Document 4J6QVxDN8pzR17n788Opg5JpR

FILE NAME: Kentile (KEN) DATE: 1988 Apr 25 DOC#: KEN012 DOCUMENT DESCRIPTION: Legal - Responses of Kentile to Interrogatories Propounded by Plaintiff Herman Kort FAX COVER SHEET Rose, Klein & Marias LLP 801 South Grand Avenue, 18thFloor Los Angeles, California 90017-4645 (213) 626-0571 FAX (213) 623-7755 Please deliver the following pages to; Telephone JILL (510) 465-772S From; Date. Time; RE: Raymond Cervantes ' July 24, 2001 11:37 a RESPONSE OF DEFENDANT KENTILE FLOORS, IN C Number o f pages (including this page): 46 Facsimile (510) 835-4913 This message is intended only for the use of the individual or entity to which itis addressed and m a y contain information that is privileged, confidential, and exempt from disclosure under applicable law. Ifthe reader ofthis message isnot the intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone and return the original message to us at the above address via the U.S. Postal Service . T h ank you. i.4*TTW ior r tT T TO TTTOT>O TO niOOTCTTTrw**->--- ui_i^_ix_tVIMK1A3 NO. 3921-- P. 2-- BUCHALTER, NEMER, FIELDS & YOUNGER A Professional Corporation ROBERT A. ZEAVIN JOHN A. GRANIEZ 3 STEVEN JUNG 700 South Flower Street, Suite 700 4 Los Angeles, California 90017-4183 (213) 626-6700 5 6 Attorneys for'. Defendant KENTILE FLOORS, INC. 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 11 DOROTHY ST. JACQUE, etc., ) et. al., ) 13 ' ) Plaintiffs, ) 13 ) vs. ) 14 ) JOHNS-MANVILLE, etc., et al., ) 15 . . ) Defendants. ) 15 _______ ) ) 17 HERMAN KORT, ) ) 18 Plaintiff, ) ' ) 19 vs. ) ) 20 JOHNS-MANVILLE, etc., et al., ) ) 21 Defendants, ) .) 22 Case No. C137465 Case No. C470152 RESPONSES OF DEFENDANT KENTILE FLOORS, INC. TO INTERROGATORIES PROPOUNDED BY PLAINTIFF HERMAN KORT 23 Pursuant to the Court's General Order Approving 24 Supplemental Standard Pre-Trial Documents dated August 13, 1987, 25 Defendant Kentile Floors, Inc. ("Kentile") responds to 26 Plaintiff Herman Kart's ("Plaintiff")*'First Set of 27 Interrogatories as follows: 28 027JUNG.2 1 INTERROGATORY NO. 1 _,f Please state the full name, present business address present residence, and capacity or title of the individual answering and signing these interrogatories on your behalf. RESPONSE TO INTERROGATORY NO. 1 Rocco Sergi, Research Manager for Kentile, will respond to these interrogatories on Kentile's behalf. Mr. Sergi's business address is 5a Second Avenue, Brooklyn, New York 11215. INTERROGATORY NO. 2 Have you ever, at any time, engaged in the manufacture of floor-covering? RESPONSE TO INTERROGATORY NO. 2 Assuming that the term "floor-covering" includes floor tiles and vinyl sheeting, Kentile responds that it has manufactured floor tiles and vinyl sheeting. INTERROGATORY NO. 3 , If your response to interrogatory #2 is yes, then state: a. The trade name of such floor covering; b. The name, address and telephone number of the floor-covering manufacturer, supplier, dealer or other entity to which such products were sold. RESPONSE TO INTERROGATORY NO. 3 a. R e i n f o r c e d v i n y l tile', v i n y l c o m p o s i t i o n tile, vinyl asbestos tile, asphalt tile and vinyl sheet flooring. 027JUNG.2 2 b. Valley Floor Covering Distributors 9666 East Telstar Avenue - El Monte, California' ' Western Wholesale 401 South J Street San Bernardino, California Butler-Johnson Corporation 1430 Nocora Avenue _ San Jose, California 95133 Tri-county Wholesale Supply Company 2690 Sherwin Avenue Montalvo, California 93020 R. N. Holmer Company 840 W. 19th Street National City, California 92050 INTERROGATORY N O . 4 In the manufacture of such floor-covering products, did you use asbestos in any of its forms or other trade names to complete said manufacture? RESPONSE TO INTERROGATORY NO. 4 Assuming the phrase "such floor-covering products" refers to floor-covering products manufactured by Kentile, Kentile responds that it has used asbestos in the manufacture of some of its floor-covering products. INTERROGATORY NO. 5 If your response to interrogatory #4 is yes, then state: a. trade name of the asbestos product used; b. The name and address of the manufacturer or supplier of said asbestos products. RESPONSE TO INTERROGATORY NO. 5 , a. Chrysotile asbestos and chrysotile asbestos backing for vinyl sheet flooring. 