics World Power Primary Metals Ed. SMACNA Convention Daily SMACNA of Pennsylvania 1976 Annual Convention & Buyers Guide The Fund has eighty-three boxes from the Manville Corporate Information Center which has advertising literature for many asbestos products. These boxes will be made available to Plaintiff for inspection and copying at the records repository maintained by the Trust in Denver, Colorado. In addition to documents specifically identified, there may be additional documents responsive to this Interrogatory among the general collection of documents in the records repository. See Response to Interrogatory No. 1. INTERROGATORY NO. 6: With regard to each form of asbestos fibers identified in the answer to Interrogatory 1(a) and 1(c), state: (a) Where it was purchased, if it was not purchased where it was obtained; (b) From whom it was purchased; 41 (c) The manner in which it was received, stored and used in the production of the product. RESPONSE; FIBER SOURCE Manville or related entities used asbestos fiber obtained from a number of sources. For products which contained chrysotile, much of the fiber used was obtained from the Jeffrey Mine in Asbestos, Quebec, which was owned and operated by a Canadian subsidiary. Other sources of chrysotile included; Advocate Mines, Ltd.; Bell Asbestos Mines, Ltd.; Calaveras Asbestos, Ltd.; Cassiar Asbestos Corporation, Ltd.; H.K. Porter Company; Marlime Chrysotile Asbestos Corporation, Ltd.; Metate Asbestos Corporation; and Pacific Asbestos Corporation. Crocidolite and amosite fibers were imported into this country, primarily from South Africa. The suppliers included: Antony Gibbs & Company, Ltd.; Asbestos Investment (Pty), Ltd.; John Beith (S.A.) Pty.; Ltd.; British Metal Corporation; Cape Blue Mines (Pty), Ltd.; Central Asbestos Company, Ltd.; C. J. Petro & Company; Colonial Sugar Refining Company, Ltd.; Egnep (Pty), Ltd.; Flintkote Building Products Group; General Mining & Finance Corporation, Ltd.; General Services Administration; Hooker Chemical Company; John Holt & Company; Kurman; Noirca Corporation; North American Asbestos Corporation; Raw Asbestos Distributors; Rhodesian Asbestos, Ltd.; S.A. Asbestos Trading (Pty), - Ltd.; V/0 Soyuspromexport; Special Asbestos Company, Inc.; Turner & Newell, Ltd.; Turners Asbestos Fibres, Ltd.; and Watson, Geach & Company, Inc. FIBER PACKAGING From the time Manville Corporation or related entities first began to sell asbestos fiber in 1916 until the early 1920s, fiber was packed by hand in jute bags. From the 1920s to the 1950s, the fiber was fed into spouts which poured fiber into jute bags. Dimensions of some of the jute bags were as follows: 20" x 36" 23" X 40" 30" X 40" 32" X 40" 25 1/2" X 42" In addition to jute bags, the use of open mouthed, two or three ply kraft paper bags began in 1940. The standard dimensions of the open mouthed bags were 16 1/4" x 7 1/2". 42 In addition to the open-mouthed bags, valve paper bags began to be used in late 1940. This multi-walled bag was constructed of a specified number of plies, then completely sealed except for a sleeved opening on one corner, through which the fiber was injected. Dimensions of the valve bags ranged from 15" x 6 3/4" to 25" x 7 1/4". Manville Corporation or related entities first began to "pressure pack" fiber in the late 1940s. By 1954, all fiber was pressure packed. Jute bags were not used after that time unless they were specifically requested by the customer. The pressure pack method allowed the fiber to be automatically weighed out, dropped into a chamber, and compressed into a block. By 1976, this method was used exclusively. Two standard bags were used in conjunction with the pressure pack method: the open mouthed multi-walled kraft paper bag and the woven polyethylene bag. Pressure packed woven polyethylene hags were constructed of woven polyethylene filaments to give strength and durability. The bags were coated on the outside with a polyethylene film to make it impervious to dust and moisture. The bag was then passed through a bag sealer which automatically applied glue to the flaps and creased the bag together. These woven polyethylene bags may have been "palletized" (stacking and gluing several bags together to form a stable load for mechanical handling). The size of the mold and resulting package dimensions were related to the density of the fiber grade involved. Varied sizes of pressure packers were developed to accommodate ranges of grades and included the following: 11" X 16" X 24" 10" x 16" X 24" 8" X 16" X 24" 7" X 16" x 30" In the 1970s, additional equipment was developed which was capable of producing high-density blocks of fiber measuring 9" x 12" x 16". These blocks had a density of 100 pounds per cubic foot or approximately twice the density of a standard pressure packed bag. Additionally, in 1972, Manville Corporation or related entities completed a program which converted all pressure packaging equipment to produce a standard sized package with dimensions of 9" x 15" x 22 1/2". This new package accommodated fifty kilograms of fiber. Also in the 1970s, a special bag, the unsized kraft paper bag, was developed for use in wet papermaking processes. The bags were constructed with multiple plies of unsized natural kraft paper. When dry they were as sturdy as regular paper bags. However, when wet, the bag had poor strength and readily dispersed in a 43 hydropulper. This allowed the fiber to be introduced into a process without being removed from the bag. INTERROGATORY NO. 7: If you have ever manufactured or had a subsidiary or predecessor in the corporate chain manufacture any insulation products which are commonly used by insulators and which contain asbestos: (a) Describe the process or method of how the products listed in 1 are cut, shaped, mixed and applied on the jobs giving particular reference as to whether or not the materials have to be sawed or cut on the job, blown into confined areas, or mixed with water into a cement or paste; (b) State if there is any way known to the defendant that the products listed below can be used and applied without the worker inhaling any of the asbestos dust or fibers: (1) Asbestos cement; Asbestos Finishes; (2) Asbestos pipe covering; (3) Asbestos bricks or blocks; (4) Asbestos sheeting; (5) Asbestos insulation used to cover extremes of heat as well as cold; (6) Asbestos insulation in loose form which may be blown into homes or buildings; (7) Asbestos in spray form; (8) Asbestos mineral in fiber form or particulate form; or blanket. (9) Asbestos Millboard, rope, gaskets, paper gloves RESPONSE: Manville Corporation or related entities manufactured cements containing asbestos. They were loose materials which were mixed with water by hand or with a hoe or trowel. They were applied in plastic form with a trowel and allowed to dry. Manville Corporation or related entities manufactured asbestos containing pipe coverings. It was sometimes necessary to form, shape or cut the pipe covering with a knife, hand saw or table saw. On the average job, less than ten percent (10%) of the total pipe insulation was cut. The pipe covering was then tied in place with wires or bonds. Manville Corporation or related entities manufactured block insulation for flat, high temperature areas. The flat surface was first covered with cement, wire or expandable metal lathes were 44 then placed on top of the cement to grip the block insulation, which was placed on top of the wire or lathes. The block insulation was, in some cases, cut by drill or saw to smoothly finish and fit the area. Manville Corporation or related entities manufactured asbestos sheeting. These products were usually applied to framing with nails or screws. It was sometimes necessary to cut these board products with a hand or table saw. Manville Corporation or related entities manufactured a wide variety of tapes containing asbestos, which were cut after applying the desired amount to the surface. Manville Corporation or related entities manufactured asbestos containing cloth in a wide selection of textures, grades, weights and thicknesses. These materials were used for awnings, conveyor belts, curtains, dust collection bags and blankets. It was sometimes necessary to cut such cloth with a knife or scissors to fit the appropriate area. Manville Corporation or related entities manufactured asbestos felt, which was used for a wide variety of applications. Generally, asbestos felt was shaped into sections where a unique fitting was required. Therefore, the felt usually had to be cut and molded to fit. Manville Corporation or related entities manufactured asbestos paper which was generally used where insulation of minimum thickness was required for protection against fire, heat or corrosion. The paper was cut or torn to fit. Gaskets or packings manufactured by Manville Corporation or related entities were used as a material placed between joints of mechanical equipment to prevent leakage. Thus, gaskets were furnished in a large number of styles and shapes. Gaskets were usually filled with asbestos paper, cloth or yarn. Alternatively, gaskets were cut from sheet packings and enclosed by a metal jacket. Most gaskets were pre-cut, but in some circumstances, it may have been necessary for an installer to fabricate or shape the gasket on the job site. INHALATION The extent of exposure to asbestos dust depends on the product involved, the general environment, work practices, installation safety procedures, and worker compliance. INTERROGATORY NO. 8: If any piece of equipment which was used at any time to install, cut, shape, etc. products identified in answer to 45 interrogatory no. 1 or 7(b) was invented, developed or first made by answering defendant or any person associated with you or any related company or association, state: (a) When it was invented, developed or made (including changes or improvements to previously available equipment); (b) The identity of each individual who participated therein and describe in detail the extent of his participation; (c) The identity of each document which reflects, refers or relates to any information set forth in answer to this interrogatory; (d) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: See Response to Interrogatory No. 1. INTERROGATORY NO. 9: For each process and/or method identified in answer to Interrogatory No. 7(a) developed or first made by you or any person associated with you or any related company or association, state: (a) When and where it was developed; (b) The identity of each individual who participated therein and describe in detail the extent of his participation; (c) The identity of each document which reflects, refers or relates to any information set forth in answer to this Interrogatory; (d) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: Not applicable. INTERROGATORY NO. 10: For each product identified in the answer to Interrogatory No. 1, describe what, if any, tests were made to determine the safety of said product and: 46 (a) State when and where each such test was made; (b) Describe the results of each such test; (c) Identify each individual who participated therein and describe in detail the extent of his participation; (d) Identify each document which reflects, refers or relates to any information set forth in answer to this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: Manville Corporation or related entities sponsored studies relating to asbestos exposure during mining, milling and manufacturing operations. One such study, which commenced in 1928, involved contributions by Manville for animal research on the effects of asbestos at the Saranac Laboratory of the Trudeau Foundation in upstate New York. The funds were contributed by Manville in the form of premium payments and assessments to the Metropolitan Life Insurance Company, which was the immediate sponsor. The amount of such contributions is not known to nor determinable by Manville. In early 1931, a report of this animal experiment was published by Dr. Leroy U. Gardner (the original director of this project) in Vol. 13, No. 3 (March 31 issue) of the Journal of Industrial Hygiene. This report is entitled "Studies on Experimental Pneumonokoniosis. VI. Inhalation of Asbestos Dust: Its Effect Upon Primary Tuberculosis Infection." In 1929, shortly after the launching of the Saranac studies, Manville and other companies in the asbestos industry asked the Metropolitan Life Insurance Company to determine whether asbestos dust was an occupational hazard and, if so, the nature of the hazard and what could be done to control it. The amounts of Manville's contributions in the form of increased premiums and assessments is not known to nor determinable by Manville. The Industrial Hygiene Division of the Department of Public Health of the McGill University Medical School in Montreal assisted Metropolitan Life in this research. The results were published in 1935 in the Public Health Reports. Vol. 50, No. 1, issued by the U.S. Public Health Service in an article entitled "Effects of the Inhalation of Asbestos Dust on the Lungs of Asbestos Workers" by A. J. Lanza, et al. The cost of publication was paid for by general tax funds. 47 As a result of the aforesaid Metropolitan Life study, additional health research on the effects of prolonged excessive inhalation of asbestos fiber on human being was undertaken at the Saranac Laboratory. The Quebec Asbestos Mining Association ("QAMA"), of which Manville was a principal member, contributed to this new research. A report on this research was delivered at the Seventh Saranac lakes symposium in 1952 and was entitled "Pulmonary Function Studies in Men Exposed for Ten or More Years to Inhalation of Asbestos Fibers" by Fernand Gregoire and George W. Wright. Another report arising out of the industry-sponsored studies at Saranac Laboratory was entitled "Experimental Studies of Asbestosis." It was written by Arthur J. Vorwald, Thomas M. Durkin and Philip C. Pratt, and appeared in the A.M.A. Archives of Industrial Hygiene and Occupational Medicine in January 1951, at Vol. 3, Page 1. In the early 1950s, an animal research project to investigate the reported association between asbestos exposure and lung cancer was begun at Saranac Lake and funded by QAMA. A report entitled "Asbestosis and Pulmonary Cancer" by Arthur J. Vorwald was released in 1952. Another project was an epidemiological study of lung cancer among asbestos miners in the province of Quebec in Canada. This study was also sponsored by QAMA with funding provided by Manville and other member companies. The study was conducted by Daniel C. Braun and T. David Truan for the Industrial Hygiene Foundation of America, Pittsburgh, Pennsylvania. The study was completed in 1957 and published in the June 1958, Vol. 17 issue of the A.M.A. Archives of Industrial Health, at Page 634 and was entitled "An Epidemiological Study of Lung Cancer in Asbestos Miners." Inter-tracheal injection experiments on test animals were conducted by the Industrial Hygiene Foundation of America ( and completed in July 1968) using asbestos fiber taken from a mine of Manville's subsidiary. Manville contributed $1,250 to this study. This study is entitled "The Pulmonary Response to Coalinga Asbestos Dust: A Preliminary Investigation" by Paul Gross, et al. Manville Corporation or related entities contributed the time of its personnel and data to a seven to ten year environmental, clinical and epidemiological study of workers exposed to asbestos which was conducted by the Division of Occupational Health of the United States Public Health Service. Reports relating to and/or based on such study include the following: "Measurement of Asbestos Exposure" by Jeremiah R. Lynch and Howard E. Ayer, published in the Journal of Occupational Medicine. (January 1968); 48 "Research on Health Effects of Asbestos" by Lewis J. Cralley, et al., published in the Journal of Occupational Medicine. (January 1968); "The Role of Trace Metals on Chemical Carcinogenesis-Asbestos Cancers" by J. R. Dixon, et al., unpublished, but presented at the International Congress of Occupational Health, Tokyo, Japan, (September 1969); "Identification and Control of Asbestos Exposures" by Lewis J. Cralley, unpublished, but presented at the International Congress on Occupational Health, Tokyo, Japan (September 1969) ; "Techniques for the Detection, Identification and Analysis of Fibers" by Robert C. Keenan and Jeremiah R. Lynch, published in the American Industrial Hygiene Association Journal. (September-October 1970) . "Fibrous and Mineral Content of Cosmetic Talcum Products" by Lewis J. Cralley, et al., published in the American Industrial Hygiene Association Journal. (July-August 1968). Manville Corporation or related entities funded a study in the amount of $142,400 which was conducted by the Mt. Sinai School of Medicine, City University of New York, entitled "Biological Effects of Modified Inorganic Fibrous Microparticles." This study commenced November 1, 1969 and was completed October 31, 1970. The purpose of the study was to explore the development of new biological test systems for fibrous materials and to determine the effect on biological activity of asbestos fiber which has been coated with a variety of physical and/or chemical substances. A related study funded by Manville Corporation or related entities to the extent of $25,000 produced a report entitled "Asbestos Hemolysis" by R. J. Schnitzer and F. L. Pundsack (then an employee of Manville), which was reported in March 1969 and published in Environmental Research. January 1970. Manville Corporation or related entities have contributed $70,000 to the Industrial Hygiene Foundation of America's "Fibrous Dust Study." The purpose of this program was to investigate factors involved in the pathogenicity of major varieties of asbestos fiber to determine the true nature of ferruginous bodies. Reports related to and/or based on this study include the following: "Proceedings of the Fibrous Dust Seminar" of the Industrial Hygiene Foundation of America, published in its Medical Series Bulletin No. 16-70. (November 22, 1968); 49 "Experimental Asbestosis: The Development of Lung Cancer in Rats with Pulmonary Deposits of Chrysotile Asbestos Dust" by Dr. Paul Gross, et al., published in the Archives of Environmental Health. Vol. 16 (September 1967); "The Pulmonary Response to Fibrous Dusts of Diverse Compositions" by Dr. Paul Gross, et al., published in the American Industrial Hygiene Association Journal. Vol. 31 (March-April 1970); "Ferruginous Bodies* in Guinea Pigs" by John M. G. Davis, et al., published in the Archives of Pathology. Vol. 89 (April 1970); "Pulmonary Ferruginous Bodies" by Dr. Paul Gross, et al., published in the Archives of Pathology. Vol. 85 (May 1968); "Pulmonary Ferruginous Bodies in City Dwellers, A Study of Their Central Fiber" by Dr. Paul Gross, et al., published in the Archives of Environmental Health. Vol. 19 (August 1969); "Ferruginous Bodies in Human Lungs" by Michael D. Utidjian, et al., published in the Archives of Environmental Health. Vol. 17 (September 1968); "Asbestos Bioeffects Research for Industry" by the Industrial Hygiene Foundation of America, Inc., published in its Medical Series. Bulletin No. 11. (1966). QAMA sponsored a study of the health effects of asbestos, if any, on workers in the asbestos cement manufacturing industry in the New Orleans area. The total funding of this study was $200,000, and Manville furnished approximately $142,000 of the sum through QAMA. In addition, Manville contributed the time of its personnel. This study began in 1969 and concentrated on the health status of present and past employees in the plants of Manville and National Gypsum Company in and around New Orleans. Reports of this study include the following: "Asbestosis in Asbestos Cement Workers" by Philip E. Enterline and Hans Weill, presented at LYON Conference. (October 1972); "Radiographic and Physiologic Patterns Among Workers Engaged in Manufacture of Asbestos Cement Product, A Preliminary Report" by Hans Weill, et al., published in the Journal of Occupational Medicine. Vol. 15 (March 1973); "Lung Function Consequences of Dust Exposure in Asbestos Cement Manufacturing Plants" by Hans Weill, et al., published in Archives of Environmental Health. Vol. 30 (February 1975); 50 "Influence of Dose and Fiber Type on Respiratory Malignancy Risk in Asbestos Cement Manufacturing" by Hans Weill, et al., published in American Review of Respiratory Disease. Vol. 120 (1979); "Lung Cancer Risk Associated with Manufacture of AsbestosCement Products" by J. Hughes and H. Weill, published in Biological Effects of Mineral Fibers. Vol. 2, Internationa1 Aaencv for Research on Cancer Scientific Publications No. 30. Lyon (1980); "Immunologic Aberrations in Asbestos Cement Workers: Dissociation from Asbestosis" by R. D. deShazo, et al., published in the Journal of Allergy and Clinical Immunology. Vol. 72, (November 1983); "Mortality of Workers Employed in > Two Asbestos Cement Manufacturing Plants" by Janet M. Hughes, et al., published in the British Journal of Industrial Medicine. Vol. 44 (1987). The Institute of Occupational and Environmental Health of QAMA conducted a study to relate the health status of the asbestosexposed population to a non-exposed population in Canada. This study was under the direction of Dr. J. C. McDonald of McGill University, Montreal, Canada. Reports generated by this study include the following: "Qualitative Aspects of Dust Exposure in the Quebec Asbestos Mining and Milling Industry" by G. W. Gibbs, presented at the Third International Symposium on Inhaled Particles. British Occupational Hygiene Society, London (September 1970); "Epidemiology of Primary Malignant Mesothelial tumors in Canada" by A. D. McDonald, et al., published in CANCER. Vol. 26, No. 4 (October 1970); "Recent Developments in Asbestosis," by Dr. Premysl V. Pelnar, published in Studia Laboris et Salutis. (1970); "Mortality from Lung Cancer and Other Causes in the Chrysotile Asbestos Mines and Mills of Quebec" by Dr. J. Corbett McDonald, et al., published in the Archives of Environmental Health. Vol. 22 (June 1971) ; "Respiratory Symptoms in Chrysotile Asbestos Mine and Mill Workers of Quebec" by Dr. J. Corbett McDonald, et al., published in the Archives of Environmental Health. Vol. 24 (May 1972); "Lung Function in Chrysotile Asbestos Mine and Mill Workers of Quebec" by Dr. Margaret R. Becklake, et al., published in the Archives of Environmental Health. Vol. 24 (June 1972); 51 'The Health of Chrysotile Asbestos Mine and Mill Workers of Quebec" by Dr. J. Corbett McDonald, et al., published in the Archives of Environmental Health. Vol. 28 (February 1974); "Radiological Changes Over Twenty Years in Relation to Chrysotile Exposure in Quebec" by Douglas Liddell et al., and published in Inhaled Particles and Vapours: IV. (1977); "Radiological Findings as Predictors of Mortality in Quebec Asbestos Workers" by F. D. K. Liddell and J. c. McDonald published in the British Journal of Industrial Medicine. Vol. 37 (1980). "Follow-Up Respiratory Measurements in Quebec Chrysotile Asbestos Miners and Millers" by Dr. Margaret R. Becklake, et al., published in the Scandinavian Journal of Work. Environment and Health 8. Supplement 1 (1982) ; "Fibre Exposure and Mortality from Pneumoconiosis, Respiratory and Abdominal Malignancies in Chrysotile Production in Quebec, 1926-75" by F. D. K. Liddell, et al., published in the Annals of the Academy of Medicine of Singapore. Vol. 13, 2nd Supplement (1984). Manville Corporation or related entities also paid for certain studies by Dr. Kenneth W. Smith who was then a full-time employee of said company. Reports of Dr. Smith's studies are as follows: "Asbestosis" printed in The Pneumoconioses. by Kenneth W. Smith (approximately 1963); "Pulmonary Disability in Asbestos Workers" by Kenneth W. Smith printed in the A.M.A. Archives of Industrial Health. Vol. 12 (August 1955); "Trends in the Health of the Asbestos Worker" by Kenneth W. Smith, published in the Annals of New York Academy of Sciences, Vol. 132, Article 1 (December 1965). In January 1977 Manville contributed $250,000 to the Mt. Sinai School of Medicine to fund a mesothelioma treatment study and program. This was a cooperative effort by Manville and the Heat, Frost and Insulators Union with the Union contributing a like amount toward the funding of this Program. The director of the Program was Dr. Irving J. Selikoff. There are no formal asbestos worker epidemiological studies underway by Manville. However, current workers and retirees who have previously worked with asbestos are a part of the overall surveillance program incorporated in MESHIMS (Manville's Environmental Safety and Health Information Management System). 