027JUNG.2 3 ( _,vLLin_ci_iviAKiAy NO. 3 9 2 1 P. 5 b. Johns-Manville Corp. Asbestos, Quebec, Canada ' f Union Carbide Niagara Falls, New York ' Carey Canada East Broughton Station, Canada Atlas Asbesto Co. c/o Huxley Development New York, N.Y. INTERROGATORY N O 6 Have you ever, at any time, supplied or distributed asbestos or asbestos-containing products to any company or manufacturer of floor-covering or any other component relative to floor-covering? RESPONSE TO INTERROGATORY NO. 6 Yes. INTERROGATORY NO. 7 If your response to interrogatory #6 is yes, then state: a. trade name of the asbestos product which was supplied or distributed; b . The name and address of each company or manufacturer to which asbestos or asbestos- containing products were supplied or delivered. RESPONSE TO INTERROGATORY NO. 7 a. Reinforced vinyl tile, vinyl composition tile, vinyl asbestos tile, asphalt tile and vinyl sheet flooring. # b. Valley Floor Covering Distributors 9666 East Telstar Avenue , El Monte, California 027JUNG.2 . 4 ---- _i>LLiiv_ajviflKiAb NO. 8921 P. 6 1 Western Wholesale 401 South J Street 2 San Bernardino, California 3 Butler-Johnson Corporation 1480 Nocora Avenue 4 San Jose, California 95133 5 Tri-County Wholesale Supply Company 2690 Sherwin Avenue 6 Montalvo, California 93020 7 R. N. Holmer Company 340 W. 19th Street 8 National City, California 92050 9 INTERROGATORY NO. 8 10 Have you ever purchased asbestos or asbestos- 11 containing products from any company, distributor, manufacturer, 12 or mining concern for the purpose of using it in the manufacture 13 of floor-covering? 14 RESPONSE TO INTERROGATORY NO. 3 15 Yes. 16 INTERROGATORY NO. 9 17 If your answer to interrogatory #8 is yes, then state: 18 a. purpose for which such asbestos or asbestos- . 19 containing product was purchased; 20 b. The name and address of the company or 21 manufacturer from which such asbestos or 22 asbestos-containing products were purchased. 23 RESPONSE TO INTERROGATORY NO. 9 24 a. Product reinforcement, durability and dimensional 25 stability. b. Johns-Manville Corp. Asbestos, Quebec, Canada Union Carbide Niagara Falls, New York 027JUNG.2 5 'NO. 3921-- P. 1 ~ Carey Canada f , East Broughton Station, Canada 3 Atlas Asbesto Co. c/o Huxley Development 4 New York, N.Y. 5 INTERROGATORY NO. 10 6 Have you ever engaged in the use, design, manufacture 7 formulation, fabrication, sale, or distribution of any asbestos a or asbestos-bearing product in the course of designing, 9 manufacturing, distributing, or selling floor-covering and/or 10 any components or parts thereof? 11 RESPONSE TO INTERROGATORY N O 10 12 Kentile has never engaged in the use, design, 13 manufacture, formulation, fabrication, sale, or distribution of 14 asbestos per se. Kentile, however, does not understand the 15 meaning of the term "asbestos-bearing product" so Kentile can 16 neither affirm nor deny with respect to that term. 17 INTERROGATORY NO. 11 18 If your response to interrogatory #10 is yes, then state: 1,9 a. trade names of any asbestos products which were 20 used, designed, manufactured, formulated, SI fabricated, sold or distributed by you; 22 b. The trade names of any floor-covering or any 23 component/part thereof which you designed, 24 manufactured, distributed or sold, and in which 25 you used any asbestos cr asbestos-bearing 26 product, ' . 27 RESPONSE TO INTERROGATORY NO. 11 ' 28 Not applicable. 027JUNG.2 6 NU. SVi! I---V 8' 1 INTERROGATORY NO. 12 2 Have you ever engaged in the* supply, design, 3 manufacture, formulation, fabrication, sale, or distribution of 4 any asbestos or asbestos-bearing product for use in the design, 5 manufacture, distribution, or sale of floor-covering and/or any 6 components or parts thereof? 7 RESPONSE TO INTERROGATORY NO. 12 8 Kentile has never engaged in the supply, design, 9 manufacture, formulation, fabrication, sale, or distribution of 10 asbestos per se. Kentile, however, does not understand the 11 meaning of the term "asbestos-bearing product" so Kentile can 12 neither affirm nor deny with respect to that term. 13 INTERROGATORY NO. 13 14 If your response to interrogatory #12 is yes, then 15 state: 1 6 a. trade names of any asbestos products which were 17 used, designed, manufactured, formulated, 18 , fabricated, sold or distributed by you; 19 b. The trade names of any floor-covering or any 20 component/part thereof which you designed, 21 manufactured, distributed or sold, and in which 23 you used any asbestos or asbestos-bearing 23 product. 24 RESPONSE TO INTERROGATORY NO. 13 25 Not applicable. 26 INTERROGATORY NO, 14 , 27 Have you, at any time, engaged in the processing, 28 marketing and sale of products containing asbestos fibers? 