52 Finally, Manville Corporation or related entities released a report on August 2, 1982, which sets forth the findings of a study performed for Manville by Epidemiology Resources, Inc. This report, titled "Projections of Asbestos-Related Disease 19802009," attempts to project the incidence of asbestos-related disease over the next three decades. Manville Corporation or related entities also sponsored research relating to insulators who installed asbestos containing thermal insulation products. In 1968, Manville Corporation or related entities joined in the establishment of the Insulation Industry Hygiene Research Program of Mt. Sinai Hospital. The purposes of this study were: (1) To develop improved methods for minimizing inhalation by insulation workers of dust and fumes encountered in their work; (2) To disseminate knowledge of those improved methods of dust and fume control wherever they may be applied advantageously; and (3) To offer cooperation, advice and assistance toward universal adoption of these methods. The Program Director was Irving J. Selikoff, M.D., Director of the Environmental Sciences Laboratory, Mt. Sinai School of Medicine, New Yotk, New York. Reports were published from time to time and circulated. In 1969-1970 at Manville's Research and Engineering Center at Manville, New Jersey, tests were conducted for the Insulation Industry Hygiene Research Program by Thomas J. Weeks and Allen F. Burns. The report on such tests is entitled "Performance of Dust Respirators against a Fibrous Dust" by Messrs. Weeks and Burns, published in American Industrial Hygiene Association Journal. (May-June 1970). Additionally, an epidemiological study of the biological effects of asbestos dust among the Port of Genoa and LaSpezia Arsenal insulation workers, among others, was conducted by the Clinica del Lavoro, Milano, Italy, under the sponsorship of the Institute of Occupational and Environmental Health, which Institute, in turn, is funded by the Quebec Asbestos Mining Association. Manville Corporation or related entities contributed to the funding of the Quebec Asbestos Mining Association. This study was initiated early in 1968. Reports generated by this study include the following: "Research Project: Epidemiological Study on the Biological Effects of Asbestos Dust at the Balangero Mine and among the Port of Genoa and LaSpezia Arsenal Insulation Workers" by Enrico C. Vigliani (June 16, 1972), Report Clinica del Lavoro "Luigi Devoto." 53 Manville Corporation or related entities, through its membership in the National Insulation Manufacturers Association, has funded, in part, the studies conducted by Dr. Clark Cooper, et al, at the University of California, Berkeley. Reports generated by this study include the following: "Industrial Hygiene for Insulation Workers" by J. Leroy Balzer, published in the Journal of Occupational Medicine. (January 1968); "Environmental Exposures in the Insulation Trade" by J. Leroy Balzer, published in NICA Outlook. (April 1970); "Evaluation and Control of Asbestos Exposures in the Insulating Trade" by Clark W. Cooper and J. Leroy Balzer, Second International Conference Biological Effects of Asbestos. Dresden (1968); "Asbestos in Relation to the type of Fibre and Dose in the Insulation Industry" by W. Clark Cooper and J. Miedema, LYON Conference, (October 1972). The first of the studies under the direction of Dr. Cooper, mentioned above, was published in the Journal of Occupational Medicine. (January 1968) and reported to numerous persons and entities including the Eleventh Annual Western Industrial Health Conference. The second study directed by Dr. Cooper, referred to above, was published in the National Insulation Contractors Association's magazine Outlook during or about 1970. All responsive documents in the possession, custody and control of the Fund will be produced at the records repository in Denver, Colorado at a time agreed upon by the parties. In addition to the documents which will be specifically identified and produced at that time, there may be other responsive documents located within the general document collection at the repository. See answer to Interrogatory No. l. INTERROGATORY NO. 11: For each label, brochure, or other written material describing or relating to the use of each product identified in answer to Interrogatory No. 1, produced by you or any person associated with you or any related company or association: (a) Describe its contents; (b) State when, where, how, and to whom it was distributed; (c) State the manner in which it was placed on or in the product container or whether it was separate from the product 54 container, or whether it was separate from the product or container; (d) State whether any written, printed or graphic matter was present to warn of any harmful ingredient it might contain. If so, state: (i) Whether a signal word, i.e. "danger", "warning" or "caution" was present; (ii) Whether the signal word was printed in boldface, capital letters or different colored inks. Which? hazard; (iii) The wording of the statements describing any (iv) The wording of all directions and/or instructions pertaining to any method of use to avoid any danger resulting from the toxic ingredient; (v) List the instructions provided for each product's use. (e) Identify each individual who participated in the writing of the label, brochure or other written materials and describe in detail the extent of his participation; (f) Identify each document which reflects, refers or relates to the information contained on the labels, brochures, or other written materials and/or the decision to include such information (if there are multiple documents, list any index of the documents and how and where stored); (g) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: Manville Corporation or related entities has, on a continuing basis, furnished customers information as to the proper use and application of its insulating products and has directly or indirectly advised industrial insulation contractors to utilize ventilation equipment, such as respirators, at the sites where finished insulation products were being worked with and applied. Those respirators which have been recommended are approved either by the Bureau of Mines or later by NIOSH for use as protection against pneumoconiosis-producing dusts. Additionally, Thomas J. Weeks and Allan F. Burns conducted tests on respirators at Manville's Research & Development Center 55 at Manville, NJ. The report on such tests was entitled "Performance of Dust Respirators Against a Fibrous Dust." A study by McGill University entitled "Evaluation of Dust Respirators" was done for Manville in November 1971. Manville Corporation or related entities also affixed caution instructions to products regarding the handling of these products. In addition, Manville's product literature contained recommendations regarding respirator usage and utilization of adequate dust collection systems when fabricating, handling and applying certain asbestos containing materials. Manville also distributed to customers copies of the following booklet providing instructions designed to reduce health and safety risks in the fabrication, handling and application of asbestos products: "Recommended Health Safety Practices for Handling and Applying Thermal Insulation Products Containing Asbestos" (1968). Manville Corporation or related entities participated in, and contributed to, the Health and Safety Educational Program of the National Insulation Manufacturers Association (NIMA) . This Program was designed to educate the insulation contractors' industry with respect to the health aspects of fibrous materials through regional meetings of insulation contractors' associations and to aid the contractors in minimizing or eliminating the inhalation of, among other things, asbestos fibers by those working with and/or installing and/or applying asbestos containing products. In 1967, and again in 1968, programs were presented at the regional meetings of industrial insulation contractors. Approximately 400 industrial insulation contractors attended each year. These programs included a verbal review (of approximately three hours' duration) of the biological effects of fibrous materials, the threshold limit value of fibrous materials, methods for evaluating concentrations of dust, and engineering and methodchange recommendations to assist the contractors in dust abatement and environmental control. In addition to the verbal presentations, booklets were prepared by NIMA, largely through Manville's participation and efforts. The booklet entitled "Recommended Safe Practices for Handling and Applying Thermal Insulation Products Containing Asbestos," printed May 1, 1968, described above, was written by members of the NIMA Education and Information Committee. The Chairman of the Committee was Clifford L. Sheckler, who, at that time, was also Manager, Accident Prevention and Health Administration of Manville. Other members of the Committee included John Vyverberg, Owens-Corning Fiberglass Corporation; Harry Mesler, Ruberoid Company; Leon Horowitz, Certain-Teed 56 Corporation; and Jack Barnhart, Executive Secretary of NIMA. The aforesaid booklet was produced and circulated during the 1968 meetings. Also, subsequent to the meetings with the contractors, considerable work was done in conjunction with environmental control, especially in the area of fixed machinery and equipment. In addition, over the past several years prior to Manville's discontinuing the manufacture of asbestos containing products, there were many oral presentations and meetings at the plant level concerning safety practices related to asbestos exposure. Manville Corporation or related entities cooperated with the Asbestos Information Association in the production of the following booklets: "Recommended Work Practices - Molding and Fabrication of Asbestos-Containing Plastic Products" "Recommended Work Practices - Fabrication and Use of Asbestos Friction Materials" "Recommended Work Practices - Fabrication and Use of Asbestos Paper Products" "Recommended Work Practices - Shop and Field Fabrication of Asbestos Sheet Products" "Recommended Work Practices - Use and Handling of Asbestos Textile Products" Additionally, Manville Corporation or related entities participated in 1971 through the Occupational Health and Safety Committee of the National Insulation Contractors Association in the preparation of a booklet entitled "Safety Reminders." Manville has distributed the following: A booklet entitled "What You Should Know About Asbestos and Health" published by Johns-Manville Corporation in January 1975. This booklet was distributed to all employees at all locations using asbestos fiber or handling products containing asbestos fiber. A booklet entitled "What Every Employee Should Know About Asbestos" published by Johns-Manville Corporation in 1973. This booklet was distributed to all employees at all locations using asbestos fiber or handling products containing asbestos fiber. A pamphlet entitled "Recommended Safety Practices for Handling Asbestos Fiber" published Johns-Manville Corporation in November 1973. This booklet was distributed to all employees 57 at all locations using asbestos fiber or handling products containing asbestos fiber. An employee notification form entitled "Dear Johns-Manville Employee" published by Johns-Manville Sales Corporation. This was inserted in paychecks of all employees at all JohnsManville Sales Corporation contract units beginning in 1970. A pamphlet entitled "Safe Work Manual" published by JohnsManville Corporation in 1971. A booklet entitled "Before You Begin" published by JohnsManville Corporation in 1976 and designed to be given to prospective employees before beginning work in a asbestos using operation. A booklet entitled "Questions and Answers Concerning Asbestos" published by Johns-Manville in 1982. In 1976, Manville began a Catalog of Occupational/ Environmental Health and Safety Programs as listed below. All the publications, audio-visual programs and other material listed in this catalog were made available to Manville customers and public interest groups as well as to all Manville personnel. A pamphlet entitled "Occupational Health Guide - Asbestos" published by Johns-Manville in 1976. This guide was designed as a reference for supervisory personnel. A 25-minute slide/tape presentation on industrial hygiene programs at Manville. A 20-minute slide-tape program on health aspects of working with asbestos. A 25-minute motion picture on occupational health risks associated with asbestos fiber. A newspaper entitled "The Asbestos Report" published by Manville in 1976. In 1980, Manville published the 1980-81 edition of the Health, Safety & Environment Catalog which, in addition to the above, included: "A Study of the Problem of Asbestos in Water" which was a reprint of a report by the American Water Works Association Research Foundation. This report was the result of intensive study and literature search and covered all aspects of the use and safety of asbestos-cement pipe materials. 58 "Asbestos Facts" published by Johns-Manville Corporation, was a series of one-page fact sheets covering various aspects of the asbestos and health issue. "Asbestos Minerals in Modern Technology" published by JohnsManville Corporation, was a comprehensive review of mineralogy. "Does Asbestos-Cement Pipe Pose a Health Hazard?" This reprint of an article in California Building & Engineer on health questions regarding asbestos-cement pipe concluded that such pipe does not pose a health hazard. "Dust Control Techniques in the Asbestos Industry" published by Johns-Manville Corporation, summarized engineering efforts at Manville to control the emission of asbestos in mining, milling and manufacturing operations. "The Asbestos Issue: A Matter of Principle" published by Johns-Manville Corporation in 1979, reported on issues related to asbestos health concerns and covered research efforts, Manville health programs and actions. "Today: Special Asbestos Update," published by Johns-Manville Corporation, covered asbestos policy, benefits and applications, types of diseases and groups affected. Over the years Manville has produced, published or distributed for use by employees a number of booklets which addressed safety and health issues in Manville operations generally. Many of these booklets addressed safe work practices to minimize exposure to dust. PRODUCT LABELING Manville placed warning labels on the packaging of its industrial thermal insulation products containing asbestos which might release dust upon installation. These labels and dates of use are as follows: 1964 to 1970 CAUTION THIS PRODUCT CONTAINS ASBESTOS FIBER. INHALATION OF ASBESTOS IN EXCESSIVE QUANTITIES OVER LONG PERIODS OF TIME MAY BE HARMFUL. IF DUST IS CREATED WHEN THIS PRODUCT IS HANDLED, AVOID BREATHING THE DUST. 59 IF ADEQUATE VENTILATION CONTROL IS NOT POSSIBLE, WEAR RESPIRATORS APPROVED BY THE U.S. BUREAU OF MINES FOR PNEUMOCONIOSIS- PRODUCING DUSTS. 1970 to 1972 CAUTION THIS PRODUCT CONTAINS ASBESTOS FIBER. AVOID BREATHING THE DUST. INHALATION OF ASBESTOS IN EXCESSIVE QUANTITIES OVER LONG PERIODS OF TIME MAY BE HARMFUL. IF DUST IS CREATED WHEN THIS PRODUCT IS HANDLED, USE PROPER PROTECTION. IF PROPER DUST CONTROL CANNOT BE PROVIDED, RESPIRATORS APPROVED BY THE U.S. BUREAU OF MINES FOR PROTECTION AGAINST THE PNEUMOCONIOSIS- PRODUCING DUSTS SHOULD BE WORN. 1972 to 1978 1978 to 1985 CAUTION CONTAINS ASBESTOS FIBER AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM CAUTION CONTAINS ASBESTOS FIBERS AVOID BREATHING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM SMOKING GREATLY INCREASES THE RISK OF SERIOUS BODILY HARM Manville began using such warning notices because in 1964 it was reported by a member of the medical profession that there might exist a risk to some persons who installed industrial insulation 60 products containing asbestos, in that inhalation of excessive quantities of asbestos fibers over prolonged periods of time under certain conditions might create a risk of contracting asbestosis to some persons. The label in use from 1972 to 1978 was prescribed by the United States Department of Labor, Occupational Safety and Health Administration (OSHA) pursuant to 29 C.F.R., Sec. 1910.1001, such regulation being promulgated by OSHA in 1972. This label was revised by Manville to include a no-smoking warning, implementation of which commenced in November 1978. In addition, product literature was available from sales personnel. Manville placed warning notices on the packaging of its asbestos fiber. The warning labels and the dates of use are as follows: 1969 to 1972 CAUTION THIS BAG CONTAINS ASBESTOS FIBER. PERSONS EXPOSED TO THIS MATERIAL SHOULD USE ADEQUATE PROTECTIVE DEVICES AS INHALATION OF THIS MATERIAL OVER LONG PERIODS MAY BE HARMFUL. 1972 to 1978 CAUTION CONTAINS ASBESTOS FIBER AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM 1978 to 1983 CAUTION CONTAINS ASBESTOS FIBER AVOID CREATING DUST BREATHING ASBESTOS MAY CAUSE SERIOUS BODILY HARM SMOKING GREATLY INCREASES THE RISK OF SERIOUS BODILY HARM 61 Use of warning labels commenced during 1969. The label in use from 1972 to 1978 was prescribed by the United States Department of Labor, Occupational Safety and Health Administration (OSHA) pursuant to 29 C.F.R., Sec. 1910.1001, such regulation being promulgated by OSHA in 1972. This label was revised by Manville to include a no-smoking warning, implementation of which commenced in November 1978. Manville also placed this warning on all bags containing asbestos fiber in five additional languages; i.e.: French, Dutch, German, Spanish and Japanese. Additional language may have been used from time to time. In addition, sales and service personnel may have, in the ordinary course of business, communicated information to those using products manufactured by Manville or employees installing such products as to current threshold limit values. The selection of the wording of the text of the warning labels was made by a group of individuals representing the following departments at Manville: Environmental Control, Employee Relations, Executive, Legal and Product Marketing. The 1972 change in labeling was mandated by the federal government under the Occupational Safety and Health Act of 1970 and the standard promulgated thereunder for exposure to asbestos. Beginning in the fall of 1974, all corporate labeling activities were within the jurisdiction of the Corporate Labeling Committee. Chairman of the Corporate Labeling Committee was Paul Kotin, M.D., Senior Vice President of Johns-Manville Corporation, Health, Safety and Environment Department, until his retirement in September, 1981. On information and belief, the labeling of products at Manville is currently the responsibility of each Product Manager in conjunction with the Corporate Labeling Committee, which consists of representatives from the operating groups, Legal Department and Health Safety and Environment Department. The following individuals have also been involved in the labeling of Manville Products: Herbert M. Ball (Deceased) William P. S. Breese 255 Brookside Court Knollwood, CO 80302 Edmund M. Fenner (Deceased) Hugh M. Jackson 5205 Sky Trail 62 Littleton, CO 80123 J. B Jobe 2800 S. University, #64 Denver, CO 80210 J. P. Leineweber (Deceased) Irving J. Pedley 10015 Royal Oak Road Sun City, AZ 85351 William B. Reitze 10870 Park Ridge Road Littleton, CO 80123 Clifford L. Sheckler (Deceased) Kenneth W. Smith, M.D. (Deceased) See Response to Interrogatory No. 1. INTERROGATORY NO. 12: For each product identified in answer to Interrogatory No. 1 state whether warnings of any harmful or potentially harmful effects of the product were printed on the cartons or packing cases in which individual containers were packed and, if so: (a) State the printed warning's contents; (b) State when the warning was used; (c) Describe the manner in which it was place on or in the product container; (d) Identify each individual who participated in writing of the label or brochure and describe in detail the extent of his participation; (e) Identify each document which reflects, refers or relates to the information contained on the cartons or packing cases and the decision to include that information; (f) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. 63 RESPONSE: When applicable, Manville Corporation or related entities complied with the labeling regulations promulgated by the United States Department of Labor, Occupation Safety and Health Administration (OSHA). Labels on asbestos containing products manufactured by Manville Corporation or related entities were generally located on the packaging material. However, the location of label also depended on the specific type of product involved. Asbestos containing pipe covering and block insulation, shipped in cardboard cartons, respectively contained a label on the side panel of each carton and on the top of each carton. Asbestos containing board products had labels stamped on every sheet or a label stamped on every five sheets, depending upon the product. Asbestos cements, shipped in multi-ply kraft paper bags and heavy duty polyethylene bags, contained a label on the back panel of each bag. Asbestos cloth, shipped in tubes, contained a label on the exterior of each tube. Asbestos containing millboard products, shipped in corrugated cardboard cartons, had a label located on the top side of the carton. See also Response to Interrogatory No. 11. INTERROGATORY NO. 13: With regard to the production, distribution, and/or sale of each product identified in answer to Interrogatory No. 1 state whether you have ever been accused of violating any of the provisions of the Federal Labeling of Hazardous Substances Act, OSHA (P.L. 91-596, 29 U.S.C. Section 651 et seq and regulations promulgated thereunder or NIOSH and its regulations and, if so, state: (a) The date of each indictment, information that accused you of such violation; complaint or (b) The court in which the proceedings were instituted; (c) The plea you entered; (d) The verdict and/or judgment in each such case; (e) The date set for trial of any pending case; (f) Identify each document which reflects, refers or relates to information pertaining to such accusation; (g) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. 64 RESPONSE; The Fund has never been accused of violating any of the provisions of the Federal Hazardous Substances Act with regard to labeling. The Fund does not have access to information which would allow it to determine whether Manville Corporation or related entities was in violation of this Act. INTERROGATORY NO. 14; For each product identified in answer to Interrogatory No. 1, state whether you contend it is a "hazardous substance" as defined in 15 United States Code, Section 1261(f) and, if so, state with specificity and particularity the facts which you rely on to support that contention. RESPONSE; Defendant objects to this Interrogatory on the ground that it calls for a legal conclusion. Without waiver of or prejudice to this objection, the Trust is continuing to compile information responsive to this request and will supplement as soon as possible. INTERROGATORY NO. 15; With regard to each product identified in answer to Interrogatory No. 1 state whether any quantity of that product has ever been seized by any agency of any government because of its containing a toxic ingredient and not having a proper label or required instructions for use; and if so; (a) State the date of each such occurrence; (b) State the name or description of the violations of which you were accused; (c) State the court in which the action was filed; (d) Describe the judgment that was rendered; (e) pending case; State the date that has been set for trial of any (f) Identify each document which reflects, refers or relates to information pertaining to such seizure; (g) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. 65 RESPONSE; To the best of the Fund's knowledge, no. INTERROGATORY NO. 16: State what action and when it was undertaken, if any, you have taken since 1935 to reduce or eliminate any risk of occupational disease or personal injury to those using your asbestos containing products which arises from the inhalation of dust and fibers. RESPONSE: See Response to Interrogatory Nos. 10 and 11. INTERROGATORY NO. 17: Describe in full and complete detail each of the activities which you have undertaken with the intention of warning the public of the effects of any product identified in answer to Interrogatory No. 1 as to the health of the user or general public and give the inclusive dates of each such activity, and: (a) Identify each individual who participated therein and describe the nature of his participation; (b) Identify each document which reflects, refers or relates to information pertaining to such warning; (c) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: See Response to Interrogatory Nos. 10 and 11. INTERROGATORY NO. 18: Have you or any of your subsidiaries or corporate predecessors (defendant) conducted or contracted to have any entity conduct studies concerning the effects of inhalation of asbestos dust or fibers on a person using or being exposed to any of the asbestos materials manufactured by "defendant"? In answer to this question, please state: (a) The date, nature and location of the studies; 66 (b) The name or names of the persons conducting the studies and their address and describe in detail the extent of their participation; (c) The purpose of the studies; (d) The identity of each document relates to any information set forth in interrogatory; which refers or answer to this (e) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE; See Response to Interrogatory No. 10. INTERROGATORY NO. 19; Has the answering defendant (see definition in No. 18) conducted any studies designated to minimize or eliminate the inhalation of asbestos dust and fibers by those exposed to the use of any of the products containing asbestos materials manufactured by it? If so; (a) The date, nature and location of your studies; (b) The name or names of the persons conducting such studies and their address and describe in detail the extent of this participation; (c) State what action, if any, was taken based upon such studies in an effort to minimize or eliminate the effects of inhalation of asbestos dust or fibers upon those using or being exposed to the dust and fibers contained in such products as manufactured by your company; (d) Identify each document which refers or relates to any information set forth in answer to this interrogatory. (e) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE; See Response to Interrogatory No. 10. 67 INTERROGATORY NO. 20: What technique, if any did and/or do you use to make dust samplings in the manufacturing and packaging production environment or at job sites where your materials are used? (a) Set forth in detail the technique used, when it was commenced and when, if ever, it was concluded; (b) State the purpose for administering such samplings; (c) State the results of such samplings; (d) State what action * if any, has been taken in response to the findings as to the dust samples; (e) Identify each document which refers or relates to such sampling; (f) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied; (g) Identify the living person knowledge of matters discussed herein. who has the most RESPONSE; For many years, Manville Corporation or related entities performed periodic industrial hygiene air sampling. Beginning in the mid-1930s, plant-wide dust counts were taken for Manville by Metropolitan Life Insurance Company. Manville's first in-house industrial hygienist was employed in 1934. Travelers Insurance Company began taking dust counts in Manville's plants in the mid- 1940s and continued monitoring into the 1950s. Manville began using its own employees to conductmonitoring in the early 1950s, and by 1958, four regional laboratories had been established to keep pace with the company's expanding environmental control programs covering all locations and utilizing a number of permanently employed industrial hygienists. The purpose of the evaluations was to determine existing asbestos dust levels, to analyze and evaluate the results, and to implement corrective action, when necessary, with respect to employees of Manville engaged in mining, milling and manufacturing operations and those employees involved in the application or installation operations. The first generally accepted occupational exposure limit for asbestos fiber in the United States was recommended in 1938 by the 68 U.S. Public Health Service and was set at five million particles per cubic foot, eight-hour, time-weighted average. In 1946, the American Conference of Governmental Industrial Hygienists (ACGIH) adopted this as their threshold limit value (TLV). In addition, for some period of time, Manville or related entities also measured airborne fiber concentrations and compared them to an experimental standard of one million fibers per cubic foot, based on the recommendation of researchers at the Saranac Laboratory. In 1968, the ACGIH proposed a standard of two million particles per cubic foot or twelve fibers longer than five micrometers per cubic centimeter, as an eight-hour, time-weighted average. As its internal standard, Manville adopted a standard of six fibers longer than five micrometers per cubic centimeter, eight-hour, time-weighted average in 1968. In 1971, OSHA promulgated an emergency standard of five fibers longer than 5 micrometers per cubic centimeter as an eight-hour, time-weighted average, and ten fibers longer than five micrometers per cubic centimeter maximum ceiling concentration, effective June 7, 1972. This standard was changed by OSHA effective July 1, 1976, to two fibers longer than five micrometers per cubic centimeter as an eight-hour, time-weighted average, and ten fibers longer than five micrometers per cubic centimeter maximum ceiling concentration. On July 21, 1986, OSHA again revised the asbestos standard to the current permissible exposure limit of 0.2 fiber per cubic centimeter, determined as an eight-hour, time-weighted average airborne concentration. An action level of 0.1 f/cc as an eighthour, time-weighted average was also established as the level above which certain compliance activities must be initiated. The following individuals were involved in industrial hygiene and safety programs for Manville or related entities: Name & Last Known Address J. P. Woodard (Deceased) Date & Nature of Employment Employed by Manville commencing in 1926; Assistant Industrial Relations Director, 1938-1945; Director of Industrial Relations, 1945-1952; retired in 1962. O. L. Binder (Deceased) Employed by Manville commencing in 1934; Industrial Hygienist, Environment Control Department, 1934-1944; Industrial Relations Manager, 1944 until retirement in 1969. 69 John P. Syme (Deceased) J. B. Jobe 2800 S. University, Denver, CO 80210 #64 Clifford L. Sheckler (Deceased) Charles W. Hite (Deceased) Hugh M. Jackson 5205 Sky Trail Littleton, CO 80123 Edmund M. Fenner (Deceased) Kenneth W. Smith, M.D. (Deceased) Employed by Manville in the mid1930s as Director of Industrial Relations; administered certain medical services to employees until 1947. Employed by Manville commencing in 1936; Executive Vice President and Chief Operations Officer until retirement in 1973. Employed by Manville commencing in 1936; Supervisor, Safety and Industrial Hygiene; Corporate Manager, Hygiene; Corporate Manager, Industrial Health; Manager, Occupational and Environmental Control until retirement in 1977; administered Manville's health and safety program, 1960-1970; served as a consultant to Manville. Employed by Manville commencing in 1937: Industrial Relations Manager, 1937-1945; Manager, Industrial Relations (Corporate), 1946-1956; Vice President Industrial Relations until retirement in 1968. Employed by Manville commencing in 1937; Corporate Safety Director, 1947 -1952; Director Corporate Training and Management Development until retirement in 1980. Employed by Manville commencing in 1940; Environmental Control Department until retirement in 1981. Employed by Manville commencing in 1944; Medical Officer at Asbestos, P.Q., 1944-46; Medical Director at Asbestos, P.Q., 1946-51; Medical Director, Manville, approximately 1952 until 1966. 70 George L. Swallow 11705 Applewood Knolls Drive Lakewood, CO 80215 Employed by Manville commencing in 1952; Project Engineer, General Plant Engineering Department, 1952-1957; Manager, Occupational Environmental Control, 1969 until retirement in 1982. Dennis R. Christensen Manville Corporation P.O. Box 5108 Denver, CO 80217 Employed by Manville commencing in 1967; Industrial Hygienist, 1967-70; Industrial Hygiene Supervisor, 1970-1982; Manager, Occupational Environmental Control, 1982-Present. William B. Reitze 10870 Park Ridge Road Littleton, CO 80123 Previously employed by CIBA Corporation in the area of toxicology and pharmacology; inspector with U.S. Department of Health; employed by Manville commencing in 1969, Industrial Hygiene, Health and Safety; Director, Health, Safety and Environment; Chief Environmental Scientist until retirement in 1987. Richard P. Carter 427 South Street Randolph, MA 02368 Employed by Manville commencing in 1971; Director, Government Relations, 1973-1976; Manager, Government Affairs, 1976-1980. Paul Kotin, M.D. 4505 S. Yosemite, Unit 339 Denver, CO 80217 Employed by Manville commencing in 1974; Senior Vice President, Health, Safety and Environment; administered Manville's health and medical program until retirement in 1981; currently a consultant to Manville. In addition to these specific individuals, Manville employed various other personnel who participated in such activities as safety inspections, engineering studies, loss control evaluations or similar type operations at Manville's plant locations. These personnel included plant managers, industrial or employee relations managers, plant physicians and nurses, plant and corporate industrial hygiene technicians, plant dust control engineers and line foremen. All responsive documents in the possession, custody or control of the Fund will be produced at the records repository maintained by the Trust in Denver, Colorado. In addition to the documents 71 which will be specifically identified and produced at that time, there may be additional documents responsive to this Interrogatory among the general collection of documents in the repository. This collection of documents will be produced at a time agreed upon by the parties. See Response to Interrogatory No. 1. INTERROGATORY NO. 21: State what, if any safety measures were taken since 1935 by defendant with regard to its employees, during the processing, manufacturing and packaging of products containing asbestos which related to dust abatement or elimination of the discharge into the work environment of asbestos particles. If any such safety measures were taken, state: (a) or clothing; The reason for the use of such measures, equipment (b) The date of implementation of safety measures; (c) Identify each document relating to safety procedures taken by employees or plant personnel in the manufacture, processing and packaging of such products; (d) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information. RESPONSE: Generally, the types of precautions taken at facilities owned and operated by Manville Corporation or related entities to prevent or reduce the exposure to asbestos included the following: 1) use of dust control devices; 2) pre-employment and periodic physical examinations; 3) training regarding safe work practices and other topics; 4) use of protective equipment such as respirators; 5) periodic air sampling; 6) engineering innovation; 7) education regarding the effects of exposure to asbestos; and 8) application of threshold limit values. Many or all of these practices have been in effect in Manville plants which manufacture asbestos containing products since the early 1930s. The practices, procedures and technology have changed substantially with the passage of time, in accordance with developing knowledge in the fields of industrial hygiene and occupational medicine. All responsive documents in the possession, custody or control of the Fund will be produced at the records repository maintained by the Trust in Denver, Colorado. In addition to the documents which will be specifically identified and produced at that time, there may be additional documents responsive to this Interrogatory 72 among the general collection of documents in the repository. This collection of documents will be produced at a time agreed upon by the parties. See Response to Interrogatory Nos. l, 10, 20 and 22. INTERROGATORY NO. 22: State for the period of time the answering defendant manufactured or used at its own plants asbestos containing products the following: (a) Knowledge as to any respirator or other breathing device which was on the market during the relevant period which would prevent the inhalation of asbestos dust and fibers; (b) A detailed description of such respirator or other breathing device, together with all information as to how such device prevents the inhalation of asbestos dust and fibers; (c) What tests, if any, were conducted, by whom and where, with regard to the effectiveness of any such device; (d) which refers interrogatory; Identify each document in any defendant's possession or relates to the subject matter of this (e) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: Since the early 1930s, respirators have been made available to employees at asbestos using facilities operated by Manville Corporation or related entities. Generally, the types of respirators used were those approved by the U.S. Bureau of Mines for pneumoconiosis producing dusts. The U.S. Bureau of Mines was a widely used source of advice for Manville Corporation or related entities with regard to the selection of respirators. Factors used by the U.S. Bureau of Mines when determining the selection of respirator devices included: - Nature of the hazard - Severity of hazard - Type of contaminant - Period of exposure - Distance of respirable air 73 - Activity of wearer The approval requirements implemented by the U.S. Bureau of Mines represented the minimum protection that a respirator should give in order to protect the wearer adequately. Efficiency of the respirator determined by the U.S. Bureau of Mines was based on the percent of the dust in the air that is retained on the filter. Various respirators classified by the U.S. Bureau of Mines were Air Supplied respirators (which had a hose line through which air that is safe to breathe was conveyed to a face piece), Chemical Filter respirators (which removed gaseous contaminants from the air) and Mechanical Filter respirators (which removed, by mechanical filtration, harmful particles from the air). Companies with grants from the U.S. Bureau of Mines for approval of manufacturing respiratory protective devices are listed below: 1941 Acme Protection Equipment Company, Pittsburg, PA American Optical Company, Southbridge, MA American-LaFrance & Foamite Industries, Inc., Elmira, B. F. McDonald Company, Los Angeles, CA Chicago Eye Shield Company, Chicago, IL Davis Emergency Equipment Company, New York, NY DeVilbiss Company, Toledo, OH Draegerwerk, Labeck, Germany E. D. Ballard Company, San Francisco, CA H. S. Cover, South Bend, IN Hygeia Respirator Company, New York, NY Mine Safety Appliances Company, Pittsburg, PA Pangborn Corporation, Hagerstown, MD Pulmpsen Safety Equipment Corporation, Brooklyn, NY Siebe, Gorman & Company, Limited, London, England Standard Safety Equipment Company, Chicago, IL W. W. Gly Manufacturing Company, Cleveland, OH Willson Products, Inc., Reading, PA NY 1949 American Optical Company, Southbridge, MA Binks Manufacturing Company, Chicago, IL E. D. Bullard Company, San Francisco, CA Metallizing Engineering Company, Inc., Long Island City, Mine Safety Appliances Company, Pittsburgh, PA Pulmosan Safety Equipment Corporation, Brooklyn, NY Willson Products, Inc., Reading, PA NY 74 1950 Acme Protection Equipment Company, Chicago, IL American Optical Company, Southbridge, MA American-LaFrance & Foamite Industries, Inc., Elmira, NY B. F. McDonald Company, Los Angeles, CA Binks Manufacturing Company, Chicago, IL Chicago Eye Shield Company, Chicago, IL Davis Emergency Equipment Company, Inc., Newark, NJ Davis Emergency Equipment Company, Inc., Newark, NJ DeVilbiss Company, Toledo, OH Draegerwerk, Lubeck, Germany E. D. Bullard Company, San Francisco, CA H. S. Cover, South Bend, IN Hygeia Filtering Corporation (formerly Hygeia Respirator Company), NY Metallizing Engineering Company, Inc., Long Island City, NY Mine Safety Appliances Company, Pittsburg, PA Pangborn Corporation, Hagerstown, MD Pulmosan Safety Equipment Corporation, Brooklyn, NY Scott Aviation Corporation, Lancaster, NY Siebe, Gorman & Company, Limited, London, England Standard Safety Equipment Company, Chicago, IL W. W. Sly Manufacturing Company, Cleveland, OH Willson Products, Inc., Reading, PA 1958 Acme Protection Equipment Company, South Huron, MI American Optical Company, Southbridge, MA Amerifean-LaFrance Corporation, Elmira, NY B. F. McDonald Company, Los Angeles, CA Binks Manufacturing Company, Chicago, IL Chicago Eye Shield Company, Chicago, IL Davis Emergency Equipment Company, Inc., Newark, NJ Draegerwerk, Lubeck, Germany E. D. Ballard Company, CA H. S. Cover, South Bend, IN Metallizing Engineering Company, Inc., Westbury, NY Mine Safety Appliances Company, Pittsburgh, PA Mine Safety Appliances Company, Limited, Glasgow, Scotland Pangborn Corporation, Hagerstown, MD Pulmosan Safety Equipment Corporation, Brooklyn, NY Scott Aviation Corporation, Lancaster, NY Siebe, Gorman & Company, Limited, London, England Standard Safety Equipment Company, Chicago, IL W. W. Sly Manufacturing Company, Cleveland, OH Welsh Manufacturing Company, Providence, RI Willson Products Division, Ray-O-Vac Company, Reading, PA 75 1965 Acme Protection Equipment Company,. South Haven, MI American Optical Company, Southbridge, MA Binks Manufacturing Company, Chicago, IL Cesco Safety Products, Inc., (formerly Chicago Eye Shield Company) Chicago, IL Davis Emergency Equipment Company, Inc., Newark, NJ DeVilbiss Company, Toledo, OH E. D. Bullard Company, Sausalito, CA Firewel Company, Inc. (subsidiary of The Aro Corporation) Buffalo, NY Fry-Fyter Company, Dayton, OH Glendale Optical Company, Woodbury, NY Globe Safety Products, Inc., (formerly Globe Industries, Inc.) Dayton, OH H. S. Cover, South Bend, IN Metallizing Engineering Company, Inc., Westbury, NY Mine Safety Appliances Company, Glasgow, Scotland Mine Safety Appliances Company, Pittsburgh, PA Pangborn Corporation, Hagerstown, MD Pulmosan Safety Equipment Corporation, Brooklyn, NY Rite Hardware Manufacturing Corporation, Glendale, CA Safeline Products, Putnam, CT Scott Aviation Corporation, Lancaster, NY Scott Air-Pak, Limited, Clarkson, Ontario, Canada U. S. Divers Company, Santa Ana, CA W. W. Sly Manufacturing Company, Cleveland, OH Welsh Manufacturing Company, Providence, RI Willson Products Division, The Electric Storage Battery Company (formerly Willson Products Division, Ray-O-Vac Company and Willson Products, Inc.), Reading, PA Many of the approved respirators which were used at Manville facilities were manufactured by American Optical Company, Mine Safety Appliances Company, Minnesota Mining and Manufacturing, Scott Aviation, Welsh Manufacturing Company, and Willson Safety Products. The specific models which were approved for use varied over the years, as newer, more sophisticated models became available. Prior to the approval of respirators by the U.S. Bureau of Mines, the Safety Engineering magazine in 1918, discussed the development of a protection device known as the "Dustite". Dustite was manufactured by Walter Soderling, Inc. and was approved in 1917 by the Underwriters Laboratory. This mask was made of rubber and polished aluminum with a dry filter of pure cotton. In 1932, the Safety Engineering magazine introduced two different respirators: the Willson Bag Respirator and the Willson Chemical Cartridge Respirator, in which a sanitary facelet covered the edge of the face piece, preventing inhalation of contaminants in the atmosphere. 