027JUNG.2 7 RESPONSE TO INTERROGATORY NO. 14 Yes. , r INTERROGATORY NO. 15 state : If your response to interrogatory #14 is yes, then a. -trade or brand name of each such product mined, manufactured, and/or marketed. b. The dates each of such products were placed on the market. c. The date each of such products were withdrawn from the market. d- A description of the physical (the chemical) composition of each such product including the type of asbestos contained in each such product (i.e., amosite, shrysotile or crocidolite) and the quantitative percentage of asbestos in each product. e. A d e s c r i p t i o n o f t h e p h y s i c a l a p p e a r a n c e o f each such product, f. A detailed description of the intended use of each such product. g. The name of the manufacturer of each such product. h. The mining' or milling concern from which the raw asbestos fiber was obtained. 027JUNG.2 a NU. 892 1-- "P. 1 0 " -- RESPONSE TO INTERROGATORY NO. IS a. Reinforced vinyl tile, 'vinyl composition tile, vinyl asbestos tile, asphalt tile and vinyl sheet flooring. b. Tile - 1906 6 '.Vinyl sheet flooring - 1966 7 c. Tile - 1986 8 Vinyl sheet flooring - 1969 9 d. Product is composed of 75% filler and 25% binder. 10 Chrysotile asbestos is 10-15% of total product. 11 e. 9x9 or 12x12 solid squares in various colors. 12 f. Floor covering. 13 g. Kentile Floors, Inc. 14 h. Johns-Manville Corp. Asbestos, Quebec, Canada 15 Union Carbide 16 Niagara Falls, New York 17 Carey Canada East Broughton Station, Canada 18 Atlas Asbesto Company 19 c/o Huxley Development New York, N.Y. 20 INTERROGATORY NO. 16 21 Have any of the products listed in interrogatory #15 22 above been altered in chemical composition or asbestos type or 23 content since first being marketed? 24 RESPONSE TO INTERROGATORY NO. 16 25 Yes. 26 INTERROGATORY NO. 17 27 If so, please state; 28 027JUNG.2 9 a. trade name of each such product. b. The date each such product was altered. c. The nature of the alteration. d. The reason for the alteration. RESPONSE TO INTERROGATORY NO. 17 a. Resilient floor tile. b . July 1986. c. Product no longer contains asbestos, d. Anticipated revisions to OSHA regulations regarding asbestos in the work place. INTERROGATORY NO, 18 For each of the products identified in interrogatory #16 above, please state the gross income realized by your company as a result of all sales within the United States, for each year the product was sold. RESPONSE TO INTERROGATORY NO. IB Not applicable. INTERROGATORY NO. 19 For each of the products identified in interrogatory #15 above, please state the gross income realized by your company per year, for all sales to the United States government, and please further state: a. gross income realized by your company, per year, . for sales to the Naval supply system of the United States government. 027JUNG.2 10 NU. H121 P- 12 RESPONSE TO INTERROGATORY NO. 19 Kentile does not maintain records which enable it to respond to this interrogatory at present. In order for Kentile to respond to this interrogatory, Kentile must manually search through its sales records from 1978 to the present. Kentile has no sales records for sales prior to 1978, Kentile, however, has 7 begun a review of its records and will supplement its response 8 to this interrogatory when it has completed its review. 9 INTERROGATORY NO. 20 10 For each of the products identified in interrogatory 11 #15 above, please state the gross income realized by your 12 company, per year, for sales to all contractors with whom you 13 did, or have done business. 14 RESPONSE TO INTERROGATORY NO. 20 15 On information and belief, Kentile denies making any 16 direct sales to contractors. See Response to Interrogatory 17 N o . 19. " 18 INTERROGATORY NO. 21 19 For each of the products identified in interrogatory 20 # 1 5 above, p l e a s e s t a t e t h e g r o s s i n c o m e r e a l i z e d b y y o u r 21 com p a n y , p e r year, f o r s a l e s o f t h e p r o d u c t s t o e n t i t i e s not 22 i d e n t i f i e d i n p r e v i o u s i n t e r r o g a t o r i e s , a n d i d e n t i f y e a c h s u c h 23 entity. 24 RESPONSE TO INTERROGATORY' N O 21 25 See Response to Interrogatory No. 19. 26 27 28 027JUNG.2 11 INTERROGATORY N O 22 Do you have any records whicty reflect sales of each of the products identified by you in interrogatory #15 above for each year said products were sold? RESPONSE TO INTERROGATORY NO. 22 Yes. INTERROGATORY NO. 23 If your answer to the preceding interrogatory is yes, please state: a. A description of said records or documents sufficient to permit plaintiff to describe such documents for purposes of a notice to produce or a motion for production of documents; b. The name, business address and telephone number, employer, and job title of the person or persons having present custody of or control over the original of said documents. a. Distributor invoices. b. Linda Gawel, Insurance Manager, Kentile Floors Inc,, 58 Second Avenue, Brooklyn, New York 11215, (718) 788-9500. INTERROGATORY NO. 24 For the period 1930 to January 1, 1978, do you have any written memoranda, specifications, blueprints or other written materials of any kind or character relating to the testing of the health effects of products identified in interrogatory #15 above? If so, please describe with sufficient 027JUNG.2 12 particularity to satisfy the requirements of a subpena duces tecum. ' , RESPONSE TO INTERROGATORY NO. 24 NO. . INTERROGATORY NO. 25 Did you make any design changes as a result of such tests? RESPONSE TO INTERROGATORY NO. 25 Not applicable. INTERROGATORY NO. 26 If so, please state: a. nature of the change made, the name, address and job classification of each person in charge of making a change. RESPONSE TO INTERROGATORY NO. 26 Not applicable. INTERROGATORY NO. 27 Have you, at any time, published and/or distributed any brochures, sales literature, pamphlets or other written materials (aside from any caution labels on containers) of any kind or character that contain any warnings, cautions, caveat, or directions concerning the possibility of injury resulting from the use of the products listed in your response to interrogatory #15? ' RESPONSE TO INTERROGATORY NO. 27 Yes. , 027JUNG.2 13 nu. o'll I y 1 INTERROGATORY NO. 28 2 From 1930 until the present, -did the asbestos products 3 manufactured or distributed by you, contain any warnings, 4 cautions, caveat or other statement on the product or its 5 packaging? 6 RESPONSE TO INTERROGATORY NO. 28 9 Assuming the term "asbestos products" includes floor 8 tiles and vinyl sheeting containing asbestos, Kentile's response 9 is "yes." 10 INTERROGATORY NO. 29 11 If so, please state: IS a. When did the warning first appear? 13 b. What was the precise wording of the warning, when 14 it first appeared? 15 c. Was the warning altered, amended or changed in 16 any manner? If so, how and when? 17 d. Where was the warning located on the product or 18 packaging? 19 e. When did you become aware of warnings placed on SO products distributed by other manufacturers or 31 suppliers of asbestos or asbestos containing 22 products? 23 f . State the manner in which your product is shipped 24 and the type of container it is shipped in to 25 retailers. ' 26 g. State whether any industrial psychologists or 7 human factor engineer were consulted prior to 2Q utilizing such warnings, cautions, etc. 027JUNG.2 14 HU. 0 1i I " T . I 0 " 1 RESPONSE TO INTERROGATORY NO. 29 2 a. 1978 - approximately. 3 b. "Warning. Existing resilient flooring may 4 contain asbestos fibers. These fibers are locked 5 into place. However, sanding resilient flooring, 6 backing or lining felt can release asbestos ? fibers into the air. Inhalation of asbestos 8 dust may be injurious to your health. Therefore, 9 do not sand resilient flooring, backing, or 10 lining felt." 11 c. No. 12 d. Insert in packages. 13 e. 1968. 14 f. Truck. 15 g. No. 16 INTERROGATORY NO. 30 17 When did you first receive notice that any person ia claimed injury as a result of exposure to asbestos or asbestos 19 containing products manufactured and/or sold by you? 20 RESPONSE TO INTERROGATORY NO. 30 21 Upon information and belief, 1977. 22 INTERROGATORY NO. 31 23 With respect to the claim described in interrogatory 24 #30, please state: ' 25 a. name and address of the claimant. 26 b. The date of notice of the claim. 27 c. A description of the claim, i.e.,.worker's 28 ( 027JUNG.2 compensation, products liability, etc. 15 1 d. The type of injuries allegedly sustained. 2 e. The name and address of* each attorriey who 3 represented the individual making such claim. 4 f. The style and court number of each claim 5 currently pending. 6 g. '-The resolution of the claim. 7 RESPONSE TO INTERROGATORY NO. 31 8 a. George Brandy 9 4459 South Indiana Avenue 10 Chicago, Illinois, 11 b. October 21, 1977. 12 C. Workers' Compensation. 13 d. Cancer of the larynx. 14 e. John P. McAuliff 15 111 West Washington Street 16 Chicago, Illinois. 17 f. Not applicable. 18 g. The claim was settled. 