76 Respirator usage was mandatory when the dust exposures at a particular work station were above the recommended threshold limit value for exposure to asbestos. After the advent of OSHA regulations for asbestos using operations, the specific requirements for respirator usage were established by law. All responsive documents in the possession, custody and control of the Fund will be produced at the records repository maintained by the Trust in Denver, Colorado. In addition to the documents which will be specifically identified and produced at that time, there may be additional documents responsive to this Interrogatory among the general collection of documents in the repository. This collection of documents will be produced at a time agreed upon by the parties. See Response to Interrogatory No. 1. INTERROGATORY NO. 23; Has the "defendant" or any entity (including associations to which the defendant is or has been a member) conducted or had conducted any investigation of the statistical and/or epidemiological relationship between the use of any product identified in answer to Interrogatory No. 1 and the contraction by humans or animals of cancer including but not limited to mesothelioma. If so: (a) investigation participation; Identify each and describe person participating in detail the extent in of such this (b) State when the investigation was conducted; (c) Identify the person or persons who authorized the investigation; (d) Identify each document which refers or relates to any information set forth in answer to this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE; See Response to Interrogatory No. 10. INTERROGATORY NO. 24; Has the "defendant" or any entity (including associations to which the "defendant" is or has been a member) conducted or had 77 conducted any investigation of the statistical and/or epidemiological relationship between the use of any product identified in answer to Interrogatory No. 1 and the contraction by humans of pulmonary asbestosis. If so: (a) Identify each investigation and describe Oparticipation; person participating in in detail the extent of such his (b) State when the investigation was conducted; (c) Identify the person or persons who authorized the investigation; (d) Identify each document which refers or relates to any information set forth in answer to this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: See Response to Interrogatory No. 10. INTERROGATORY NO. 25: If the answering defendant did not respond affirmatively to Interrogatory No. 1 but undertook the types of inquiries indicated in Interrogatories 23 and 24--answer said interrogatories under this question including all subparts. RESPONSE: Not applicable. INTERROGATORY NO. 26: Describe in detail all written and oral reports including those reports originating from users of any of the products identified in answer to Interrogatory 1, including doctors, and employees and agents of the defendants concerning any relationship between the use of these products and the development of pulmonary asbestosis in humans or animals; (a) Identify all persons making said reports and to whom said reports were made; (b) State whether any report or series of reports initiated changes and/or reevaluation of the production, sale or use, or recommendations for use, of any of those products; 78 (c) Identify each document which refers or relates to any information set forth in answer to this interrogatory; (d) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: See Response to Interrogatory No. 10. INTERROGATORY NO. 27: Describe in detail all written and oral reports including those reports originating from users of any of the products identified in answer to Interrogatory No. 1, including doctors, employees and agents of the defendants concerning any relationship between the use of any of those products and the development of cancer including but not limited to mesothelioma in humans or animals: (a) Identify all persons making said reports and to whom said reports were made; (b) State whether any report or series of reports initiated changes and/or reevaluation of the production, sale or use, or recommendations for use, of any of those products; (c) Identify each document which refers or relates to any information set forth in answer to this interrogatory; (d) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full spbstance of the information supplied. RESPONSE: See Response to Interrogatory No. 10. INTERROGATORY NO. 28: For each product identified in answer to Interrogatory No. 1 state whether the production and/or sale of the product has been discontinued, limited or curtailed, and, if so: (a) State when it was discontinued; (b) State with specificity and particularity all the reasons for the discontinuance; 79 (c) Identify each individual who participated in the decision to discontinue production and/or sale and describe in detail the extent of his participation; (d) Identify all documents which reflect, relate to each such discontinuance; refer or (e) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: See Response to Interrogatory No. 1. INTERROGATORY NO. 29: Do you contend that each of the products identified in Interrogatory Nos. 1 or 70 do not or did not create any risk to one who applies or uses the product? (a) contention; If so, state the factual basis for each such (b) If not, state: by such use; (i) The degree and kind of risk which is created (ii) The conditions created, increased or decreased; under which such risk is (iii) Identify each document which reflects, refers or relates to your,answers to this interrogatory; (iv) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. - RESPONSE: See Response to Interrogatory Nos. 1 and 10. INTERROGATORY NO. 30: Do you contend that it was not your responsibility to warn the ultimate user listed in Interrogatory Nos. 1 or 70 of any health risk related to products/asbestos? 80 (a) State the factual basis for such response; (b) Identify each document which reflects, refers or relates to your answers to this interrogatory; (c) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE; Defendant objects to this Interrogatory on the grounds that it calls for a legal conclusion on the ultimate issues presented in this case. INTERROGATORY NO. 31; Do you contend that it was only the responsibility of the employing company involved, or others, to so warn the workers of the risk of harm arising from the use of your product or of the danger of asbestos to their health? (a) State the basis for such contention; (b) Identify which others were so responsible; (c) Identify each document which reflects, refers or relates to your answer to this interrogatory; (d) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE; Defendant objects to this Interrogatory on the grounds that it call for a legal conclusion on the ultimate issues presented in this case. INTERROGATORY NO. 32; Do you contend that the health danger to any plaintiff was not foreseeable by the answering defendant at the time the products alleged to have caused plaintiff's injuries were sold? If so, as to each plaintiff; (a) State the factual basis for such contention; (b) Identify each document relied upon in support of such contention; 81 (c) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state . the full substance of the information supplied. RESPONSE: Defendant objects to this Interrogatory on the grounds that it calls for a legal conclusion on the ultimate issues presented in this case. INTERROGATORY NO. 33: Do you contend that the health consequences to each plaintiff from the use by each plaintiffs of products containing asbestos was obvious? If so, as to each plaintiff: (a) State the factual basis for such contention; (b) Identify all documents relied upon in support of such contention; (c) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: Defendant objects to this Interrogatory on the grounds that it calls for a legal conclusion on the ultimate issues presented in this case. INTERROGATORY NO. 34: Do you contend that each plaintiff knew, understood and appreciated the danger to his/her health arising from his contact with asbestos products which the answering defendant mined, distributed, manufactured or allowed to be used within their production facilities? If so, as to each plaintiff: (a) State the factual basis for such contention; (b) Identify each document relied upon in support of such contention; (c) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. 82 RESPONSE: After reasonable inquiry and search, the information known and available to the Trust is insufficient to respond at this time. INTERROGATORY NO. 35: Do you contend that plaintiff unreasonably exposed himself to the danger arising from his contact with asbestos products which the answering defendant mined, distributed, manufactured or allowed to be used within the confines of a facility of the answering defendant? If so, as to each plaintiff: (a) State the factual basis for such contention; (b) Identify each document relied upon in support of such contention; (c) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: After reasonable inquiry and search, the information known and available to the Trust is insufficient to respond at this time. INTERROGATORY NO. 36: Do you contend that plaintiffs used any asbestos product in other than their usual, customary and expected manner? If so, as to each plaintiff: (a) State the name and chemical composition of the product claimed to have been used in other than its usual, customary and expected manner; (b) State in detail the manner in which plaintiffs used said product in other than its usual, customary and expected manner; (c) Identify each document relied upon in support of such contention; (d) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. 83 RESPONSE: After reasonable inquiry and search, the information known and available to the Trust is insufficient to respond at this time. INTERROGATORY NO. 37: Has the answering defendant ever been named as a defendant in a proceeding including any other civil action, Workmen's Compensation Actions, filing of Workmen's Compensation consent agreements, or other proceedings, to recover damages for injuries resulting from any accident or alleged occupational disease (including asbestosis, cancer, etc.) as a result of exposure at the complainant in such proceedings to asbestos from 1925 to 1975: (a) State the name and address of each plaintiff; (b) State the name and address of each co-defendant; (c) State the date it was filed; (d) State the name of the court in which it was filed; (e) Describe the judgment rendered; (f) State the date that has been set for hearing or trial of any case still pending; (g) Describe the terms of any settlement reached before or during trial; (h) State whether any judgment that has been rendered; appeal is pending from any (i) State the exact nature of the condition alleged in such action to have resulted from the plaintiffs' use of or contact with said product and identify the product involved; (j) Identify each document which reflects, refers or relates to any information pertaining to that complaint; (k) State the first date any notice of the complainants problems came to the attention of the answering defendant; (l) State whether any appeal is judgment that has been rendered. pending from any RESPONSE: The Fund will produce non-privileged documents from Manville Corporation workers' compensation documents as well as a list of 84 all asbestos health claims pending against Manville Corporation or related entities at the time of Manville's Chapter 11 petition at the records repository maintained by the Trust in Denver, Colorado. Additional information regarding the cases contained on the list is a matter of public record. See Response to Interrogatory No. 1. INTERROGATORY NO. 38i With respect to the period from 1940 through 1980, state the names, addresses and company title or position of each person who at any time during that period was in charge of the following activities with regard to each of the products identified in answer to Interrogatory 1: (a) Production; (b) Marketing; (c) Labeling; (d) Advertising; (e) Product evaluation; (f) Research and development; (g) Distribution. RESPONSE: Listed below are the plant managers of Manville*s major asbestos using facilities. This information was compiled to the best of Manville's current knowledge and existing records. INDUSTRIAL PRODUCTS DIVISION MAJOR MANUFACTURING FACILITIES Facility and Dates of Operation Plant Managers & Last Known Address P.O. Box 9067 Long Beach, CA 90810 (1938 to 1982) 1938-54 1955-56 J. A. Carey (Deceased) T. H. Eaton Three Chimneys Royal Oak, MD 21662 1956-57 85 P. V. Dybdal 1957-59 1960-64 1964-67 1968-69 1969-75 1975-81 High Street North Billerica, 01862 (1940 to 1985) MA 1943-54 1954-59 1960 1961-67 1967-72 1972-76 86 2618 Tim Ball Road Waterford, CA 96386 A. R. Girardi (Deceased) S. J. Lane, Jr. Pleasant Point Plantation Star Route #5 Beaufort, SC 29902 G. A. Paddock 415 Flossmoor Avenue Waukegan, IL 60085 D. H. Gallagher 6666 S. Arapahoe Way Littleton, CO 80120 R. J. Alleman 7393 S. Downing Circle East Littleton, CO 80122 W. A. Ford 2900 Park Newport, Newport Beach, CA #330 92660 R. M. Woodward 7 Crescent Street Nashua, NH 03060 V. B. Padham (Deceased) N. J. Gray (Acting) 6755 W. Rowland Avenue Littleton, CO 80123 E. C. Truax (Deceased) J. F. Mell 62 Thomas Drive Chelmsford, HA 01824 A. W. Swanson 78 N. Ridge Road P.O. Box 219 Castle Rock, CO 80104 1977-85 D. E. Guy 209 E. Loch Haven Drive Fayetteville, NC 28304 INDUSTRIAL PRODUCTS DIVISION INDUSTRIAL INSULATIONS DIVISION Main Street Manville, NJ 08835 (1913 to 85) 1938-43 1944-49 J. E. Begert (Address Unknown) Unknown 1950-54 H. J. O'Brien (Address Unknown) 1955-60 J. B. McCarty (Deceased) 1961-66 K. H. Slater 13722 Tartan Drive Sun City West, AZ 85375 1967-82 A. W. Jung 275 S. Metape Circle Bound Brook, NJ 08805 Main Street Manville, NJ 08835 1983-84 H. S. Heydon, Jr. 17 Calvin Road Kendall Park, NJ 08824 1983-84 D. B. Smith (Sealing Components) 10 Arlyne Drive Somerville, NJ 08876 1985 H. G. Kopp (Sealing Components) 634 St. James Place Nacogdoches, TX 75961 BUILDING PRODUCTS DIVISION BUILDING MATERIALS MANUFACTURING DIVISION Main Street Manville, NJ 08835 1950 52 1958 66 W. F. Fischer (Address Unknown) 1953 58 Unknown 1966 72 W. L. Ruff (Deceased) 87 1976 J. A. Manara 123 Grove Street Somerville, NJ 08876 1977-78 R. D. Phillips 56 Mine Mount Road BernardSville, NJ 07924 PACKINGS & FRICTION MATERIALS DIVISION Main Street Manville, NJ 08835 1958 U. D. Torrance 77 Highland Drive San Luis Obispo, CA 93401 1959-60 P. D. Cannon (Deceased) 1961-62 C. L. Stake 244 Shadow Ridge Court Condo 58 Marco Island, FL 33937 1963-69 C. J. DeBiase 5Q30 Sanford Circle Englewood, CO 80110 1970-71 J. A. Krochta 1141 B Spring Lane Run Martinsville, NJ 08836 INDUSTRIAL SPECIALTIES DIVISION Main Street Manville, NJ 08835 1977-81 C. G. Guerin 1795 Bollmer Farm Road Martinsville, NJ 08836 1982-85 F. J. Sydlowski, Jr. 673 John Christian Road Bridgewater, NJ 08807 Tilton, NH 03275 (1948 to 1976) 1948-57 Gilman H. Lowery (Last Known Address) Sharon, MA 1957-69 Wesly Wilkinson (Deceased) 1970-76 88 M. C. Hutchins Route 7, Box 135C Laconia, NH 03246 Sinale Plant Manaaer P.O. Box 55 Waukegan, IL 60085 (1923 to 1985) 1922-24 H. A. Headson (Address Unknown) 1924-27 S. A. Williams (Address Unknown) 1927-37 J. P. Kottcamp (Address Unknown) 1937-44 K. W. Huffine (Address Unknown) 1944-49 C. R. Wikel, Sr. 980 Coventry Lane Lake Forest, IL 60045 1949-50 A. K. Higbee (Address Unknown) INDUSTRIAL PRODUCTS DIVISION INDUSTRIAL INSULATIONS DIVISION P.O. Box 55 Waukegan, IL 60085 1950-56 T. R. Turnbull (Deceased) 1956-60 E. C. Truax (Deceased) 1961-64 N. J. Gray 6755 West Rowland Av< Littleton, CO 80123 1964-69 S. J. Lane, Jr. Pleasant' Point Plantation Star Route #5 Beaufort, SC 29902 1970-72 J. A. McCague (Address Unknown) 1972-74 J. W. Christopher P.O. Box 247 Franktown, CO 80116 1974-79 89 J. W. Reeder 410 Oxford Lane Jamesburg, NJ 08831 1979-82 R. E. Gatti 142 Cottonwood Drive Celena, OH 45822 1983-84 E. A. Paddock 415 Flossmoor Avenue Waukegan, IL 60085 BUILDING PRODUCTS DIVISION BUILDING MATERIALS MANUFACTURING DIVISION P.O. BOX 55 Waukegan, IL 60085 1950 A. K. Higbee (Address Unknown) 1951-56 F. M. Armstrong 810 Capri Boulevard Treasure Island, FL 33706 1956-61 A. B. Marchant Route 1, P.O. Box 150C Whitestone, VA 22578 1962-64 W. L. Miltimore P.O. Box 536 Waukegan, IL 60085 1964-70 N. J. Gray 6755 West Rowland Avenue Littleton, CO 80120 1970-77 C. R. Wikel, Jr. 980 Coventry Lane Lake Forest, IL 60045 1978-82 J. H. Scott P.O. BOX 1487 Lyons, CO 80540 1976-82 E. A. Paddock (Flexboard only) 415 Flossmoor Avenue Waukegan, IL 60085 PACKING & FRICTION MATERIALS DIVISION P.O. BOX 55 Waukegan, IL 60085 1954-58 H. Nies (Deceased) 1958-68 90 G. L. Simmons 3966 E. Evans Denver, CO 80210 1968-69 1970 1971 P.O. BOX 190 Zelienople, PA (1943 to 1973) 16163 1943-46 1946-48 1948-69 1970-73 P.O. BOX 591 Pittsburg, CA (1926 to 1985) 94565 1926-28 1928-37 1937-63 1963-66 1966-68 91 C. F. Luquer 5105 Mayan Ranch Road Apartment 105 Fort Worth, TX 76132 N. J. Gray 6755 West Rowland Avenue Littleton, CO 80120 J. W. Reeder 410 A. Oxford Lane Jamesburg, NJ 08831 S. K. Cooper (Address Unknown) J. L. Miller 1470 Central Avenue Merritt Island, FL 32952 R. E.- Robinson 310 South High Street Zelienople, PA 16063 R. G. Frederick 55 Rockrose Drive RD #1 Baden, PA 15005 P. A. Andrews (Deceased) C. L. Bates (Deceased) W. B. Kelley 1407 Grove Way Concord, CA 94521 W. L. Ruff (Deceased) J. C. Jones 9289 Skyway, Space 26 P.O. Box 40 Paradise, CA 95969 1968-69 T. F. Rooney (Deceased) 1970-73 A. C. Pennewell (Deceased) 1973-76 J. W. Cook 82 Fairway Lane Littleton, CO 80123 1976-85 A. W. Macrae 319 Barrow Street Walnut creek, CA 94598 The following is a listing of district sales managers for northeast regional sales offices. Insulation Systems 1958 Northeast E.R , Wilkinson Industrial Building Products 1958 Northeast R.D , Hayes 1959 New York J.E Kindregan 1959 Philadelphia S.A Peterson 1960 New York J.E Kindregan I960 Philadelphia S.A Peterson Industrial Insulation i960 Boston C.O GarceIon 1960 New York T.S Nicely 1960 Philadelphia E.J Sullivan 1961 Boston C.O Garcelon 1961 New York T.S Nicely 1961 Philadelphia E.J Sullivan & T. P. Williams 1962 Northeast T.S Nicely 1962 Philadelphia T.P Williams 1963 Northeast T.S Nicely 92 1963 Philadelphia T.P. Williams 1964 Northeast T.S. Nicely 1964 Philadelphia T.P. Williams 1965 Northeast T.S. Nicely 1965 Philadelphia T.P. Williams 1966 Northeast T.S. Nicely 1966 Philadelphia T.P. Williams 1967 Northeast T.S. Nicely 1967 Philadelphia T.P. Williams 1968 Northeast T.S. Nicely 1968 Philadelphia T.P. Williams 1969 Northeast T.S. Nicely 1969 Philadelphia T.P. Williams 1970 New York T.S. Nocely 1970 Philadelphia J.A. Campbell 1970 Eastern Area J. Huffine 1971 New York T.S. Nicely 1971 Philadelphia J.A. Campbell 1971 Eastern Area J. Huffine Industrial Products Division 1972 North Atlantic S.V. Lukas 1972 New York T.S. Nicely 1972 Philadelphia J.A. Campbell, 1972 Eastern Marine P.F. Coggins 1973 North Atlantic S.V. Lukas 1973 New York T.S. Nicely 93 1973 1973 1974 1974 1974 1974 1975 1975 1975 1975 1975 1975 1975 1976 1976 1977 1977 1977 1977 Philadelphia Eastern Marine Northeast (Constr.Prod.) Northeast (Equip.Prod.) Eastern Marine East Northeast (Constr.Prod.) Northeast (Equip.Prod.) Northeast (Air Handling) Northeast (Sealing Comp.) Eastern (Refract.Prod.) East (Elec.Equip.) Northeast (Reinforcements) Northeast (Insul.Sys.) Eastern Marine (Refract.) Northeast (Insul.Sys.) Northeast (Refract.) Northeast (Sealing Comp.) Eastern J.A. Campbell, Jr P.F. Coggins S.V. Lukas J. Huffine P.F. Coggins R.T. Flanagan T.M. Kirby J. Huffine E.w. Korty S.V. Lukas P.F. Coggins R.T. Flanagan R.D. Wisbon T.J. Carley P.F. Coggins T.J. Carley C.L. Varney S.V. Lukas D.J. Stenison 94 1978 Northeast (Insul.Sys.) W.C. Roth 1978 Northeast (Refract.) C.L. Varney 1979 Northeast (Insul.Sys.) W.C. Roth 1979 Northeast (Refract.) C.L. Varney 1980 Northeast (Insul.Sys.) W.C. Roth 1980 Northeast (Refract.) C.L. Varney 1982 Northeast (Insul.Sys.) W.C. Roth 1982 Eastern (Refract.) C.L. Varney The following is a listing of district managers regarding sales/marketing. Northeast T.J. Carley 19 Cedarcroft Rd., (609)783-4009 Gibbsboro, NJ 08026 Southeast R.S. Parsley 275 Hollyberry Rd., (404)993-1569 Roswell, GA 30075 North Central W.H. Samberg 10827 Lakeview Dr., (419)877-0173 Whitehouse, OH 43571 Midwest E.W. Korty 542 N. Vine St., (312)323-8464 Hinsdale, IL 60521 Southwest K.M. Thomson 11827 Meadowview, (713)376-2137 Cypress, TX 77429 Rocky Mountain J.J. Whalen 6672 W. Portland Place, (303)979-8500 Littleton, CO 80123 95 West Coast D.E. Kiepler 521 W. Coolidge Dr., (213)284-1925 San Gabriel, CA 91775 LABELING See Response to Interrogatory No. 11. ADVERTISING See Response to Interrogatory No. 5. RESEARCH 6 DEVELOPMENT The individuals in charge of Research and Development since its inception are as follows: Dates Name & Last Known Address Title 1929-1931 A. M. Hamblet (Address Unknown) Manager of Research & Development 1932-1937 B. B. Townshend (Address Unknown) Manager of Research & Development 1937-1938 None (E. R. Williams served as Assistant Manager) 1939-1941 E. R. Williams (Address Unknown) Director of Research & Development 1941-1964 C. F. Rassweiler (Address Unknown) Vice President for Research & Development 1964-1969 A. C. Smith P. 0. Box 1523 Drawer B Rancho Santa Fe, 92067 CA Vice President for Research & Development 1969-1976 F. L. Pundsack 8 Sedgwick Drive Englewood, CO 80110 Vice President for Research & Development 1975-10/77 H. W. Gilbert 7020 W. Stetson Place, #13 Littleton, CO 80123 General Manager, Research Division 1976-1977 C. J. DeBiase 5030 Sanford Circle 96 Senior Vice President for Production & Englewood, CO 80110 Technology 1979-1982 C. J. Sulewski 19035 Greenbrier Lane Monument, CA 80132 Senior Vice President for Production & Technology INTERROGATORY NO. 39t Identify the living parties or persons who are the most knowledgeable about asbestos mined and products containing asbestos sold and/or distributed by you from 1940 to present. Identify all documents which relate to such sales and/or distribution. RESPONSE; No single person or group can be " considered "most knowledgeable" about more than sixty years of operations of Manville Corporation and its related entities. In an effort to be responsive, the Fund will produce corporate organization charts for inspection and copying at the records repository maintained by the Trust in Denver, Colorado at a time comvenient to the parties. See Response to Interrogatory No. 1. INTERROGATORY NO. 40: Has the answering defendant or has anyone on its behalf attended and/or participated in any conference, seminar, lecture or symposium dealing with the health hazards of using any product identified in answer to Interrogatory Nos. 1 or 7 or of asbestos in general and, if so, state; (a) The date and place of such conference, seminar, lecture or symposium; (b) The person or persons conducting such conference, seminar, lecture or symposium; (c) The person or persons who attended on your behalf; (d) The subject matter of such conference, seminar, lecture or symposium; (e) The speakers and/or moderators at such conference, seminar, lecture or symposium; (f) Whether any reports or memoranda were made concerning the subject matter of such conference, seminar, lecture or symposium; identifying each such report or memorandum. 