1.9 INTERROGATORY NO. 32 20 Do you have policies of insurance that cover the 21 claims that have been made by plaintiffs herein? 22 RESPONSE TO INTERROGATORY NO. 32 23 A determination of what coverage is available for this 24 claim cannot be made until after this claim is paid by the 25 carriers. Consequently, Kehtile cannot state what policies 86 will cover the claim. ' 27 28 027JUNG.2 16 "U. U )i r . 10 1 INTERROGATORS. NO- 33 2 If so, please list the names of each'insurance carrier . r 3 with whom you have coverage, the amount of such coverage, and 4 the date of each such policy. 5 RESPONSE TO INTERROGATORY NO. 33 6 To the extent that this interrogatory requests the 7 identities and amounts of coverage which Kentile expects will 8 afford coverage, see Exhibit "A." 9 INTERROGATORY NO. 34 10 Please describe in detail the type of packages in 11 which you have sold asbestos material, listing the dates each 12 type of package was used, a physical description thereof, and a 1 3 description of any printed material or trademarks that appeared 14 thereon. 15 RESPONSE TO INTERROGATORY NO. 34 ( 16 Tile was packaged in corrugated cardboard cartons made 17 to hold 45 square feet of tile in various gauges. The name of 18 .the company, size of tiles, package handling instructions, 19 style, color and code number appeared on each carton. 20 Vinyl sheet flooring was rolled in brown paper. The 21 pattern, color, length and width were marked. 22 23 For the period 1930 to January l, 1978, did you 24 receive any reports or communications from your workers' 25 compensation insurance carrier or products liability insurance 26 carrier with regard to the hazards ^incident to use of asbestos- 27 containing floor-covering products? If so, please state who had 28 possession of said reports., the location of said reports and 027JUNG.2 17 tiie substance of the contents of said report, listing for each such report the respective insurance company, its address and . r ' the agent signing such correspondence. RESPONSE TO INTERROGATORY NO. 35 NO. INTERROGATORY NO. 36 Have you imported asbestos or asbestos materials since 1930? RESPONSE TO INTERROGATORY NO. 36 Yes. INTERROGATORY NO. 37 If the answer to the preceding interrogatory is yes, then state: a. From where the asbestos or asbestos materials was imported. b. How long you have imported asbestos and asbestos materials. c. Whether you have supplied this imported asbestos or asbestos materials to any of the other defendants since 1945, when these transactions took place and where. d. Whether any warnings, cautions, caveats or directions accompanied the materials referred to in subpart c and the date thee first appeared. RESPONSE TO INTERROGATORY NO. 37 , . a. Johns-Manville Corp. Asbestos, Quebec, Chnada Carey Canada Corp. , East Broughton Station, Canada 027JUNG.2 18 1 b. 1950-61; 1969-86 2 C. No. 11 . 3 d. Johns-Manville; October 1, 1968. 4 Carey Canada; upon information and belief, 1977. 5 INTERROGATORY NO. 38 6 If you have discontinued manufacturing and/or selling 7 any asbestos products, please state the reasons therefor, 8 RESPONSE TO INTERROGATORY NO. 38 9 It would not be practical to comply with upcoming 10 revisions to OSHA regulations regarding asbestos in the work 11 place. 12 * INTERROGATORY NO. 39 13 Have any other manufacturers or suppliers of asbestos 14 or asbestos containing products ever furnished you with 15 information as to the state of the medical knowledge regarding 16 the connection between asbestos exposure and the contracting of 17 pulmonary diseases including cancer and asbestosis? 18 RESPONSE TO INTERROGATORY NO. 39 19 No. 20 INTERROGATORY NO. 40 21 If the answer to the preceding interrogatory is yes, 22 'then state; 23 a. What information was furnished to you. 24 b. The date the information was furnished to you. 25 c. The names of all parties who furnished the 26 * information to you. - , 27 28 027JUNG.2 19 RESPONSE TO INTERROGATORY NO. 40 Not applicable. r ' INTERROGATORY NO. 41 I Since 1930: Have any manufacturers or suppliers of j asbestos or asbestos-containing products furnished to you or I have you furnished any manufacturers or suppliers of asbestos r or asbestos-containing products with the results of any i research test, medical studies or experiments regarding the < state of the medical knowledge as to the connection between k asbestos exposure and the contracting of cancer o asbestosis? l] RESPONSE TO INTERROGATORY NO. 41 n NO. ' u INTERROGATORY NO. 42 14 If the answer to the preceding interrogatory is yes, IE then state: ie a. When each took place. ' 17 b. Who participated in each. ie ' 1-9 c. A summary of the content of each document or communication. 20 RESPONSE TO INTERROGATORY NO. 42 21 Not applicable. 22 23 Have you ever conducted or sponsored or contributed 24 financially to any studies or research to determine if the 25 inhalation of asbestos fibers may be harmful? if so, please 26 state: , 27 a. By whom the research was conducted, giving 28 complete names and addresses. 027JUNG.2 20 b. The dates that each such test was conducted. 2 c. The complete results of pach test or study. 3 d. Whether you will supply copies of reports of the 4 research department pertaining to the 5 corporation's use of asbestos in its manufactured 6 floor-covering products, without the necessity 7 of a formal notice to produce or motion to 8 produce documents, and, if so, please attach said 9 copies to your answers to interrogatories. 10 RESPONSE TO INTERROGATORY NO. 43 11 Yes. 12 a. SRx, Inc. , Menlo Park, California for the 13 Resilient Floor Covering Institute. 14 b. 1979. 15 c . Results of test indicate that there is no 16 exposure to airborne asbestos fibers in the use 17 and maintenance of the tile, and when recommended 18 procedures are used for its installation and 19 removal, exposure is substantially below the OSHA 20 limit. 21 d. No, 22 INTERROGATORY NO. 44 23 State the names and addresses of all persons who have 24 served as chief medical officers since 1930, listing the 25 periods of.time each was employed by you and in what capacity. 26 RESPONSE TO INTERROGATORY NO. 44 , 27 ' Not applicable. 28 027JUNG.2 21 1 INTERROGATORY WO. 45 2 Name the person in the corporate structure to whom the 3 chief medical officer reports, also giving that persons1 4 position or job title in the corporation. 5 RESPONSE TO INTERROGATORY NO. 45 6 Not applicable, 7 INTERROGATORY NO. 46 8 Please state the duties and responsibilities of the 9 corporation's chief medical officer. 10 RESPONSE TO INTERROGATORY NO. 46 11 Not applicable. 12 INTERROGATORY NO. 47 13 Please state the names and addresses of all physicians 14 who were employed, retained or otherwise engaged by you at any of its facilities from the year of 1930 until the present time 15 16 for the purposes of evaluating, diagnosing or treating pulmonary 17 complaints or problems in past, present or prospective 18 employees. 19' RESPONSE TO INTERROGATORY NO. 47 20 Kentile does not maintain records which enable it to 21 r e s p o n d to t h i s i n t e r r o g a t o r y at p r e s e n t . In o r d e r f o r K e n t i l e 22 to r e s p o n d t o t h i s i n t e r r o g a t o r y , K e n t i l e m u s t m a n u a l l y s e a r c h 23 through all its files for the last sixty years simply to 24 retrieve the information requested. Kentile, however, has begun 25 this arduous task and will supplement"this response when it has 26 completed its review. , 27 28 027JUNG.2 .22 t i.tvvi >i'~r/n,,rl ,uul,_ni.Liii_ajiiniu'0 N U .M ^ I K. '4 1 INTERROGATORY NO. 48 2 Please state the names and addresses of all persons 3 employed by you from 1930 through January l, 1978, who 4 functioned as industrial hygienists. As contemplated by these 5 interrogatories, an industrial hygienist is one that performs 6 engineering or health studies to identify and evaluate 7 potential occupational health hazards and suggests methods of 8 dealing with same. with respect to each person employed by you 9 as an industrial hygienist, please state: 10 a. facility or office to which each was assigned. 11 b. His or her complete and precise duties and 12 responsibilities. 13 RESPONSE TO INTERROGATORY NO. 48 14 See Response to Interrogatory No. 47. 15 INTERROGATORY NO. 49 16 Did your medical officers, physicians or industrial 17 hygienists at any time, ever make any recommendations and/or 18 Suggestions to you pertaining to the risks or hazards to 19' persons involved in the manufacturing or use of floor-covering 20 products containing asbestos? If so, please state: 21 a. Where the recommendations were made. 22 b . To whom they were made. 23 c. By whom they were made. 24 d. T h e s u b s t a n c e of e a c h r e c o m m e n d a t i o n . 25 RESPONSE TO INTERROGATORY NO. 49 26 NO. , 27 28 027JUNG.2 23 1 INTERROGATORY NO. 50 2 Please state the names of trad,e association 3 periodicals to which you subscribed from 1923 to January 1, 4 1978. State whether or not during said period, you had any 5 knowledge of any articles being printed in industry trade 6 journals, essays', memoranda, and other similar sources 7 pertaining to the hazardous potential of asbestos and which of 8 such articles were received by you. . 