97 RESPONSE; Representatives of Manville Corporation or related entities attended many meetings, seminars, conferences or conventions where the biological effects of asbestos exposure were discussed. It is impossible to determine all of the meetings, seminars, conferences or conventions attended by representatives of Manville Corporation or related entities. However, it is known that representatives of Manville attended or participated in such conferences sponsored by: 1) the Trudeau Institute at Saranac Lake in the 1930s, 1940s and 1950s; 2) the Mellon Institute in Pittsburgh, Pennsylvania in the 1930s; and 3) a U.S. government-sponsored conference on shipyard safety in 1942. In more recent years, representatives of Manville or related entities attended the following additional conferences where asbestos health issues were discussed: Montreal 1958 - Symposium on Cardio-Respiratory Diseases in Industry - McGill and Montreal Universities Oxford 1960 - Inhaled Particles and Vapours - British Occupational Hygiene Society Caen 1964 - International Congress on Asbestosis Chambre Syndicale de l'Amiartte New York 1964 - Biological Effects of Asbestos - New York Academy of Sciences Cambridge 1965 - Inhaled Particles and Vapours II - British Occupational Hygiene Society Vienna 1966 - XV. international Congress on Occupational Health - Permanent Commission and International Association on Occupational Health Cincinnati 1967 - X-Ray - Meeting of Experts on Radiology of Asbestosis - International Union Against Cancer (UICC) Dresden 1968 - Biologische Wirkungen des Asbestos - East Germany Society of Occupational Medicine Tokyo 1969 - XVI. International Congress on Occupational Health - Permanent Commission and International Association on Occupational Health 98 Johannesburg 1969 London (UK) 1969 London (UK) Sardinia 1970 1970 Cardiff Bucharest Helsinki 1970 1971 1971 Buenos Aires 1972 Lyon Montreal 1972 1973 Geneva Brighton 1973 1975 International Conference on Pneumoconiosis - Department of Mines, Government of the Republic of South Africa The Control of Asbestos in Working Environment - British Occupational Hygiene Society Inhaled Particles and Vapours III British Occupational Hygiene Society Meeting of the Sub-Committee and International Colloquium on Asbestosis - Permanent Commission and International Association on Occupational Health, Subcommittee on Asbestosis Symposium on the Tissue Response to Asbestos - University of South Wales IV. International Pneumoconiosis Conference - International Labor Organization (ILO) Geneva International Symposium on Safety and Health in Shipbuilding and Ship Repairing - International Labor Organization (ILO) Geneva XVII. International Congress on Occupational Health - Permanent Commission and International Association on Occupational Health Biological Effects International Agency Cancer (IARC) of for Asbestos Research on Institute of Occupational and Environmental Health - Fibres for Biological Experiments Institute of Occupational and Environmental Health (IOEH), Montreal, Canada ILO (experts) - Asbestos: Health Risks and their Prevention - International Labor Organization (ILO) Geneva XVIII. International Congress on Occupational Health - Permanent Commission and International Association on Occupational Health 99 Edinburgh 1975 - Rouen 1975 - Berlin 1975 - Lyon (France) 1976 - Paris Washington Montreal 1977 1977 1977 Washington 1977 Johannesburg 1977 New York 1978 - Dubrovnik (Yugoslavia) 1978 Caracas (Venezuela) 1978 San Francisco 1979 Lyon (France) 1979 Inhaled Particles IV - Occupational Hygiene Society British Symposium Pathologie de L'Amiante Centre Henri Becquerel", Rouen Asbest and Asbestose - Colloquium - German Society for Traumatology Working Group on the Evaluation of Carcinogenic Risk of Chemical to Man: Asbestos - International Agency for Research on Cancer (IARC) Lyon Colloque - Amiante et Cancerogenese Humaine - (sponsor unknown) Workshop on Asbestos: Definition and Measurement Methods - (sponsor unknown) International Conference on Cancer and Environment - Institute of Hematology and Oncology of Montreal Occupational Exposures to Fibrous and Particulate Dust and Their Extension into the Environment - Society for Occupational and Environmental Health Asbestos Sympiosium - Department of Mines, Government of the Republic of South Africa Health Hazards of Asbestos Exposures - New York Academy of Sciences XIX. International Congress on Occupational Health - Permanent Commission and International Association on Occupational Health Fifth International Conference on Pneumoconiosis - International Labor Organization (ILO), Geneva International Conference on Occupational Lung Diseases - American College of Chest Physicians Biological Effects of International Agency Cancer (IARC), Lyon Mineral Fibres for Research on 100 Cardiff (UK) 1979 - Cardiff Workshop on In Vitro Testing Medical Research Council Mt. Ste-Marie (Quebec) 1979 - Workshop on Occupational Health Standards - Society for Occupational and Environmental Health Los Angeles 1980 - Medical and Legal Aspects of Asbestos Related Disease - University of Southern California On information and belief, the proceedings of such conferences are matters of public record. There may be documents responsive to this Interrogatory among the general collection of documents at the records repository maintained by the Trust in Denver, Colorado. Relevant documents will be produced to the plaintiff for review and copying, at the records repository, at a time comvenient to the parties. See Response to Interrogatory No. 1. INTERROGATORY NO. 41: Is the answering defendant, any association it belonged to or any carrier that it had asbestos product liability with, submit to make a statement at the hearing concerning the dangers of asbestos conducted in March, 1967 before the House of Representatives of the United States Congress Sub-Committee on Labor? If so, identify those persons who are or were associated with you that participated, and identify any writing concerning said participation. RESPONSE: The Fund has not been able to find any information regarding hearings on asbestos held by the Select Sub-Committee on Labor in March, 1967. However, hearings on asbestos were held before the Select Sub-Committee on Labor of the Committee on Education and Labor, House of Representatives (H.R. 14816) in February and March of 1968. Responsive documents will be produced at the records repository maintained by the Trust in Denver, Colorado at a time agreed upon by the parties. INTERROGATORY NO. 42: State when, if at all, you received knowledge of the following publications or matters discussed therein, who received such knowledge and identify all documents relating to such knowledge: (a) Fleischer, Viles, Gade and Drinker, "a Health Survey of Pipe-Covering Operations in Construction Naval Vessals," 28 J. Indus. Hyg. 9-16; 101 (b) Selikoff, et al., "Asbestosis and Neoplasia," 42 Am. J. Med. (1967); (c) Selikoff, Churg and Hammon, "The Occurrence of Asbestosis Among Industrial Insulation Workers," 132 ann. New York Acad. Sc. 139 (1965); (d) "Documentation of the Threshold Limit Values for Substances in Workroom Air," A.C.G.I.H. (3rd 1971); (1961); (e) "Threshold Limit Values for 1961," A.C.G.I.H. (f) 1906 report by Dr. H. Montague Murray; (g) 1934 study by Dr. Anthony J. Lanza, Assistant Medical Director of Metropolitan Life Insurance Company. RESPONSE: The Fund is continuing to compile information responsive to this Interrogatory and will supplement as soon as possible. INTERROGATORY NO. 43: Identify each publication contained in your research library, or otherwise in your custody, including but not by way of limitation, your Research and Development center, all medical journals, industrial medical journals, industrial hygiene journals, technical literature in the area of asbestos mining, manufacture, application and use, and Governmental publications, dealing with occupational diseases arising from the manufacture and use of asbestos-containing products. As to all such publications, state the volumes which are in your custody and control, when each such volume was received and the present location of such publications. RESPONSE: As of 1982, Manville Corporation or related entities subscribed to the following are journals or periodicals. The dates in parentheses represent the first year of subscription. (Periodic newsletter through membership) Advanced Data (1976) AIHA Journal (1960) * AIHA Newsletter (Unknown) American Journal of Epidemiology (1975) American Journal of Industrial Medicine (1980) American Journal of Law and Medicine (1977) American Journal of Nursing (1976) American Journal of Pathology (1974) 102 American Journal of Public Health (1975) American Review of Respiratory Disease (1975) American Scientist (1975) AWWA Journal (1974) Annals of Occupational Hygiene (1974) * AOMA Report (Unknown) Archives of Environmental Health (1973) Asbestos (i960) Asbestos Worker (1962) Audio Visual Communication (1976) A V Guide (1976) British Journal of Cancer (1975) British Journal of Industrial Medicine (1972) Business Week (1972) CA Cancer/Clinic (1969) CAL OSHA Labor (1977) CAL OSHA News (1979) CAL OSHA Reporter (1974) CAL OSHA, Title 8 (1976) Canadian Medical Association Journal (1980) Canadian Occupational Safety and Health Law (1980) Cancer (1974) Cancergram (1978) Cancer News (1975) Cancer Research (1974) Chemical & Engineering News (1970) Chemical Regulation Reporter (BNA) (1980) Chemical Week (1972) The Chemical Worker Chest (1970-71; 1974) Congressional Staff Directory (Unknown) CPSC Memo (1980) CPSC Publication Calendar (1980) Dangerous Prop. Industrial Materials Report (1980) Defend. Employment/OSHA, Contests (1979) Dun's Review (1974) Editor & Publisher (1978) Emergency Medicine (1977) Enterprise (1977) Environment (1978) Environment Reporter (BNA) (1977) Environment Health Letter (1972) Environmental Health Perspectives (1972) Environmental Pollution & Control (1972) Environmental Research (1974) Environmental Science & Technology (1977) Environmental study Conference (1978) Experimental Lung Research (1979) FDA Drug Bulletin (1981) Federal Register (1972) Federal Yellow Book (1978) Federation Proceedings (1970) 103 Food Chemical News (1974) Harvard Business Review (1950) Harvard Environmental Law Review (1981) Harvard Medical School of Health Letter (1978) Hazardous Materials Management Journal (1979) Hazardous Substances Advisory (1980) Hazardous Waste News (1980) IARC Monogram (Carcinoma Risk/Chemical to Man) (1980) IARC Scientific Series (1980) Industrial Hygiene Digest (1964) Industrial Hygiene News (1976) Industrial Hygiene News Report (1974) Industrial Photography (1976) Industry Week (1974) Int'l Archives of Occupational & Environmental Health ILO Information (1975) Job Safety & Health Report (1974) Journal of Air Pollution Association (1973) Journal of American Medical Association (1956) Journal of Environmental Health (1974) Journal of Environmental Pathology/Toxicology (1977) Journal of Hazardous Materials (1975) Journal of the National Cancer Institute (1978) Journal of Occupational Medicine (1975) Journal of Society/Occupational Medicine (1975) Journal of Toxicology & Environmental Health (1977) Laboratory Management Alcohol Journal (1976) Laboratory/Occupational Health Program Monitor (1974) Lancet (1975) Mayo Clinic Proceedings (1976) Media & Methods (1976) Medical World News (1975) Medicolegal News (1975) Mine Injuries & Work Time Quarterly (1978) Mine Safety/Health Administration Mailings (1979) Mine Safety & Health Reporter (BNA) (1979) Monthly Labor Review (1976) Monthly Vital Statistics (1976) Morbidity & Mortality (1975) NAS News Report (1977) The Nation's Health (1978) NICA (National Insulation Contractors Association) Outlook (1974) National Library of Medical News (1975) National Safety Council Library Bulletin (1975) National Safety Council Data Sheets (1975) Nature (1980) New England Journal of Medicine (1974) New York Times (Newspaper) (1976) Noise Control Report (1974) Noise Regulation Reporter (1975) Nosology News (1981) (1979) 104 NTIS Newsline (1980) NTP Technical Bulletin (1980) OAG Airline Guide (1976) OAG Travel Planner (1977) Occupational Hazards (1971) Occupational Health (St. Joseph's Hospital-Denver) (1977) Occupational Health Nursing (1969) Occupational Health & Safety (1976) Occupational Health & Safety Letter (1972) Occupational Safety & Health Reporter (BNA) (1973) Oncology Times (1980) OSHA Report (MAN Manager) (1973) OSHA Regulations Update Services (1979) Pathologist (1974) Preventive Medicine (1980) Product Safety & Liability Reporter (1977) Scandinavian Journal of Work/Environment & Health (1975) Science (1974) Science News (1975) The Sciences (1974) Scientific Medicine (1980) Scientific American Medicine (Update) (1980) Sound & Vibration (1980) Source Data (1980) State Regulation Rpt of Toxic Substances & Hazardous Waste The Tobacco Observer (1979) Today's Secretary (1976) Tox Tips (1978) Toxic Materials News (1974) Toxic Materials Reference Service (1977) Toxic Substance Journal (1979) Toxicology & Applied Pharmacology (1975) Wall Street Journal (1976) Washington Post (1976) (1974) The Fund has 115 boxes from the Manville Corporate Information Center which may be responsive to this Interrogatory. These boxes and all specifically identified documents will be made available to plaintiff for review and copying at the records repository maintained by the Trust in Denver, Colorado at a time convenient to the parties. See Response to Interrogatory No. 1. INTERROGATORY NO. 44: As to any threshold limit values published by the American Conference of Governmental Industrial Hygienists, state whether you have brought such information to the attention of those using your products or asbestos products on your premises. (If yes, how?) If you have not done so, state the reasons why you have not done so. 105 RESPONSE See Response to Interrogatory No. 11. INTERROGATORY NO. 45: Has answering defendant or any of its employees been: (a) a member of or (b) affiliated in any manner with or (c) received reports or (d) subscribed for reports or publication to the Industrial Hygiene Foundation organized in Pittsburgh, Pennsylvania? RESPONSE: Johns-Manville was a member of the Industrial Hygiene Foundation of America, and received materials from the organization. INTERROGATORY NO. 46: With regard to Interrogatory No. 45, what years did answering defendant or its employee(s) participate under (a), (b), (c) or (d)? RESPONSE: Defendant objects to the word ''participate'' in that it is undefined, lacking in specificity artd may have unintended legal ramifications. Without waiver of or prejudice to this objection, Defendant states that it was a member of the Industrial Hygiene Foundation of America, later the Industrial Health Foundation, from 1936 through the present. INTERROGATORY NO. 47: With regard to Interrogatory No. 45, do you have any documents obtained from the Industrial Hygiene Foundation? If so: (a) List all such documents; (b) Who currently has them in their possession? (c) When was each received? (d) State the name of the individuals who received such documents or information contained in such documents. 106 RESPONSE; The Fund will produce responsive documents at the records repository maintained by the Trust in Denver, Colorado at a time convenient to the parties. See Response to Interrogatory No. 1. INTERROGATORY NO. 48; Have you received any reports or documents prepared by Metropolitan Life Insurance Company from 1929 to about 1960, concerning statistical and other studies of asbestos workers? If so, state: (a) The documents received; (b) Who received them and when; (c) The current location of the documents. RESPONSE: The Fund is continuing to compile information responsive to this Interrogatory and will supplement as soon as possible. INTERROGATORY NO. 49; State all chemical, industrial, medical or trade associations to which you have belonged since 1936. RESPONSE: Manville Corporation or related entities belonged to the following organizations which are involved directly or indirectly with the mining or milling of asbestos fiber, or the manufacturing or installation of asbestos containing products, current through 1985: American Society of Testing Materials 1916 Race Street Philadelphia, PA 19103 (approximately 1930s through 1985) Asbestos Cement Pipe Producers Association 1600 Wilson Boulevard Suite 1308 Arlington, VA 22209 (approximately 1972 to early 1980s) Asbestos Cement Product Association New York, NY (approximately 1955 to 1967) (defunct) 107 Asbestos Information Association/North America 1745 Jefferson Davis Highway Arlington, VA 22202 (approximately 1971 through early 1980s) Asbestos Textile Institute P.O. Box 471 Willow Grove, PA 19090 (11/16/44 to 1973) Automotive Parts Rebuilders Association 6849 Old Dominion Drive McLean, VA 22101 (approximately 1950 to 1972) Brake Lining Materials Association 370 Lexington Avenue New York, NY 10017 (approximately 1926 to 1949) (defunct) Canadian Asbestos Information Centre (formerly Institute of Occupational Environmental Health) 1130 Sherbrooke Street West, Suite 410 Montreal, Quebec H3A 2H8 CANADA (1966 to 1983) Friction Materials Standards Institute E-210 State Highway, Number 4 Paramus, NJ 07652 (approximately 1949 to 1972) Industrial Health Foundation (formerly Industrial Hygiene 34 Penn Circle West Pittsburgh, PA 15206 (1936 through 1985) Foundation) Mid-West Insulation Contractor's Association 2202 Hanscom Boulevard Omaha, NE 68105 (approximately 1962 through 1985) National Building Material Distributors Association 1701 Lake Avenue Glenview, IL 60025 (1966 through 1985) 108 National Insulation Contractors Association address unknown (1954 through 1980s) National Insulation Manufacturers Association, 441 Lexington Avenue New York, NY 10017 (approximately 1958 to 1968) Inc. Quebec Asbestos Mining Association Suite 412, 5 Place Ville Marie Montreal, Quebec H3B 2G2 Canada (approximately 1930 to 1983) Resilient Floor Covering Institute 966 Hungerford Drive, Suite 12-B Rockville, MD 20850 (1978 through 1985) Southwest Insulation Contractor's Association 1406 Third National Bank Building Dayton, OH 45402 (sometime after 1958 through 1985) Thermal Insulation Manufacturers Association, 441 Lexington Avenue New York, NY 10017 (approximately 1969 through 1985) Inc. Western Insulation Contractor's Association 83 Hazel Lane Piedmont, CA 94611 (1955 through 1985) INTERROGATORY NO. 50: With regard to the associations enumerated in the answer to Interrogatory No. 49, state; (a) The names of each individual associated with the answering defendant since that date who have had dealings with each said association; (b) association; Describe the nature of their dealings with each such (c) State their last known address; (d) If still employed, their current job and title; (e) List all documents related to said affiliation. 109 RESPONSE: Defendant objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, lacking in specificity and impossible to answer in light of the length of time and number of organizations which the Manville Corporation or related entities has been a member. Without waiver of or prejudice to the foregoing objection, the Fund will produce responsive documents at the records repository maintained by the Trust in Denver, Colorado at a time convenient to the parties. In addition to the documents which will be specifically identified and produced at that time, there may be additional documents responsive to this Interrogatory among the general collection of documents in the repository. This collection of documents will be produced at a time agreed upon by the parties. See Response to Interrogatory No. 1. INTERROGATORY NO. 51i Name each corporate officer and/or member of corporate management who attended any meeting and/or conference concerning the health, safety or medical aspects of asbestos and/or the use of products containing asbestos, and for each person identified, state the nature of his participation in each such meeting or conference. (a) If any papers were received or given by the individuals listed for answer to Interrogatory NO. 51, list each such document and who has copies of them. RESPONSE: See Response to Interrogatory Nos. 40 and 50. INTERROGATORY NO. 52: State the sources of all asbestos and/or asbestos containing products which have been incorporated in any product manufactured or distributed by answering defendant in its own facility (including installing on its equipment or buildings) or utilized from 1936 to 1980. (a) State the names of all individuals associated with the above stated sources who dealt with or handled your account: (b) Identify any such document which refers, or relates to any information provided in answer interrogatory; reflects to this this (c) As to any information received orally in answer to interrogatory, identify each person who supplied such 110 information and state the full substance of the information supplied. RESPONSE: Manville or related entities used asbestos fiber obtained from a number of sources. For products which contained chrysotile, much of the fiber used was obtained from the Jeffrey Mine in Asbestos, Quebec, which was owned and operated by a Canadian subsidiary. Other sources of chrysotile included: Advocate Mines, Ltd.; Bell Asbestos Mines, Ltd.; Calaveras Asbestos, Ltd.; Cassiar Asbestos Corporation, Ltd.; H.K. Porter Company; Mar lime Chrysotile Asbestos Corporation, Ltd.; Metate Asbestos Corporation; and Pacific Asbestos Corporation. Crocidolite and amosite fibers were imported into this country, primarily from South Africa. The suppliers included: Antony Gibbs & Company, Ltd.; Asbestos Investment (Pty), Ltd.; John Beith (S. A.) Pty.; Ltd.; British Metal Corporation; Cape Blue Mines (Pty), Ltd.; Central Asbestos Company, Ltd.; C. J. Petro & Company; Colonial Sugar Refining Company, Ltd.; Egnep (Pty), Ltd.; Flintkote Building Products Group; General Mining & Finance Corporation, Ltd.; General Services Administration; Hooker Chemical Company; John Holt & Company; Kurman; Norca Corporation; North American Asbestos Corporation; Raw Asbestos Distributors; Rhodesian Asbestos, Ltd.; S.A. Asbestos Trading (Pty), Ltd.; V/O Soyuspromexport; Special Asbestos Company, Inc.; Turner & Newell, Ltd.; Turners Asbestos Fibres, Ltd.; and Watson, Geach & Company, Inc. All responsive documents in the possession, custody or control of the Fund will be produced at the records repository maintained by the Trust in Denver, Colorado. In addition to the documents which will be specifically identified and produced at that time, there may be additional documents responsive to this Interrogatory among the general collection of documents in the repository. This collection of documents will be produced at a time agreed upon by the parties. See Response to Interrogatory No. 1. INTERROGATORY NO. 53: State the names of all individuals associated with you who had any dealings with the requisition and/or procurement of asbestos or products containing asbestos as indicated in answer to Interrogatory NO. 52 and for each such person: (a) Identify the nature of his association(s), the locations and the dates of their occurrence; (b) Identify each document which refers, reflects or relates to any information provided in answer to this interrogatory; 111 (c) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: See Response to Interrogatory Nos. 38 and 39. Interrogatory No. 54: State the names of all individuals who dealt with or handled the account with and/or made any sales to the employers of the Plaintiff of asbestos and/or products containing asbestos. (a) Describe in detail the nature and dates of each such association with the said accounts; (b) Identify each document which refers, reflects or relates to any information provided in answer to this interrogatory. RESPONSE: See Response to Interrogatory Nos. 38 and 39. INTERROGATORY NO. 55: Identify each individual whom you expect to call as an expert witness at the trial of this litigation, and for each person identified: (a) The subject on which the expert is expected to testify and the substance of the facts and opinions to which he or she is expected to testify and a summary of the grounds for each opinion; (b) Identify each document referring, relating or containing any such facts and/or opinions and identify each individual having custody of each document identified. RESPONSE: Defendant has not determined or identified expert witnesses at this time. INTERROGATORY NO. 56: Identify each individual who you have retained or employed or anticipate retaining or employing in any way in preparation of or 112 anticipation of trial in this litigation who is not expected to be called as a witness at trial, and for each such individual: (a) State the substance of any facts or opinion which he or she has discussed with any agent, employee or representative of the answering defendant, together with a summary of the grounds for each opinion; (b) Identify each document referring to or containing such facts and/or opinions, and identify each person having custody of each document identified. RESPONSE: Defendant objects to this Interrogatory on the ground that it seeks information which is beyond the scope of Civil Rule 26 and is privileged. INTERROGATORY NO. 57: State the names, last known addresses and telephone numbers of each and every person whom you intend to call as a witness at the trial of this litigation: (a) State the substance of any facts or opinion which he or she has discussed with any agent, employee or representative of the answering defendant, together with a summary of the grounds for each opinion; (b) Identify each document referring to or containing such facts and/or opinions, and identify each person having custody of each document identified; (c) Specify witnesses you intend to use at the trial of this case with respect to the occurrences and/or cause of plaintiffs' illnesses or with respect to the claimed damages or with respect to your liability. RESPONSE: Defendant has not determined or identified witnesses at this time. INTERROGATORY NO. 58: State whether your corporation is and has been insured for: (a) Product liability insurance, including "excess or umbrella" policies; (b) Workmen's Compensation; 113 (c) For product liability coverage, state: (i) If so, the limits of coverage; (ii) The name of the insurance company; (iii) Whether this claim has been accepted or whether a letter of intent to deny coverage has been received. RESPONSE: Manville Corporation or related entities had primary and excess liability insurance coverage for bodily injury claims. Insurance coverage was the subject of two declaratory judgment actions entitled: (1) Johns-Manville Corporation, et al v. The Home Insurance Company, et al., originally filed in San Francisco Superior Court, Docket No. 765226, and later a part of a coordinated action entitled "Judicial Council Coordination Proceeding No. 1072" in the State of California; and (2) Commercial Union Insurance Company v. Johns-Manville Corporation, et al. United States District Court, District of Massachusetts, Civil Action No. 80-306-N. Manville has settled with most of the insurance companies which were involved in these suits, as well as other carriers which were not involved in any litigation. Total settlements exceed $800 million. The following carriers were among those which entered into agreements with respect to their insurance obligations to Manville and related companies: Aetna Casualty and Surety Company AIU Insurance Company Allstate Insurance Company American Re-Insurance Company Centaur Insurance Company Columbia Casualty Company Commercial Union Insurance Company Continental Casualty Company First State Insurance Company Gibraltar Casualty Company Granite State Insurance Company Highlands Insurance Company The Home Insurance Company Insurance Company of North America ISLIC (International Surplus Lines Insurance Company) INSCO, Ltd. Lexington Insurance Company Lloyd's of London Midland Insurance Company National Union Fire Insurance Company of Pittsburgh, PA Northbrook Excess & Surplus Insurance Company Northeastern Fire Insurance Company of Pennsylvania 114 Peerless Casualty Company Peerless Insurance Company Prudential Reinsurance Company Reliance Insurance Company Rocky Mountain International Insurance, Sun Insurance Office, Ltd. Travelers Indemnity Company Ltd. Manville Corporation is continuing to pursue litigation against Protective National Insurance Company of Omaha and Canadian Indemnity Company in San Francisco Superior Court in an effort to secure all funds to which it is entitled. Any funds which are obtained as a result of these ongoing efforts will be distributed pursuant to the terms of the Manville Corporation Second Amended and Restated Plan of Reorganization, November 28, 1988, ("Plan".) Manville Corporation is also attempting to resolve a claim against South Hampton Insurance Company, Ltd. for recovery under coverage provided for bodily injuries. Manville Corporation is pursuing claims against numerous additional carriers which are in liquidation in order to protect its rights as to those carriers. Finally, Manville Corporation is continuing to investigate other carriers which may have provided coverage to Manville or related entities. INTERROGATORY NO. 59: In whose possession are you and your predecessors' annual reports from 1936 to the present? RESPONSE: Annual reports pertaining to Manville Corporation are in the possession of the Fund, and will be produced at the records repository maintained by the Trust in Denver, Colorado at a time agreed upon by the parties. INTERROGATORY NO. 60: Describe in detail your policy with respect to the destruction of records pertaining to each of the products identified in answer to Interrogatory No. 1. (a) Identify all documents pertaining to your policy, if any, regarding the destruction of such records; (b) Identify the person or persons having custody of such policy documents; (c) Identify the person or persons in charge of destroying records pertaining to each such product; 115 (d) Identify each document which refers, reflects or relates to any information provided in answer to this interrogatory; (e) Describe what steps, if any, you have taken since the institution of this action or other actions involving asbestos to prevent the destruction of any documents relating to asbestos. RESPONSE: The Fund is unaware of any documents destroyed during the course of the asbestos litigation. Additionally, Manville Corporation or related entities prohibited destruction of documents during the asbestos litigation. However, documentation has been discovered which indicates that some potentially relevant documents may have been destroyed in the early 1960s. In addition, prior to the advent of asbestos litigation, other documents may have been destroyed in the normal course of business. Specific records known to the Fund to be responsive to this Interrogatory will be produced at the records repository maintained by the Fund in Denver, Colorado at a time agreed upon by the parties. INTERROGATORY NO. 61: State the names of all individuals who aided in the preparation of these answers, and for each such person, state: (a) Which interrogatories they helped prepare or the particular subject area for which they supplied information; (b) Their current position with the company; (c) Their current or last known home and business address and phone numbers. RESPONSE: The Response to these Interrogatories were prepared by attorneys representing the Fund, using documents available to them. INTERROGATORY NO. 62: State all processes used by plaintiff's employer, known to any defendant where asbestos was an ingredient. RESPONSE: Unknown. 116 INTERROGATORY NO. 63; State all use of asbestos insulation by plaintiff's employer, known to any defendant. (a) Types of asbestos insulation used; (b) Manufacturer and/or brand names; used; (c) Locations in said plants where said insulation was (d) The person most knowledgeable in said corporation about the purchasing of insulation by distributors that covered the states of New Jersey, Delaware, Pennsylvania and Maryland. RESPONSE: Unknown. INTERROGATORY NO. 64: State whether you have entered into any agreement, either oral or written, with any other defendant in this action regarding (1) Settlement or non-settlement and/or (2) on liability. Allocation of damages, should the plaintiffs prevail If the answer is yes to either of the above, state the substance of each such agreement and such parties who have entered into this agreement: (a) Identify those persons who participated in preparation of each such agreement and describe in detail nature and extent of his participation; and the the (b) Identify each document which contains, refers or relates to each such agreement. RESPONSE: No. INTERROGATORY NO. 65: Do you or your attorneys know of any person or persons not listed in the preceding answers having knowledge of facts relevant to the allegations in this lawsuit including witnesses to the accident, injury, illnesses, etc. in question? If yes, please 117 state the names, addresses, home telephone numbers, places of employment, relationship to you, the present whereabouts of all such persons, and which of said persons you intend to produce as witnesses in the trial of this action. RESPONSE: No. INTERROGATORY NO. 66: Do you or your attorneys have any written statements from any persons having knowledge of facts relevant to the subject matter of this lawsuit, including witnesses to the accident, injury, illnesses, etc. in question? If yes, please state the names, addresses, home telephone numbers, places of employment, relationship to you and the present whereabouts of all such persons. RESPONSE: No. INTERROGATORY NO. 67: State whether you were a member of the Asbestos Information Association (A.I.A.) or in any manner received information or participated in any of the association's activities. RESPONSE: Yes. INTERROGATORY NO. 68: If your answer to any part of Interrogatory 82 is in the affirmative, please state: (a) attended; The date, time and places of any A.I.A. meetings (b) The date and time period during which you received any publication of the A.I.A.; (c) The name, address and telephone number of each and every person who attended such meetings and to whom any such publications were sent; (d) The nature of the information that was furnished at meetings or in such publications; 118 (e) Name, address and telephone number of the present or last known custodian of any copies of A.I.A. newsletters, correspondence or publications. RESPONSE: Manville Corporation or related entities were members of AIA/NA beginning in 1969. All non-privileged documents relating to Manville's participation in AIA/NA will be produced at the records repository maintained by the Trust in Denver, Colorado. In addition to documents specifically identified, there may be other documents responsive to this request among the general collection of documents in the records repository. See Response to Interrogatory No. 1. INTERROGATORY NO. 69: If answering defendant or any or its agents or employees received Asbestos Magazine, please state: (a) The date and time periods during which you received such publication; (b) The frequency of receipt, occasionally, rarely, etc.; e.g., regularly, (c) The terms, circumstances or requirements of receipt of such publication, e.g. free, by subscription, distributed at meetings, etc.; (d) Name, address and telephone number of the present or last known custodian of any copies of such magazine. RESPONSE: Manville Corporation or related entities subscribed to and received the "Asbestos Magazine" on a yearly basis. The Fund has copies of the issues or excerpts of issues listed below: Issues 1959 December 1960 January 1967 April 1971 August, September, October, December 1972 January, February, March, April, May, June, October December 119 1973 January, February, March, April, May, June, October, December 1974 January, February, March, April, May, June, October, December 1975 January, February, March, April, May, June, October, December 1976 January, February, March, April, May, June, October, December 1977 January, February, March, April, May, June, October, December 1978 January, February, March, April, May, June, October, December 1979 January, February, March, April, May, June, October, December 1980 January, February, March, April, May, June, October, December 1981 January, February, March, April, May, June, October December 1982 January, February, March, April, May, June, October, December Excerpts Raw Fiber/Product Statistics 1919 - 1930 1919 - 1939 1931 - 1939 1940 - 1942 1940 - 1952 1953 - 1960 1943 - 1946 1947 - 1950 1951 - 1957 INTERROGATORY NO. 70; 1961 - 1981 Does the answering defendant have in its possession any medical records, not previously produced in this case relating to any of the plaintiffs, including, but not limited to, charts, xrays, physical examination reports, summaries, tape recordings of interviews and any and all other records pertaining to the medical 120 condition of the plaintiffs? If so, plaintiffs request that such records be produced in accordance with Rule 34. RESPONSE: No. INTERROGATORY NO. 71: With respect to each denial and affirmative defense contained in your response to the Complaint, state the following: (a) Identify which defense it relates to; (b) Each fact upon which your contention is based; (c) The names and present or last known addresses and present or last known employer of all persons having knowledge of any of the facts set out in answer to subparagraph (b) hereof; (d) The description or designation of each document which in any way reflects, relates or refers to any of the facts set out in answer to subparagraph (b) hereof. RESPONSE: Defendant will supplement its response to this Interrogatory as soon as possible. ~. SECTION II INTERROGATORIES AND REQUEST FOR PRODUCTION DIRECTED TO DEFENDANTS ON WHOSE PREMISES PLAINTIFF WAS EMPLOYED BY DEFENDANT OR OTHERS INTERROGATORY NO. 72: Describe in detail, with specificity and particularity each product which was being installed, repaired, removed, or otherwise used on the answering defendant's premises at all relevant times which contained asbestos, and for each such product describe: (a) Its chemical ingredients; (b) For each ingredient contained therein state: (i) The name or chemical composition of each substance, what harmful effect, if any are known, that it produces in man or mammals and whether it produces its harmful effects through ingestion, inhalation, absorption or a combination of these; 121 substance produced; (ii) When you determined and/or learned that the produced harmful effects and how such effects were (iii) Identify each individual who participated in such determination and/or obtained such knowledge; (iv) Identify each document that refers, reflects or relates to any information pertaining to the properties of each of the ingredients and/or how the harmful effects are produced as well as your determination of those toxic effects and the manner by which they are produced; (v) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied; (c) Whether any of these products were manufactured or distributed by answering defendant; mined, (d) The location within defendants premises where said product was being installed, repaired, or removed. RESPONSE: Not applicable. INTERROGATORY NO. 73: Provide the information requested in Interrogatory No. 2 for products iisted in No. 72. RESPONSE: Not applicable. INTERROGATORY NO. 74: For each product identified in answer to Interrogatory No. 72, identify: (a) The general contractor on the project which was responsible for or participated in the installation, repair, or removal of said product; (b) Any subcontractor or other contractor which was responsible for or participated in the installation, repair, or removal of said product, and state: contractor (i) The type of agreement under which each named was responsible for or participated in such 122 installation, repair or removal (e.g. subcontractor, independent contractor); (ii) The extent of each named contractor's expressed responsibility or participation under said agreement. (c) Any other person, firm or entity who was responsible for or participated in the installation, repair or removal of said products; (d) Each document which refers, reflects or pertains to any information provided in the answer to this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who has supplied such information and state the full substance of the information supplied. RESPONSE; Not applicable. INTERROGATORY NO. 75; Identify any supervisory personnel of answering defendant or the entity performing the functions enumerated in Interrogatory NO. 72 who were present during some or all of the installation, repair or removal of the products identified in answer to Interrogatory Number 72, and for each such person, state; (a) The name of the person, firm or other entity who had the authority to hire him/her; (b) The name of the person, firm or other entity who had the authority to fire him/her; (c) The name of the person, firm or other entity who actually paid his/her wages; (d) The name of the person, firm or other entity who had control over his/her day to day performance. RESPONSE; Not applicable. INTERROGATORY NO. 76; Identify each and every worker on answering defendant's job site who participated in the installation, repair or removal of the products identified in answer to Interrogatory No. 72 at all relevant times, and for each such person state; (a) His job title at the job site; 123 (b) His duties at the job site; if any; (c) The local union to which he belonged at that, time, (d) The name of the person, firm or other entity who had the authority to: job. (i) (ii) (iii) (iv) Hire him/her; Fire him/her; Pay his/her wages; Control his/her day to day performance on the RESPONSE: Not applicable. INTERROGATORY NO. 77: For each product identified in answer to Interrogatory No. 72, state what person, firm or other entity was responsible or participated in providing said product to the workers on the job site? (a) How was the product purchased or Otherwise acquired, before being distributed for use on the job site? RESPONSE: Not applicable. INTERROGATORY NO. 78: For each product identified in answer to Interrogatory No. 72 state: (a) What person, firm or other entity purchased and/or obtained said product; (b) Where it was purchased, and/or obtained; (c) From whom it was purchased; (d) The dates it was purchased; (e) The manner in which it was received, stored and distributed for use on the job site. RESPONSE: Not applicable. 124 INTERROGATORY NO. 79: State whether asbestos products were hieing installed, or removed on answering defendant's premises during the time in areas where electrical construction workers were to work. If so, describe: repaired relevant required (a) Whether and when answering defendant became aware of these circumstances; (b) Any action which defendant took to insure the safety of such workers under these circumstances. RESPONSE: Not applicable. INTERROGATORY NO. 80: State what action, if any, you have taken since 1935 to reduce or eliminate any risk of occupational disease or personal injury to those using asbestos products or to those in close proximity to those using such products while on your premises, which arises from the inhalation of dust and fibers. RESPONSE: Not applicable. INTEROGATORY NO. 81: Describe in full and complete detail each of the activities which you have undertaken with the intention of warning workers on your premises of the effects of any product identified in answer to Interrogatory No. 1 as to the health of the user or those in close proximity to the user and give the inclusive dates of each such activity, and (a) Identify each individual who participated therein and describe the nature of his participation; (b) Identify each document which reflects, refers or relates to information pertaining to such warning; (c) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: 125 Not applicable. INTERROGATORY NO. 82: State what if any safety measures were taken by you as to your employees, or other workers on your premises during the installment, repair or removal of products containing asbestos. If any such safety measures were taken, state: (a) or clothing; The reason for the use of such measures, equipment (b) Identify each document relating to safety procedures taken by such employee or workers; (c) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information. RESPONSE: Not applicable. INTERROGATORY NO. 83: Describe in detail all written and oral reports including those reports originating from suppliers of any of the products identified in answer to Interrogatory No. 72, including doctors, and employees and agents of the suppliers concerning any relationship between the use of or proximity to the use of these products and the development of asbestos related illnesses in humans or animals: (a) Identify all persons making said reports and to whom said reports were made; (b) State whether any report or series of reports initiated changes and/or re-evaluation of the use, or recommendations for use, of any of those products; (c) Identify each document which refers or relates to any information set forth in answer to this interrogatory; (d) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: Not applicable. 126 INTERROGATORY NO. 84: For each product identified in answer to Interrogatory No. 72, state whether the product has been removed from ahy or all premises and equipment owned by answering defendant, and, if so: (a) State when it was removed; (b) state with specificity and particularity all the reasons for the removal; (c) Identify each individual who participated in the decision to remove said product and describe in detail the extent of his participation; (d) Identify all documents which reflect, refer or relate to each such discontinuance; (e) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. RESPONSE: Not applicable. INTERROGATORY NO. 85: For each product identified in answer to Interrogatory No. 72, state whether the use of that product in any or all of your premises has been limited and/or curtailed, reduced or discontinued and, if so: reduced; (a) Describe how it was so limited or curtailed or (b) State when it was so limited, curtailed or reduced; (c) State with specificity and particularity all of the reasons for the limitation, curtailment, or reduction; (d) Identify each individual who participated and the extent of his participation in the decision to so limit, curtail or reduce production and/or sale; (e) Identify each document which reflects, refers or relates to the limitation, curtailment or reduction and/or the decision to implement the limitation, curtailment or reduction; this (f) As to any information received orally in answer to interrogatory, identify each person who supplied such 127 information and state the full substance of the information supplied. RESPONSE: Not applicable. INTERROGATORY NO. 86: Identify the living parties or persons who are the most knowledgeable about the installation, repair or removal of asbestos products on your premises during the relevant dates: RESPONSE: Not applicable. INTERROGATORY NO. 87: State what person, entity or firm determining whether asbestos containing installed, repaired or removed from your relevant dates. was responsible products would premises during for be the RESPONSE: Not applicable. SECTION III INTERROGATORIES DIRECTED TO ALL RAILROAD DEFENDANTS INTERROGATORY NO. 88: (a) Identify the dates of all sales of asbestos-containing products by answering defendant (or its alleged corporate predecessors as set forth in plaintiffs' complaints) to the railroad defendants in these cases (Amtrack, Penn Central Transportation Company and the Pennsylvania Railroad). (b) Identify all documents concerning such sales to these railroads. RESPONSE: Defendant objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome and impossible to answer in light of the number of products sold and the length of time over which they were sold. Without waiver of or prejudice to this foregoing objection, the Fund will produce.responsive documents at 128 the records repository maintained by the Trust in Denver, Colorado at a time convenient to the parties. In addition to the documents which will be specifically identified and produced at that time, there may be additional documents responsive to this Interrogatory among the general collection of documents in the repository. See Response to Interrogatory No. 1. INTERROGATORY NO. 89: Identify all documents concerning sale of asbestos-containing products by answering defendant to the railroad defendants and their predecessors to the railroad defendants: (a) Wilmington, Delaware railroad shops; (b) Philadelphia, Pennsylvania, railroad shops; RESPONSE: See Response to Interrogatory No. 88. INTERROGATORY NO. 90: (a) Describe below in detail each and every asbestoscontaining product sold or manufactured by answering defendant or its alleged corporate predecessors as set forth in plaintiffs' complaints. (b) Describe all similar products that were non-asbestoscontaining. RESPONSE: Asbestos containing products manufactured by Manville Corporation or related entities which may have been used in the railroad industry are listed below: MANVILLE CORPORATION OR RELATED ENTITIES RAILROAD INDUSTRY ASBESTOS-CONTAINING PRODUCTS Anti-Sweat Sectional Pipe Insulation Asbesto-Metallic Friction Blocks Asbesto-Sponge Felted Sectional Pipe Insulation Asbesto-Sponge Felted Train Pipe Insulation Asbesto-Sponge Felted Sheets and Blocks 129 Asbestocel Asbestocel Fine Corrugated Asbestocel Sectional Pipe Insulation Asbestocel Sheets and Blocks Asbestoment (Fireproof Cable Insulation) AsbestoSide (Exterior Wall Siding) Asbestos Clothing Asbestos Combination Spiral Pipe Insulation Asbestos Cord Asbestos Fibrous Enamel Asbestos Fire-Felt Sectional Pipe Insulation Asbestos Fire-Felt Sheets and Blocks Asbestos Flexible Steam Pipe Asbestos Paper and Roll Board Asbestos Protected Metal Roofing and Siding Asbestos Roll Fire-Felt Asbestos Roof Putty Asbestos Rope Packing (Twisted and Braided) Asbestos Wick Packing Barge Roofing Brake Band Lining (Industrial) Ceilinite (Steel Passenger Car Insulation) Cement No. 302 (Fire Felt Insulating) Cement No. 400 Cement - Fireite Asbestos Furnace Cement Colorblende Asbestos Shingles 130 Ebony Asbestos Wood 85% Mag sectional Pipe Insulation 85% Mag Blocks 85% Mag Locomotive Boiler & Air Pump Lagging Flexstone Asbestos Roofing Jewett Ring Packings Jomanco (Friction Tape) Kearsarge (all products including gaskets) Keystone Air Pump Packing Keystone Hair Insulator Lead Joint Runner Locomotive CabCock Packing Locomotive Cab Roofing Millboard (Sheet) Mobilene Sheet Packing (Style #101) Mogul Coil Packing Moulded Air Pump Packing Niagrite (Fireproof Cable Insulation) Nycinsul (Steel Passenger Car Insulation) Phoenix Asbestos Stove Lining Referite Salamander (Steel Passenger Car