9 RESPONSE TO INTERROGATORY NO. SO 10 The Federal Register; Occupational Safety and Health 11 Reporter; Pollution Engineering Magazine; Occupational Safety 12 and Health Magazine; Safety & Health News? 29 CFR; Handbook of 13 Engineering. Kentile had knowledge of articles from the early 14 1970's. 15 16 Name those organizations, groups, inter-company or 17 industrial organizations, their committees or subcommittees, to 18 which you belong which conducted studies or researched 19 relationships, if any, between exposure to asbestos fibers or 20 products and asbestosis and lung cancer, from 1945 to 1970 and 21 the years of your membership. 22 RESPONSE TO INTERROGATORY NO. 51 23 Resilient Floor Covering Institute. 24 INTERROGATORY NO. 52 ` 25 - Have you received copies of transcribed minutes of the 26 various committee meetings, subcommittee meetings, general 27 meetings and Board of Director meetings of any organization 28 027JUNG.2 24 iyu. oy l i r. t o 1 listed in answer to interrogatory #51 within one year of such 2 meetings. - 3 RESPONSE TO INTERROGATORY NO. 52 4 No. ' 5 INTERROGATORY NO. 53 6 Please, state the amounts you have spent or contributed 7 annually, from 19,30 until January 1, 1978, for research 8 specifically directed to the relationship, if any, between an 9 exposure to asbestos-containing floor-covering products and 10 asbestosis, lung cancer or any other pulmonary disease. 11 RESPONSE TO INTERROGATORY NO. 53 12 Unknown. 13 INTERROGATORY NO. 54 14 Please state the amount you have annually contributed 15 through January i, 1978, to any independent medical research 16 group or groups conducting research into the relationship , if 17 any, between exposure of those employees who work with asbestos- 1 8 containing products to asbestos and any pulmonary disease. 19 RESPONSE TO INTERROGATORY NO. 54 20 Not applicable. 21 INTERROGATORY NO. 55 22 Please state the names and addresses of the organizations 23 or groups conducting the studies referred to in answer to 24 interrogatories numbered-53 and/or 54. 25 RESPONSE TO INTERROGATORY NO. 55 26 Resilient Floor Covering Institute. 27 28 027J U N G . 2 25 Vi.' 1. V'ji ||,"r/nm * _\LL1i*_U_lirviunu iiy. u Jc 1 INTERROGATORY NO. 56 2 Have you had a department, division or section devoted 3 to scientific and/or medical research during the period from 4 1930 until January 1, 1978? If so, state its title(s) and when 5 it was first formed. 6 RESPONSE TO INTERROGATORY NO. 56 7 No. 8 INTERROGATORY NO. 57 9 Please state the scientific or medical periodicals to 10 which you, your medical department or industrial hygiene 11 division subscribed during the period between 1930 and 1964, 12 specifying the date such subscriptions were begun. 13 RESPONSE TO INTERROGATORY NO. 57 14 See Response to Interrogatory No. 50. 15 INTERROGATORY NO. 58 16 Please state whether any of your asbestos-containing 17 products were provided with any special instructions, oral or 18 written, in regard to utilizing said products in a manner so as 19 to avoid exposing workers to amounts of dust exceeding 20 threshold limit values. If so, state: 21 a. when these instructions were given. 22 . 23 b. By whom these instructions were given. c. Whether the instructions were oral or written. 24 d. The precise content of the instructions. 25 e. If t h e 'instructions were written, please attach a 26 copy of the instructions. 27 28 027JUNG.2 26 my. <yu I r. a 1 RESPONSE TO INTERROGATORY WO. 58 2 Yes. 3 a. Approximately 1978 - present, 4 b- Package inserts. 5 c. Written. 6 d. See Response to Interrogatdry No. 29(b). 7 e. This is not an interrogatory. 8 INTERROGATORY NO. 59 9 Did any representatives of yours attend the 20th 10 annual meeting of the IHF in November, 1955, in Pittsburgh, 11 Pennsylvania? If so, give the name and current address of each 12 such attendee. 13 RESPONSE TO INTERROGATORY NO. 59 14 Upon information and belief, no. 15 INTERROGATORY NO. 60 16 Have you received a copy or copies of the Industrial 17 Hygiene Digest published monthly by the IHF, and if so, state 18 the date of initial receipt of such publication. 