Insulation) Sea Rings Service Sheet Packing (Style #60) Sill Covering Slater's Felt 131 Special Combination Air Pump Packing Standard Asbestos Shingles Thermo Fire-Felt Sheets & Blocks Transite Transite Asbestos Wood (Smoke Jacks/Stacks & Caps/Ventilators) Universal Combination Steam Hammer Packings Universal Piston Packings Universal Rod & Plunger Packings Vitro Fire-Felt Sheets & Blocks Vitribestos Sheets & Blocks Water Gauge Gaskets Waterproofing Felt (#50) Asbestos free products manufactured by Manville Corporation Or related entities which may have been used in the railroad industry are listed below: MANVILLE CORPORATION OR RELATED ENTITIES RAILROAD INDUSTRY NON-ASBESTOS-CONTAINING PRODUCTS Asphalt Roofing Cement Built-up Brine and Ammonia Insulation Cold Water Paint Duplex Rod & Plunger Packing Hairinsul (Refrigerator Car Insulation) Junior Trap Liberty Red Rubber Sheet Packing (Styles #107, #108) Orangeburg Fibre Conduit Pilot Brand Roofing Piston Packing (Power Reverse Gear) 132 Exhibit "AM Manville Asbestos Containing Thermal Insulation or Shipyard Products Product Name: #12 Asbestos Paper Tape Product Type: Paper Fiber Type: Chrysotile % Fiber by Weight: 95.0 Date Manufactured: Date Discontinued: 1936 1980 Date Labeled: None Product Name: 15A Asbestos Jacket Product Type: Paper, Felt Fiber Type: Chrysotile % Fiber by Weight: 50.0 - 57.0 Date Manufactured: Date Discontinued: 1931 1980 Date Labeled: None Product Name: 45A Asbestos Jacket Product Type: Felt, Blankets Fiber Type: Chrysotile % Fiber by Weight: 50.0 Date Manufactured: 1931 Date Discontinued: 1980 Date Labeled: None Product Name: #50 Asbestos Weatherproofing Felt Product Type: Fiber Type: Paper, Felt, Blankets Chrysotile % Fiber by Weight: 50.0-55.0 Date Manufactured: Date Discontinued: 1923 1976 Date Labeled: 1970 Product Name: 55 Cable Fireproofing Tape Product Type: Fiber Type: Tape Chrysotile % Fiber by Weight: 72.0 Date Manufactured: Date Discontinued: 1956 1982 Date Labeled: 1 Product Name: 85% Magnesia Product Type: Block, Pipe Insulation Fiber Type: Chrysotile and/or Amosite % Fiber by Weight: 7,3 - 15.0 Date Manufactured: 1902 Date Discontinued: 1970 Date Labeled: 1964 Product Name: 85% Magnesia Cement Product Type: Cement Fiber Type: Chrysotile and/or Amosite % Fiber by Weight: 7.3-15.0 Date Manufactured: 1902 Date Discontinued: 1970 Date Labeled: 1965 Product Name: 88 Cloth (Coated) Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 58.0 Date Manufactured: Date Discontinued: 1960 1983 Date Labeled: None Product Name: 89 Cloth (Coated) Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 58.0 Date Manufactured: Date Discontinued: 1955 1983 Date Labeled: None Product Name: 91 Cloth (Coated) Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 61; 0 Date Manufactured: Date Discontinued: 1957 1983 Date Labeled: None Product Name: 95 (1/16) Cloth Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 32.0 Date Manufactured: 1942 Date Discontinued: 1983 Date Labeled: None (Coated) 2 Product Name: 95 (1/8) Cloth Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 19.0 Date Manufactured: 1942 Date Discontinued: 1983 Date Labeled: None (Coated) Product Name: 96 (1/16) Cloth Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 25.0 Date Manufactured: 1942 Date Discontinued: 1983 Date Labeled: None (Coated) Product Name: 96 (1/8) Cloth Product Type: Fiber Type: Cloth Chrysotile % Fiber by Weight: 18.0 Date Manufactured: Date Discontinued: 1942 1983 Date Labeled: None (Coated) Product Name: 101 (1/32, Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 45.0 Date Manufactured: 1903 Date Discontinued: 1983 Date Labeled: None 3/32) Cloth (Coated) Product Name: 101 (1/16, Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 39.0 Date Manufactured: 1903 Date Discontinued: 1983 Date Labeled: None 1/4) Cloth (Coated) Product Name: 101 Asbestos Millboard Product Type: Sheet Fiber Type: Chrysotile % Fiber by Weight: 69.2 -^78.5 Date Manufactured: 1910 (Hard) 3 Date Discontinued: 1951 Date Labeled: None Product Name: 102 Asbestos Millboard Product Type: Fiber Type: Sheet Chrysotile % Fiber by Weight: 75.0 - 86.6 Date Manufactured: Date Discontinued: 1910 1980 Date Labeled: 1970 (Medium) Product Name: 103 Asbestos Millboard Product Type: Fiber Type: Sheet Chrysotile % Fiber by Weight: 76.0 - 90.0 Date Manufactured: 1910 Date Discontinued: 1951 Date Labeled: None (Soft) Product Name: 104 Asbestos Millboard Product Type: Sheet Fiber Type: Chrysotile % Fiber by Weight: 92.8 Date Manufactured: 1915 Date Discontinued: 1951 Date Labeled: None Product Name: 105 Asbestos Millboard Product Type: Sheet Fiber Type: Chrysotile % Fiber by Weight: 77.0-92.8 Date Manufactured: 1915 Date Discontinued: 1951 Date Labeled: None Product Name: 106 Asbestos Millboard Product Type: Fiber Type: Sheet Chrysotile % Fiber by Weight: 70.0 - 91.2 Date Manufactured: Date Discontinued: 1918 1980 Date Labeled: 1970 Product Name: Product Type: Fiber Type: 106B Asbestos Millboard Sheet Chrysotile 4 % Fiber by Weight: 95.0 Date Manufactured: Date Discontinued: 1918 1980 Date Labeled: 1970 Product Name: 106H Asbestos Millboard Product Type: Fiber Type: Sheet Chrysotile % Fiber by Weight: 87.0 - 88.0 Date Manufactured: Date Discontinued: 1918 1980 Date Labeled: 1970 Product Name: 135 Tadpole Gasketing Tape Product Type: Fiber Type: Tape % Fiber by Weight: 36.0 Date Manufactured: 1948 Date Discontinued: 1982 Date Labeled: None Product Name: 135-S Tadpole Gasketing Tape Product Type: Tape Fiber Type: % Fiber by Weight: 36.0 Date Manufactured: 1948 Date Discontinued: 1982 Date Labeled: None Product Name: 219 Asbestos Millboard Product Type: Fiber Type: Sheet Chrysotile % Fiber by Weight: 84.0 - 86.8 Date Manufactured: Date Discontinued: 1918 1980 Date Labeled: 1970 Product Name: 300 Cement Product Type: Fiber Type: Cement Chrysotile % Fiber by Weight: 100.0 Date Manufactured: Date Discontinued: 1932 1970 Date Labeled: None Product Name: 301 Cement 5 Product Type: Fiber Type: Cement Chrysotile % Fiber by Weight: 14.7 - 18.8 Date Manufactured: Date Discontinued: 1925 1971 q Date Labeled: 1965 Product Name: 302 Cement (Originally called Asbestos Cement Felting; later known as Fire Felt Insulating Cement) Product Type: Fiber Type: Cement Chrysotile % Fiber by Weight: 49.4 - 70.0 Date Manufactured: Date Discontinued: 1858 1970 Date Labeled: 1965 Product Name: 304 Cement (Asbestos Hot Blast Cement) Product Type: Fiber Type: Cement Chrysotile % Fiber by Weight: 50.0 - 53.4 Date Manufactured: Date Discontinued: 1884 1969 Date Labeled: 1965 Product Name: 319 Semi-Refractory Cement Product Type: Cement Fiber Type: Chrysotile % Fiber by Weight: 20.0 - 21.0 Date Manufactured: 1925 Date Discontinued: 1969 Date Labeled: 1965 Product Name: 320 Cement Product Type: Fiber Type: Cement Unknown (Probably Chrysotile) % Fiber by Weight: Date Manufactured: Date Discontinued: Date Labeled: None Product Name: 329 Cement Product Type: Fiber Type: Cement % Fiber by Weight: Date Manufactured: Date Discontinued: 1890 1915 - 1920 Date Labeled: None 6 Product Name: 340 Cement Product Type:o Cement Fiber Type: Chrysotile % Fiber by Weight: 60.0 Date Manufactured: 1908 Date Discontinued: 1969 Date Labeled: None Product Name: 0352 Cement Product Type: Cement Fiber Type: Chrysotile % Fiber by Weight: 25.0 - 40.0 Date Manufactured: Date Discontinued: 1931 1969 Date Labeled: 1965 Product Name: 352 Cement Product Type: Cement Fiber Type: Chrysotile % Fiber by Weight: 100.0 Date Manufactured: 1923 Date Discontinued: 1973 Date Labeled': 1965 Product Name: Product Type: Fiber Type: 364 Cement Cement Chrysotile % Fiber by Weight: 50.0 - 60.0 Date Manufactured: Date Discontinued: 1908 1955 Date Labeled: None Product Name: 400 Cement Product Type: Cement Fiber Type: Chrysotile % Fiber by Weight: 21.6 - 23.0 Date Manufactured: 1915 Date Discontinued: 1969 Date Labeled: 1965 Product Name: 450 Cement Product Type: Cement Fiber Type: Chrysotile % Fiber by Weight: 7.1 - Date Manufactured: 1930 38.5 7 Date Discontinued: 1971 Date Labeled: 1965 Product Name: 500 Cement Product Type: Fiber Type: Cement Chrysotile % Fiber.by Weight: 16.7 - Date Manufactured: 1933 Date Discontinued: 1971 Date Labeled: 1965 20.0 Product Name: 678 Semi-Refractory Cement Product Type: Fiber Type: Cement Chrysotile and/or Amosite % Fiber by Weight: 20.0 - 35.0 Date Manufactured: 1941 Date Discontinued: 1969 Date Labeled: 1965 Product Name: 7700 Coated Asbestos Jacket Product Type: Fiber Type: Felt Chrysotile % Fiber by Weight: 24.0 - 26.0 Date Manufactured: 1931 Date Discontinued: 1983 Date Labeled: None Product Name: AAAA Grade Product Type: Fiber Type: Rope Chrysotile % Fiber by Weight: 99.0 - 100.0 Date Manufactured: Date Discontinued: 1884 1983 Date Labeled: 1972 Product Name: AAAA Grade Asbestos Cloth Product Type: Fiber Type: Cloth Chrysotile % Fiber by Weight: 99.0 - 100.0 Date Manufactured: Date Discontinued: 1884 1970 Date Labeled: None Product Name Product Type Fiber Type: AAAA Grade Asbestos Tape Tape Chrysotile 8 % Fiber by Weight: 99.0 - 100.0 Date Manufactured: 1884 Date Discontinued: 1983 Date Labeled: 1972 Product Name: AAA Grade (788, 857, Product Type: Fiber Type: Rope Chrysotile % Fiber by Weight: 95.0 - 99..0 Date Manufactured: Date Discontinued: 1884 1982 Date Labeled: 1972 869, 873) Product Name: AAA Grade Asbestos Cloth Product Type: Fiber Type: Cloth Chrysotile % Fiber by Weight: 95.0 - 99.0 Date Manufactured: 1884 Date Discontinued: 1974 Date Labeled: 1972 Product Name: AAA Grade Asbestos Tape Product Type: Tape Fiber Type: Chrysotile % Fiber by Weight: 95.0 - 99.0 Date Manufactured: Date Discontinued: 1884 1983 Date Labeled: 1972 Product Name: AAA Grade Asbestos Tubing Product Type: Fiber Type: Tubing (Braided) Chrysotile % Fiber by Weight: 95.0 - 99.0 Date Manufactured: Date Discontinued: 1884 1982 Date Labeled: 1972 Product Name: AA Grade Asbestos Cloth Product Type: Fiber Type: Cloth Chrysotile % Fiber by Weight: 90.0 - 95.0 Date Manufactured: 1884 Date Discontinued: 1974 Date Labeled: 1972 Product Name: AA Grade Asbestos Tape 9 Product Type: Tape Fiber Type: Chrysotile % Fiber by Weight: 90.0 - 95.0 Date Manufactured: 1884 Date Discontinued: 1983 Date Labeled: 1972 Product Name: AA Grade Asbestos Tubing Product Type:, Tubing (Braided) Fiber Type: Chrysotile % Fiber by Weight: 90.0 - 95.0 Date Manufactured: 1884 Date Discontinued: 1982 Date Labeled: 1972 Product Name: A Grade Asbestos Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 85.0 - 90.0 Date Manufactured: 1884 Date Discontinued: 1974 Date Labeled: 1972 Cloth Product Name: A Grade Asbestos Tubing Product Type: Tubing (Braided) Fiber Type: Chrysotile % Fiber by Weight: 85.0 - 90.0 Date Manufactured: Date Discontinued: 1884 1982 Date Labeled: 1972 Product Name: Product Type: AERTITE Finishes Fiber Type: Chrysotile % Fiber by Weight: 14.7 - Date Manufactured: Date Discontinued: 1920 1982 Date Labeled: None 18.0 Product Name: Air-Cell (Generic name for ASBESTOCEL) Product Type: Sheet/Block, Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: 52.6 - 98.0 Date Manufactured: Date Discontinued: 1908 1915 - 1920 Date Labeled: None 10 Product Name: ALBASEAL Product Type: Fiber Type: Sealing Compound Chrysotile % Fiber by Weight: 40.0 Date Manufactured: Date Discontinued: 1953 1975 Date Labeled: None Product Name: ANTI-SWEAT Product Type: Sheet/Block, Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: up to 72.0 Date Manufactured: 1903 Date Discontinued: 1965 Date Labeled: None Product Name: ARMATURO Asbestos Paper Product Type: Fiber Type: Paper Chrysotile % Fiber by Weight: 84.0-97.0 Date Manufactured: 1920-1924 Date Discontinued: Approximately 1980 Date Labeled: 1970 (Insulating Jacket) Product Name: ARP-40 (Insulating Jacket) Product Type: Fiber Type: Paper Chrysotile % Fiber by Weight: 60.0 Date Manufactured: Date Discontinued: 1963 1971 - 1975 Date Labeled: Unknown Product Name: Asbestica Tape Product Type: Tape Fiber Type: Chrysotile % Fiber by Weight: 80.0 - 85.0 Date Manufactured: Date Discontinued: 1948 1982 Date Labeled: Product Name: ASBESTILE Cement Product Type: Fiber Type: Cement Chrysotile % Fiber by Weight: 8.2 - 21.8 Date Manufactured: Date Discontinued: 1930 1982 11 Date Labeled: None Product Name: ASBESTOCEL Product Type: Sheet/Block, Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: 52.6 - 98.0 Date Manufactured: 1902 Date Discontinued: 1971 - 1975 Date Labeled: Product Name: ASBESTOCEL Paper Product Type: Paper Fiber Type: Chrysotile % Fiber by Weight: 52.6 - 98.0 Date Manufactured: Date Discontinued: 1902 1924 - 1931 Date Labeled: None Product Name: ASBESTOCITE Product Type: Fiber Type: Board Chrysotile % Fiber by Weight: 33.0 - 45.0 Date Manufactured: Date Discontinued: 1927 1975 Date Labeled: 1970 Product Name: ASBESTOMENT Product Type: Fiber Type: Cement Chrysotile % Fiber by Weight: 6.0 Date Manufactured: Date Discontinued: 1923 1970 Date Labeled: None Product Name: Asbestos Air Chamber Covering Product Type: Pipe Insulation Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not Available Date Manufactured: 1880 Date Discontinued: 1893 - 1895 Date Labeled: None Product Name: Asbestos and Hair Felt Removable Covering Product Type: Pipe Insulation Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available 12 Date Manufactured: 1891 Date Discontinued: 1896 - 1900 Date Labeled: None Product Name: Asbestos and Hair Woven Felt (Originally called Asbestos and Hair Lagging) Product Type: Paper, Felt, Blankets Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1884 Date Discontinued: 1890 Date Labeled: None Product Name: Asbestos Combination Spiral Pipe Product Type: Pipe Insulation Fiber Type:. Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1931 Date Discontinued: 1934 - 1936 Date Labeled: None Insulation Product Name: Asbestos Corded Sheathing Product Type: Fiber Type: Paper, Felt, Blankets Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1887 Date Discontinued: 1896 - 1900 Date Labeled: None Product Name: ASBESTOS EBONY Product Type: Board Fiber Type: Chrysotile % Fiber by Weight: 47.0 - 75.0 Date Manufactured: 1911 Date Discontinued: 1984 - 1985 Date Labeled: Product Name: Asbestos Felt Product Type: Fiber Type: Felt Chrysotile % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1890 1890 - 1891 Date Labeled: None Product Name: Asbestos FIRE FELT 13 Product Type: Felt Fiber Type: Chrysotile % Fiber by Weight: 61.0 - 98.0 Date Manufactured: 1891 Date Discontinued: 1971 - 1975 Date Labeled: Product Name: Asbestos FIRE FELT Product Type: Sheet/ Block Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: 1903 Date Discontinued: 1971 - 1975 Date Labeled: Product Name: Asbestos Fire Felt Covering Product Type: Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: 41.0 - 61.5 Date Manufactured: Date Discontinued: 1891 1971 - 1975 Date Labeled: Product Name: Asbestos Fire Felt Locomotive Lagging Product Type: Sheet/ Block Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: 1900 Date Discontinued: 1903 - 1906 Date Labeled: None Product Name: Asbestos FIRETARD Product Type: Fiber Type: Blankets Chrysotile % Fiber by Weight: 88.9 - 92.0 Date Manufactured: 1931 Date Discontinued: 1980 Date Labeled: 1970 Product Name: Asbestos Hair Felt Covering Product Type: Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1908 1911 - 1915 Date Labeled: None 14 Product Name: Asbestos Jelly Rolls Product Type: Fiber Type: Blankets Chrysotile % Fiber by Weight: 90.0 Date Manufactured: 1930 Date Discontinued: 1968 Date Labeled: None Product Name: Asbestos Lining and Deadening Felt Product Type: Fiber Type: Paper, Felt, Blankets Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1900 1903 - 1906 Date Labeled: None Product Name: Asbestos Lining Felt Product Type: Paper, Felt, Blankets Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1871 - 1877 Date Discontinued: .1900 Date Labeled: None Product Name: Asbestos Locomotive Lagging (Originally called Asbestos Lagging) Product Type: Paper, Felt, Blankets Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1884 Date Discontinued: 1900 Date Labeled: None Product Name: Asbestos Millboard (In Hard, Medium and Soft Grades) Product Type: Sheet Fiber Type: % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1896 1910 Date Labeled: None Product Name: Asbestos Millboard Board) Product Type: Sheet Fiber Type: Chrysotile % Fiber by Weight: Not available (Originally called Asbestos 15 Date Manufactured: Date Discontinued: 1871 - 1875 1896 Date Labeled: None Product Name: Asbestos Molded Blocks Product Type: Fiber Type: Block Chrysotile % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1900 1915 - 1920 Date Labeled: None Product Name: Asbestos Moulded Sectional Product Type: Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1891 1915 - 1920 Date Labeled: None Covering Product Name: Asbestos "Navy Brand" Product Type: Sheet/Block Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: 1902 Date Discontinued: 1915 - 1925 Date Labeled: None FIRE FELT Product Name: Asbestos "Navy Brand" Product Type: Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: 1902 Date Discontinued: 1915-1925 Date Labeled: None FIRE FELT Covering Product Name: Asbestos Pipe Blanket Product Type: Fiber Type: Blankets Chrysotile and/or Amosite % Fiber by Weight: 98.0 - 99.0 Date Manufactured: Date Discontinued: 1898 1960 Date Labeled: None Product Name: Product Type: Asbestos Roll FIRE FELT Felt, Blankets 16 Fiber Type: Chrysotile % Fiber by Weight: 91.0 - Date Manufactured: 1891 Date Discontinued: 1980 Date Labeled: 1970 99.0 Product Name: Asbestos Sectional Covering Product Type: Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: 1888 Date Discontinued: 1890 Date Labeled: None Product Name: Asbestos Sheathing Product Type: Fiber Type: Sheet Unknown (Probably Chrysotile) % Fiber by Weight: Not Available Date Manufactured: Date Discontinued: 1869 Date Labeled: Product Name: Asbestos Sponge Hair Felt Product Type: Fiber Type: Felt Chrysotile % Fiber by Weight: Not available Date Manufactured: 1893 Date Discontinued: 1900 - 1903 Date Labeled: None Product Name: Asbestos Sponge Felt Product Type: Fiber Type: Felt Chrysotile % Fiber by Weight: 68.0 - 96.2 Date Manufactured: 1890 Date Discontinued: 1961 Date Labeled: None Product Name: Product Type: Asbestos Sponge (Felted, Sectional, Sheet/Block, Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1890 1953 - 1959 Date Labeled: None Molded) 17 Product Name: Asbestos Steam Packing Product Type: Fiber Type: Rope % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1871 Date Labeled: Product Name: Asbestos Turbine Blanket Product Type: Fiber Type: Paper, Felt, Blankets Amosite % Fiber by Weight: 98.0 - 99.0 Date Manufactured: Date Discontinued: 1951 1977 Date Labeled: 1971 Product Name: Besto-Tak Product Type: Tape Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: 75.0 - 100.0 Date Manufactured: 1959 - 1963 Date Discontinued: 1975 - 1978 Date Labeled: 1972 Product Name: Body Sealer Product Type: Sealing Compound Fiber Type: Chrysotile % Fiber by Weight: 37.0 - 41.0 Date Manufactured: 1954 Date Discontinued: 1975 Date Labeled: None Product Name: BRANCHTITE Product Type: Sealing Compound Fiber Type: Chrysotile % Fiber by Weight: 50.0 Date Manufactured: 1954 Date Discontinued: 1974 Date Labeled: None Product Name: C Asbestos Millboard Product Type: Fiber Type: Sheet Chrysotile % Fiber by Weight: 60.2 - 67.6 Date Manufactured: Date Discontinued: 1918 1980 Date Labeled: 1970 18 Product Name: CEILINITE Product Type: Fiber Type: Felt Chrysotile % Fiber by Weight: 50.0 - 98.0 Date Manufactured: Date Discontinued: 1910 1973 Date Labeled: 1970 Product Name: CELLAMITE Product Type: Fiber Type: Felt Chrysotile % Fiber by Weight: Date Manufactured: Date Discontinued: 1939 1959 - Date Labeled: None 1947 1963 Product Name: CHAMPION Sectional Covering Product Type: Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: up to 59.0 Date Manufactured: Date Discontinued: Date Labeled: Product Name: Commercial Grade Product Type: Fiber Type: Rope Chrysotile % Fiber by Weight: 75.0-80.0 Date Manufactured: 1884 Date Discontinued: 1982 Date Labeled: 1972 (566, 702, 733, 787) Product Name: Commercial Grade Asbestos Cloth Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 75.0 - 80.0 Date Manufactured: Date Discontinued: 1884 1982 Date Labeled: 1972 Product Name: Commercial Grade Asbestos Paper Product Type: Fiber Type: Paper Chrysotile % Fiber by Weight: 95.0 Date Manufactured: 1929 19 Date Discontinued: 1980 Date Labeled: 1970 Product Name: Commercial Grade Asbestos Tape Product Type: Tape Fiber Type: Chrysotile % Fiber by Weight: 75.0 - 80.0 Date Manufactured: 1884 Date Discontinued: 1982 Date Labeled: 1970 Product Name: Commercial Grade Asbestos Tubing Product Type: Tubing (Braided) Fiber Type: Chrysotile % Fiber by Weight: 75.0 - 80.0 Date Manufactured: 1884 Date Discontinued: 1982 Date Labeled: 1972 Product Name: D.C. FLEXSTONE Product Type: Felt Fiber Type: Chrysotile % Fiber by Weight: 30.0 - 85.0 Date Manufactured: 1929 Date Discontinued: Approximately Date Labeled: 1970 1980 Product Name: DEKERAN Product Type: Board Fiber Type: Chrysotile % Fiber by Weight: 29.6 - 34.6 Date Manufactured: 1963 Date Discontinued: 1975 Date Labeled: 1970 Product Name: DOUBLEX Asbestos Paper Product Type: Paper Fiber Type: Chrysotile % Fiber by Weight: 80.0 Date Manufactured: 1936 Date Discontinued: Approximately 1980 Date Labeled: 1970 Product Name Product Type Fiber Type: DUXSEAL Sealing Compound Chrysotile 20 % Fiber by Weight: 52.5 - 69.0 Date Manufactured: Date Discontinued: 1934 1982 - Asbestos Content Date Labeled: None Product Name: Engineers Insulating Tape Product Type: Fiber Type: Blankets Chrysotile % Fiber by Weight: Not available Date Manufactured: 1926 Date Discontinued: 1956 Date Labeled: None Product Name: EQUALITY Product Type: Sheet/Block Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1908 Date Discontinued: 1908 - 1911 Date Labeled: None Product Name: EUREKA Covering Product Type: Pipe Insulation Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1903 Date Discontinued: 1915 - 1920 Date Labeled: None Product Name: EXPRESS Covering Insulation) Product Type: Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: up to 59.0 Date Manufactured: Date Discontinued: Date Labeled: (See Wool Felt Sectional Pipe Product Name: FIBROFIL Product Type: Fiber Type: Cement Chrysotile % Fiber by Weight: 30.0 Date Manufactured: Date Discontinued: 1940 1969 Date Labeled: None 21 Product Name: FIBROID Asbestos Paper Product Type: Fiber Type: Paper Chrysotile % Fiber by Weight: 95.0 Date Manufactured: Date Discontinued: 1911 Approximately 1980 Date Labeled: 1970 Product Name: Fibrous Adhesive Product Type: Fiber Type: Cement Chrysotile % Fiber by Weight: 14.0 - 20.0 Date Manufactured: Date Discontinued: 1887 1981 - Asbestos Content Date Labeled: None Product Name: FIL-INSUL Product Type: Fiber Type: Cement Chrysotile and/or Amosite % Fiber by Weight: 70.0 - 80.0 Date Manufactured: 1930 Date Discontinued: 1969 Date Labeled: None Product Name: Fine Corrugated ASBESTOCEL Product Type: Sheet/Block, Pipe Insulation Fiber Type: Chrysotile % Fiber by Weight: 52.6 - 98.0 Date Manufactured: 1923 Date Discontinued: 1971 - 1975 Date Labeled: Product Name: FIREITE Furnace Cement Product Type: Cement Fiber Type: Chrysotile % Fiber by Weight: 1.8 - 3.7 Date Manufactured: 1924 Date Discontinued: 1973 Date Labeled: None Product Name: Flat TRANSITE Product Type: Fiber Type: Board Chrysotile and/or Amosite % Fiber by Weight: 22.0 - 69.2 Date Manufactured: Date Discontinued: 1907 1985 Date Labeled: 1970 22 Product Name: FLEXBOARD Product Type: Board Fiber Type: Chrysotile % Fiber by Weight: 33.0 - Date Manufactured: 1927 Date Discontinued: 1983 Date Labeled: 1970 50.0 Product Name: Flexible MIN-K Product Type: Sheet Fiber Type: Amosite % Fiber by Weight: 20.0 Date Manufactured: 1963 Date Discontinued: 1975 Date Labeled: 1970 Product Name: Heat Treating Cement Product Type: Cement Fiber Type: Chrysotile and/or Amosite % Fiber by Weight: 1.0 Date Manufactured: 1954 Date Discontinued: 1973 Date Labeled: None Product Name: High Strength FIBROID Asbestos Paper Product Type: Fiber Type: Paper Chrysotile % Fiber by Weight: 85.7 - 88.0 Date Manufactured: 1930 Date Discontinued: Approximately 1980 Date Labeled: 1970 Product Name: High Temperature Flexible MIN-K Blankets Product Type: Blankets Fiber Type: Amosite % Fiber by Weight: 20.0 Date Manufactured: Date Discontinued: 1963 1974 Date Labeled: 1970 Product Name: High Temperature Insulation Product Type: Block, Pipe Covering Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1924 23 Date Discontinued: 1926 Date Labeled: None Product Name: HF-NAVASEAL Product Type: Sealing Compound Fiber Type: Chrysotile % Fiber by Weight: 27.0 Date Manufactured: 1955 Date Discontinued: 1975 Date Labeled: . None Product Name: H-NAVASEAL Product Type: Sealing Compound Fiber Type: Chrysotile % Fiber by Weight: 48.0 Date Manufactured: 1951 Date Discontinued: 1975 Date Labeled: None Product Name: INDENTED Product Type: Pipe Insulation Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1908 Date Discontinued: 1924 Date Labeled: None Product Name: Industrial Vent Caulking Product Type: Sealing Compound Fiber Type: Chrysotile % Fiber by Weight: 53.0 Date Manufactured: 1957 Date Discontinued: 1974 Date Labeled: None Product Name: INSULKOTE ET Product Type: Finishes Fiber Type: Chrysotile % Fiber by Weight: 11.7 - 15.5 Date Manufactured: Date Discontinued: 1929 1982 Date Labeled: None Product Name: Product Type: Fiber Type: INSULKOTE SG Finishes Chrysotile 24 % Fiber by Weight: 14.7 - 16.7 Date Manufactured: 1929 Date Discontinued: 1982 Date Labeled: None Product Name: INSULKOTE ST Product Type: Finishes Fiber Type: Chrysotile % Fiber by Weight: 6.2 - 21.0 Date Manufactured: Date Discontinued: 1929 1982 Date Labeled: None Product Name: LAPTITE Product Type: Cement Fiber Type: Chrysotile % Fiber by Weight: 10.0 - Date Manufactured: 1938 Date Discontinued: 1954 Date Labeled: None 16.9 Product Name: Long Fiber Asbestos Paper Product Type: Fiber Type: Paper Chrysotile % Fiber by Weight: 88.0 - 98.5 Date Manufactured: 1930 Date Discontinued: Approximately 1980 Date Labeled: 1970 Product Name: MAGNO Product Type: Fiber Type: Sheet/Block Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1908 1908 - 1911 Date Labeled: None Product Name: MARIMET 45 Product Type: Fiber Type: Board Amosite % Fiber by Weight: 43.0 - 44.0 Date Manufactured: Date Discontinued: 1970 1985 Date Labeled: 1970 Product Name: MARINITE 25 Product Type: Fiber Type: Board Amosite and/or Chrysotile % Fiber by Weight: 40.0 - 50.0 Date Manufactured: Date Discontinued: 1936 1940 - Asbestos Content Date Labeled: 1970 Product Name: MARINITE 23 Product Type: Fiber Type: Board Amosite % Fiber by Weight: 25.0-27.0 Date Manufactured: Date Discontinued: 1955 1975 - Asbestos Content Date Labeled: 1970 Product Name: MARINITE 30 Product Type: Board Fiber Type: Amosite % Fiber by Weight: 49.7 - Date Manufactured: 1949 Date Discontinued: 1970 Date Labeled: None 50.0 Product Name: MARINITE 36 Product Type: Board Fiber Type: Amosite and/or Chrysotile % Fiber by Weight: 29.7 - 57.0 Date Manufactured: Date Discontinued: 1955 1975 - Asbestos Content Date Labeled: 1970 Product Name: MARINITE 65 Product Type: Fiber Type: Board Chrysotile and/or Amosite % Fiber by Weight: 55.5 - 70.0 Date Manufactured: 1955 Date Discontinued: 1975 - Asbestos Content Date Labeled: 1970 Product Name: Marine Acoustical Unit Product Type: Board Fiber Type: Chrysotile % Fiber by Weight: 33.0 Date Manufactured: 1941 Date Discontinued: 1975-78 Date Labeled: 1970 26 Product Name: Marine Veneer Product Type: Fiber Type: Board Chrysotile % Fiber by Weight: 31.0 - 51.0 Date Manufactured: Date Discontinued: 1938 1985 - Asbestos content Date Labeled: 1970 Product Name: Metal Veneered MARINITE Product Type: Fiber Type: Board Chrysotile and/or Amosite % Fiber by Weight: 15.0 - 40.0 Date Manufactured: 1951 Date Discontinued: 1973 Date Labeled: 1970 Product Name: METAL-ON Product Type: Fiber Type: Jackets Chrysotile and/or Amosite % Fiber by Weight: 7.0 - 14.3 Date Manufactured: 1959 Date Discontinued: 1974 Date Labeled: 1966 Product Name: MICROBESTOS Product Type: Paper Fiber Type: Chrysotile % Fiber by Weight: 40.0 - 97.0 Date Manufactured: 1959 Date Discontinued: Approximately Date Labeled: None 1980 Product Name: MIN-K 500 Product Type: Sheet/Block Fiber Type: Amosite % Fiber by Weight: 5.0 Date Manufactured: Date Discontinued: 1958 1977 Date Labeled: 1970 Product Name: MIN-K 1301 Product Type: Sheet/Block Fiber Type: Amosite % Fiber by Weight: 5.0 - 12.0 Date Manufactured: 1958 Date Discontinued: 1975 27 Date Labeled 1970 Product Name: MIN-K 2000 Product Type: Fiber Type: Sheet/Block Amosite % Fiber by Weight: 5.0 - 12.0 Date Manufactured: Date Discontinued: 1959 1975 Date Labeled: 1970 Product Name: MIN-KLAD Product Type: Blankets Fiber Type: Amosite % Fiber by Weight: 5.0 Date Manufactured: Date Discontinued: 1958 1972 Date Labeled: 1970 Product Name: MOLTEN METAL MARINITE Product Type: Board Fiber Type: Amosite % Fiber by Weight: 38.0 - 40.0 Date Manufactured: 1962 Date Discontinued: 1980 Date Labeled: 1970 Product Name: MX-3808 Asbestos Filler Product Type: Cement Fiber Type: Chrysotile % Fiber by Weight: 52.0 - 55.0 Date Manufactured: Date Discontinued: 1951 1970 Date Labeled: 1965 Product Name: MX 4851 (Aluminized) Product Type: Fiber Type: Cloth Chrysotile % Fiber by Weight: 75.0 Date Manufactured: Date Discontinued: Date Labeled: None Cloth (Coated) Product Name: MX 5184 Cloth Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 65.0 (Coated) 28 Date Manufactured: 1971 Date Discontinued: Date Labeled: None Product Name: MX 5215 Cloth Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 69.0 Date Manufactured: 1971 Date Discontinued: Date Labeled: None (Coated) Product Name: MX 5243 Cloth Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 65.0 Date Manufactured: Date Discontinued: Date Labeled: None (Coated) Product Name: MX 5385 Cloth Product Type: Cloth Fiber Type: Chrysotile % Fiber by Weight: 50.0 Date Manufactured: Date Discontinued: Date Labeled: None (Coated) Product Name: NATIONAL Sectional Covering Product Type: Pipe Insulation Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1891 Date Discontinued: 1900 - 1903 Date Labeled: None Product Name: Product Type: Navy 450 Cement Cement Fiber Type: Chrysotile % Fiber by Weight: 13.5 - 38.5 Date Manufactured: 1941 Date Discontinued: Not Active about Date Labeled: 1965 1972 Product Name: Product Type: NIAGRITE Felt, Blankets 29 Fiber Type: Chrysotile % Fiber by Weight: 98.0 Date Manufactured: Date Discontinued: 1911 1973 Date Labeled: 1970 Product Name: Product Type: NODRSEAL Sealing Compound Fiber Type: Chrysotile % Fiber by Weight: 50.0 - 59.4 Date Manufactured: 1947 Date Discontinued: 1975 Date Labeled: None Product Name: Non-Burn Asbestos Paper Product Type: Paper Fiber Type: Chrysotile % Fiber by Weight: 95.0 - 97.0 Date Manufactured: Date Discontinued: 1900 Approximately 1980 Date Labeled: 1970 Product Name: PALLITE Product Type: Board Fiber Type: Amosite % Fiber by Weight: 50.0 Date Manufactured: 1937 Date Discontinued: 1973 Date Labeled: 1970 Product Name: PERFECTION Pipe Covering Product Type: Pipe Insulation Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1903 1908 - 1911 Date Labeled: None Product Name: REEFERITE Product Type: Board Fiber Type: Chrysotile % Fiber by Weight: 29.0 - 37.0 Date Manufactured: Date Discontinued: 1950 1974 Date Labeled: 1970 30 Product Name: Safety Blow-off Covering Product Type: Pipe Insulation Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: 1903 Date Discontinued: 1915 - 1920 Date Labeled: None Product Name: silicated THERMOBESTOS Product Type: Sheet/Block, Pipe Covering Fiber Type: Chrysotile and/or Amosite % Fiber by Weight: 7.0 - 14.3 Date Manufactured: Date Discontinued: 1966 1974 Date Labeled: 1966 Product Name: SONITE Product Type: Block Fiber Type: Amosite % Fiber by Weight: 5.0 Date Manufactured: 1969 Date Discontinued: 1975 Date Labeled: 1970 Product Name: Standard Flexible MIN-K Blankets Product Type: Paper, Felt, Blankets Fiber Type: Amosite % Fiber by Weight: up to 20.0 Date Manufactured: Date Discontinued: 1963 1974 Date Labeled: 1970 . Product Name: STANDARD Sectional Covering (See Wool Felt Sectional Pipe Insulation) Product Type: Pipe Insulation Fiber Type: % Fiber by Weight: up to 59.0 Date Manufactured: Date Discontinued: Date Labeled: Product Name: Stove Putty Product Type: Sealing Compound Fiber Type: Chrysotile % Fiber by Weight: 15.0 - 25.0 Date Manufactured: Date Discontinued: 1934 1971 31 Date Labeled: None Product Name: Submarine Bulkhead Product Type: Fiber Type: Board % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1963 1967 Date Labeled: None Product Name: Super FIRE FELT Product Type: Sheet/Block, Paper, Felt, Blanket Fiber Type: Chrysotile and/or Amosite % Fiber by Weight: 40.0 - 60.0 Date Manufactured: 1925 Date Discontinued: 1971 - 1975 Date Labeled: Product Name: SUPEREX 1900 Product Type: Fiber Type: Sheet/Block Chrysotile and/or Amosite Fiber by Weight: 10.0 - 12.0 Date Manufactured: 1922 Date Discontinued: 1973 Date Labeled: 1965 Product Name: SUPEREX 2000 Product Type: Fiber Type: Sheet/Block Chrysotile and/or Amosite % Fiber by Weight: 9.0 - 12.0 Date Manufactured: Date Discontinued: 1971 1972 - Asbestos content Date Labeled: 1971 Product Name: SUPEREX Cement Product Type: Cement Fiber Type: Chrysotile and/or Amosite % Fiber by Weight: 8.4 - 15.0 Date Manufactured: 1922 Date Discontinued: 1973 Date Labeled: 1965 Product Name: Superex Cement for Navy Product Type: Cement Fiber Type: Chrysotile and/or Amosite % Fiber by Weight: 7.0 - 20.0 32 Date Manufactured: Date Discontinued: Date Labeled: 1965 1941 1957 Product Name: SUPEREX-M Product Type: Sheet/Block, Pipe Insulation Fiber Type: Chrysotile and/or Amosite % Fiber by Weight: 8.4-15.0 Date Manufactured: 1930 Date Discontinued: 1971 Date Labeled: 1965 Product Name: SUPEREX-SG Product Type: Sheet/Block Fiber Type: Chrysotile and/or Amosite % ?iber by Weight: 10.0 Date Manufactured: 1969 Date Discontinued: 1973 Date Labeled: 1966 Product Name: THERM-O-BESTOS Product Type: Sheet/Block, Pipe Insulation Fiber Type: Chrysotile and/or Amosite % Fiber by Weight: Not available Date Manufactured: 1937 Date Discontinued: 1947 Date Labeled: None Product Name: THERMOBESTOS Product Type: Fiber Type: Block, Pipe Covering Chrysotile and/or Amosite % Fiber by Weight: 7.0 - 14.3 Date Manufactured: Date Discontinued: 1950 1974 Date Labeled: 1964 Product Name: Thermobestos Cement Product Type: Fiber Type: Cement Chrysotile and/or Amosite % Fiber by Weight: 7.0 - 14.3 Date Manufactured: Date Discontinued: 1959 1969 Date Labeled: None Product Name: Product Type: THERMO FELT Felt 33 Fiber Type: Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1931 Date Labeled: Product Name: Thermo FIRE FELT Product Type: Sheet/Block Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1908 1936 Date Labeled: None Product Name: THERMOMAT Product Type: Fiber Type: Felt, Tape Amosite and/or Chrysotile % Fiber by Weight: 49.6 - 96.0 Date Manufactured: 1931 Date Discontinued: 1971 - 1975 Date Labeled: Product Name: Thermomix 700 Product Type: Cement Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: 1966 Date Discontinued: 1970 Date Labeled: 1970 Product Name: Thermomix 720 Product Type: Fiber Type: Cement Chrysotile % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1966 1970 Date Labeled: 1970 Product Name: Thermomix 770 Product Type: Cement Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: 1966 Date Discontinued: 1970 Date Labeled: 1970 34 Product Name: Thermomix 810 Product Type: Fiber Type: Cement Crocidolite % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1966 1970 Date Labeled: 1970 Product Name: Thermo-Pac 500 (Twisted Asbestos Rope Packing) Product Type: Rope Fiber Type: Chrysotile % Fiber by Weight: 75.0 - 80.0 Date Manufactured: 1917 Date Discontinued: 1983 Date Labeled: 1972 Product Name: Thermo-Pac 750 Product Type: Rope Fiber Type: Chrysotile % Fiber by Weight: 95.0 - 98.0 Date Manufactured: 1969 Date Discontinued: 1982 Date Labeled: 1972 Product Name: Thermo-Pac 1000 Product Type: Fiber Type: Rope Chrysotile % Fiber by Weight: 98.0 - 100.0 Date Manufactured: 19.17 Date Discontinued: 1983 Date Labeled: 1972 Product Name: Thermo-Pac Blue Product Type: Fiber Type: Rope Crocidolite % Fiber by Weight: 100.0 Date Manufactured: Date Discontinued: 1917 1973 Date Labeled: 1972 Product Name: THERMOTAPE Product Type: Fiber Type: Tape Chrysotile and/or Araosite % Fiber by Weight: 75.0 - 80.0 Date Manufactured: Date Discontinued: 1951 1971 - 1975 Date Labeled: 35 Product Name: Thermo-Wrap Product Type: Fiber Type: Sheet/Block, Blankets Unknown (Probably Chrysotile) % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1939-1950 1971-1975 Date Labeled: Product Name: THERMOWRAP Product Type: Fiber Type: Blankets Chrysotile and/or Amosite % Fiber by Weight: 90.0 Date Manufactured: Date Discontinued: 1951 1971 - 1975 Date Labeled: Product Name: TRANOSEAL (TRANOLSEAL) Product Type: Sealing Compound Fiber Type: Chrysotile % Fiber by Weight: 38.0-47.1 , Date Manufactured: 1947 Date Discontinued: 1974 Date Labeled: None Product Name: TRANSITE Acoustical Panel Product Type: Board Fiber Type: Chrysotile % Fiber by Weight: 33.0 Date Manufactured: 1937 Date Discontinued: 1974 Date Labeled: 1970 Product Name: TRANSITE Core Plate Product Type: Fiber Type: Board Chrysotile and/or Amosite % Fiber by Weight: 52.0 - 71.0 Date Manufactured: Date Discontinued: 1938 1985 Date Labeled: 1970 Product Name: Type A Asbestos Millboard Product Type: Fiber Type: Sheet Chrysotile % Fiber by Weight: 95.7 - 99.0 Date Manufactured: 1918 36 Date Discontinued: 1980 Date Labeled: 1970 Product Name: Type T NODRSEAL Product Type: Sealing Compound Fiber Type: Chrysotile % Fiber by Weight: 50.0 - 55.0 Date Manufactured: 1954 Date Discontinued: 1975 Date Labeled: None Product Name: Underwriter's Grade Asbestos Cloth Product Type: Fiber Type: Cloth Chrysotile % Fiber by Weight: 80.0 - 85.0 Date Manufactured: Date Discontinued: 1884 1974 Date Labeled: Product Name: Underwriter's Grade Asbestos Tape Product Type: Tape Fiber Type: Chrysotile % Fiber by Weight: 80.0 - 85.0 Date Manufactured: Date Discontinued: 1884 1983 Date Labeled: Product Name: Underwriter's Grade Asbestos Tubing Product Type: Fiber Type: Tubing (Braided) Chrysotile % Fiber by Weight: 80.0 - 85.0 Date Manufactured: Date Discontinued: 1884 1982 Date Labeled: Product Name: UNISEAL Product Type: Fiber Type: Sealing Compound Chrysotile % Fiber by Weight: 53.0 - 59.0 Date Manufactured: Date Discontinued: 1947 1975 Date Labeled: None Product Name Product Type Fiber Type: Unspecified Grade, Cloth Chrysotile Originally Offered 37 % Fiber by Weight: Date Manufactured: Date Discontinued: Date Labeled: 1871 - 1875 Product Name: Veneered MARINITE Product Type: Fiber Type: Board Amosite and/or Chrysotile % Fiber by Weight: 16.0 - 41.0 Date Manufactured: 1955 Date Discontinued: 1975 - Asbestos Content Date Labeled: 1970 Product Name: VITRIBESTOS Product Type: Sheet/Block Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: 1908 Date Discontinued: 1959 Date Labeled: None Product Name: Vitro FIRE FELT Product Type: Sheet/Block Fiber Type: Chrysotile % Fiber by Weight: Not available Date Manufactured: Date Discontinued: 1908 1936 Date Labeled: None Product Name: Welding Paper Product Type: Paper Fiber Type: Chrysotile % Fiber by Weight: 99.0 Date Manufactured: 1930 Date Discontinued: Approximately Date Labeled: 1970 1980 Product Name: White Surface Asbestos Jacket Product Type: Fiber Type: Jacket Chrysotile % Fiber by Weight: 82.0 Date Manufactured: Date Discontinued: 1931 1971 Date Labeled: None Product Name: XXX Asbestos Millboard 38 Product Type: Fiber Type: Sheet Chrysotile % Fiber by Weight: 67.0 - Date Manufactured: Date Discontinued: 1918 1980 Date Labeled: 1970 75.2 39 Radiator Trap Rag-Felt Roofings (Ready-to-Lay) Regal Roof Coating Slatekote Brand Roofing Slip-Type Expander Ring (Air Brake) Standard Hair Felt (Refrigerator Car Insulation) Steam Trap Union Washers Volume Meter Wool Felt Sectional Pipe Insulation Zero Sectional Pipe Insulation See also Response to Interrogatory Nos. 1 and 3. Respectfully submitted Bankl^z Delaware Building 300 Delaware Avenue Suite 800 Wilmington, Delaware 19899 Attorneys for Manville Corporation Asbestos Disease Compensation Fund 133 AFFIDAVIT I, CFOAAlH)t[ re. `f-J , being of full age and first duly sworn, depose and state that I am <?.ouoSSc- of the Manville Corporation Asbestos Disease Compensation Fund, a defendant in this action; that I am authorized to make this affidavit on its behalf; that the matters stated in the foregoing document are not within my personal knowledge; that I am informed that no single official, employee, or former employee of either the Fund or of Manville Corporation has personal knowledge of all such matters; that information contained herein has been compiled at my direction by counsel for the Fund, and the responses are in accordance with the information available to them; and that the answers are true and correct, insofar as it is possible to verify them. Further affiant sayeth naught. Subscribed and sworn to before me this day of P , 1989. NOTA^T PUBLIC My Commission Expires May 14,1994 134 AFFIDAVIT OF MAILING GENERAL SERVICE LIST The undersigned, an employee of Phillips & Snyder, P.A. 300 Bank of Delaware Center, P.0. Box 90, Wilmington, DE 19899 hereby swears that on November 27, 1989, she deposited in the U.S Mail or hand-delivered the attached document(s) addressed to: Andrew G. Ahern, III, Esquire 1701 N. Market Street P.O. Box 248 Wilmington, DE 19899 Charles P. Brandt, Esquire 1020 N. Bancroft Parkway P.O. Box 85 Wilmington, DE 19899 Robert Aulgur, Esquire Whittington & Aulgur Lancaster Pike & Loveville Road Hockessin, DE 19707 David H. Burt, Esquire 1700 Mellon Bank Center 919 Market Street Wilmington, DE 19801 Robert B. Anderson, Esquire Mellon Bank Center P.O. Box 111 Wilmington, DE 19899 James F. Bailey, Jr., Esquire James F. Bailey & Associates 222 Delaware Avenue, Suite 1212 P.O. Box 2034 Wilmington, DE 19899 Douglas B. Catts, Esquire Schmittinger & Rodriguez 414 S. State Street P.O. Box 497 Dover, DE 19903 P. Clarkson Collins, 222 Delaware Avenue P.O. Box 2306 Wilmington, DE 19899 Esquire John D. Balaguef, Esquire Brandywine Gateway Plaza 1300 N. Market Street Wilmington, DE 19801 Philip B. Bartoshesky, Biggs & Battaglia P.O. Box 1489 Mellon Bank Center Wilmington, DE 19899 Esquire Howard M. Berg, Esquire Berg, Bifferato, Cottrell & Tighe One Customs House Square P.O. Box 33 Wilmington, DE 19899 Beverly L. Bove, Esquire Tomar, Seliger, Simonoff, Adourian & 01Brien Mellon Bank Center Suite 1704 Wilmington, DE 19801 Jamea F. Davis, Esquire Hercules, Inc. 8th Floor, Law Dept. Hercules Plaza Wilmington, DE 19894 Kurt Doelze, Esquire 5301 Limestone Road Wilmington, DE 19808 Jeffrey T. Eddy, Esquire Ness, Motley, Loadholt, Richardson & Poole 151 Meeting Street P.O. Box 137 Charleston, SC 29402 John A. Elzufon, Esquire Elzufon & Associates 222 Delaware Avenue P.O. Box 1630 Wilmington, DE 19899 Joseph A. Gabay, Esquire Goldfein & Joseph 222 Delaware Avenue P.0. Box 2206 Wilmington, DE 19899 Robert Goldman, Esquire Tybout, Redfearn, Casarino & Pell 300 Delaware Avenue P.0. Box 2092 Wilmington, DE 19899 Eric L. Grayson, Esquire Stephen D. M. Robinson & Associates Montchanin Mills Building P.O. Box 3993 Wilmington, DE 19807 James S. Green, Esquire Connolly, Bove, Lodge & Hutz 1220 Market Building P.O. BOX 2207 Wilmington, DE 19899 Kathleen D. Hadley, Esquire Suite 212 1300 N. Market Street Wilmington, DE 19801 Richard P. Hannum, Esquire Prickett, Jones, Elliott, Kristol & Schnee 1310 N. King Street P.O. Box 1328 Wilmington, DE 19899 James F. Harker, Esquire Suite 400 1300 N. Market Street Wilmington, DE 19801 Robert Jacobs, Esquire Jacobs & Crumplar, P.A. 2 East 7th Street P.O. Box 1271 Wilmington, DE 19899 J. Michael Johnson, Esquire Gollatz, Griffin, Ewing & McCarthy 2 Penn Center, 6th Floor Philadelphia, PA 19102 J. R. Julian, Esquire 824 Market Street Mall Suite 1001 P.O. Box 2171 Wilmington, DE 19899 James F. Kipp, Esquire Trzuskowski, Kipp, Kelleher & Pearce 1020 N. Bancroft Parkway P.O. Box 429 Wilmington, DE 19899 Julius Komissaroff, Esquire Komissaroff & Perry P.O. Box 1568 Wilmington, DE 19899 Roger D. Landon, Esquire Heckler & Cattie 200 W. 9th Street P.O. Box 128 Wilmington, DE 19899 James Lawless, IV, Esquire Morris, Nichols, Arsht & Tunnell 1201 N. Market Street P.O. Box 1347 Wlmington, DE 19899 Jeffrey S. Marlin, Esquire Biggs & Battaglia 1206 Mellon Bank Center P.O. Box 1489 Wilmington, DE 19899 Michael B. McCauley, Esquire 702 Goldsborough Building 1102 West Street Wilmington, DE 19801 James McKinstry, Esquire P.O. Box 551 Wilmington, DE 19899 2 Francis J. Murphy, Esquire Ashby, McKelvie & Geddes One Rodney Square P.O. Box 1150 Wilmington, DE 19899 Michael N. Onufrak, Esquire White and Williams 1234 Market Street, 17th Floor Philadelphia, PA 19707 John Owens, Esquire 1220 N. Market Street Wilmington, DE 19899 Richard A. Paul, Esquire E. I. DuPont & Co. Legal Department DuPont Building, 7th Floor Wilmington, DE 19898 Somers S. Price, Esquire Potter, Anderson & Corroon 350 Delaware Trust Building P.O. Box 951 Wilmington, DE 19899 Judith N. Renzulli, Esquire Duane, Morris & Heckscher 1500 One Franklin Plaza Philadelphia, PA 19102 Timothy M. Rafferty, P.O. Box 627 Hockessin, De 19707 Esquire Richard F. Rago, Esquire 1218 Market Street Wilmington, DE 19801 Donald E. Reid, Esquire Morris, Nichols, Arsht & Tunnell 1201 N. Market street P.O. Box 1347 Wilmington, DE 19899 Wilmington, DE 19899 Loreto P. Rufo, Esquire 300 Delaware Avenue P.O. Box 25046 Wilmington, DE 19899 James W. Semple, Esqire Morris, James, Hitchens & Williams 222 Delaware Avenue, 10th Floor P.O. Box 2306 Wilmington, DE 19899 Mary Pat Trostle, Esquire White & Williams 1300 N. Market Street-Suite 701 Brandywine Gateway Plaza Wilmington, DE 19899 Michael Weiss, Esquire Kimmell, Weiss & Carter, P.A. 913 Market Street, 12th Floor P.O. Box 272 Wilmington, DE 19899 John Williams, Esquire 507 S. State Street P.O. Box 454 Dover, DE 19903 John M. Willard, Esquire 803 Shipley Street Wilmington, DE 19801 Phebe S-. Young, Esquire Bayard, Handelman & Murdoch, P.A. 1300 Delaware Trust Building P.O. Box 25130 Wilmington, DE 19899 Robert B. Young, Esquire Young & Sherlock 300 S. State Street P.O. Box 1191 Dover, DE 19903 David Roeberg, Esquire Roeberg & Associates, P.A. 1122 N. French Street P.O. Box 712 3 Stuart B. Young, Esquire Young, Conaway, Stargatt & Taylor i<odney Square North 11th Floor P.0. Box 391 Wilmington, DE 19899 SWORN AND DEPOSED before me this 27th day of November, 1989. mnvpi-l.ser.mjg.10 4 Michael Dockterman, Esq. Edward J. Melia, Esq. Kevin T. Martin, Esq. Wildman, Harrold, Allen & One IBM Plaza Suite 3000 Chicago, IL 60611 Dixon Robert H. Schultz, Jr., Esq. Heyl, Royster, Voelker & Allen 17 Ginger Creek Meadows P.O. Box 467 Edwardsville, IL 62025 John B. Grogan, Esq. JOHN B. GROGAN, LTD. 77 West Washington Chicago, IL 60602 John J. Kurowski, P.C. Kurowski & Courtney, P.C. 12 Park Place Professional Centre Swansea, IL 62221 Armstrong, Teasdale, Schlafly Davis & Dicus One Metropolitan Square #2600 St. Louis, MO 63102-2740 Ronald Motley, Esq. Ness, Motley, Loadholt, & Poole 151 Meeting Street Suite 600 Charleston, NC 29401 Richardson Kenneth R. Heineman, Esq. Ellen E. Bonacorsi, Esq. Ronald L. Hack, Esq. Coburn, Croft & Putzell One Mercantile Center Suite 2900 St. Louis, MO 63101 C. Michael Evert, Jr. Evert & Weathersby Suite 225 3405 Piedmont Road, NE Atlanta, GA 30305 John J. Lynch, Esq. Evans & Dixon 16th Floor Marquette Building 314 North Broadway St. Louis, MO 63102-2093 M. Novak, Esq. Freeborn & Peters 11 South LaSalle Street Chicago, IL 60603 *