19' RESPONSE TO INTERROGATORY NO. 60 20 No. 21 INTERROGATORY NO. 61 22 __ Have you ever requested IHF officials to: 23- a. Perform a search of the medical literature to 24 determine whether any scientists or doctors were 25 reporting cases of asbestosis and/or lung cancer 26 i ship workers, mechanics, or others working with 27 or exposed to asbestos containing products, or 28 027JUNG.2 27 l, n , ii.tu n m IUJOC., _MC tn_Oi_mrtlMrtO m . w i\ r. 1 1 discussing the potential hazards incident to use 2 of asbestos-containing products.~ , 3 b. Perform any studies or research into potential 4 health hazards incident to the use of asbestos- 5 containing floor-covering products. 6 c. Review governmental publications of Great Britain 7 ' for determining whether any research was being 8 conducted by the British government into any 9 potential health hazards incident to the use of 10 floor-covering products containing asbestos. 11 d. Review governmental publications of Great Britain 12 to determine whether the Chief Inspector of 13 Factories, or any other British government 14 agency, had issued any regulations or published 15 any findings relative to potential health hazards 16 incident to the use of floor-covering products 17 containing asbestos. 18 RESPONSE TO INTERROGATORY NO. 61 19 No. 20 INTERROGATORY NO. 62 21 Did you at any time prior to January l, 1980 warn any 22 labor union representing ship workers, mechanics, or other 23 working with or exposed to asbestos-containing products, of any 24 potential health hazard form the use of floor-covering products 25 containing asbestos? 26 RESPONSE TO INTERROGATORY NO. 62 , 27 No. 28 027JUNG.2 28 n_U_inn m n g iiu. u ; i r, ju 1 INTERROGATORY NO. 63 2 If the answer to the preceding,, interrogatory is yes, 3 then state: 4 a. name of the union. 5 b. How said union was informed. 6 c. The date and place of said information or 7 ` warning. a d. The content and nature of said warning. 9 e. The individual or individuals warned. 10 RESPONSE TO INTERROGATORY NO. 63 11 Not applicable. 12 INTERROGATORY NO. 64 13 State the name of all persons who have acted in the 14 capacity of medical librarian for you from 1930 to January l, 15 1978, give their current address, telephone number, and current 16 position with the company. 17 RESPONSE TO INTERROGATORY NO. 64 18 Not applicable. 1'9 INTERROGATORY NO. 65 20 State whether you ever subscribed to or received 21 copies of the Asbestos Worker magazine and state the years of 22 subscription or receipt of this magazine. 23 RESPONSE TO INTERROGATORY NO. 65 24 NO. ' 25 INTERROGATORY NO. 66 25 Please state whether you .subscribe to the Asbestos 27 magazine and list the inclusive dates of your subscription. 28 027JUNG . 2 29 LT LV U I IW O L, _|\ L L i H _ i x _ m n i w n u 1 RESPONSE TO INTERROGATORY NO. 66 2 No. ,r ' 3 INTERROGATORY NO. 67 4 Please identify all booklets, manuals, journals, and 5 all publications directed from you prior to January l, 1980 to 6 customers and users of all asbestos-containing products and the 7 dates said information was forwarded regarding proper use and 8 application of your asbestos containing products. 9 RESPONSE TO INTERROGATORY NO. 67 10 Various sales brochures, package inserts and 11 installers' manuals. 12 INTERROGATORY NO. 68 13 Please describe and identify all tests and experiments 14 conducted by your prior to January 1, 1980 to determine whether 15 or not asbestos fibers contained within your asbestos- 16 containing floor-covering products would become airborne upon 17 their being applied by asbestos workers or helpers. Please 18 ,state the dates of all tests and experiments, the results, and 19 conclusions of each test and/or experiment. 20 RESPONSE TO INTERROGATORY NO. 68 21 Not applicable. 22 INTERROGATORY NO. 69 , 23 At any time prior to 1964 were any tests or studies 24 conducted or sponsored by you to determine: 25 a. the level of dust o fiber concentrations incident 26 to: , 27 i. Cutting or sawing your floor-covering 28 products containing asbestos; 027JUNG.2 30 - OUL. zt. UUI ' KU51, _ M 1 1N_i(JVIAK 1Au no. y in r. i r 1 ii. Tearing down the product during repair and 2 maintenance functions. 3 b. Whether long term (20 years or more) exposure to 4 floor-covering product containing 15% asbestos or 5 less for work periods less than a hours a day, 6 both indoors and outdoors, which resulted in the 7 liberation of asbestos dust or fiber below 5 8 million particles per cubic foot (mppcf) might 9 cause asbestosis or expose such worker to an 1 increased statistical risk of contracting: 11 i. Bronchogenic cancer; 12 ii. Mesothelioma (pleural or peritoneal); 13 iii. Gastrointestinal cancer. 14 RESPONSE TO INTERROGATORY NO. 69 ( i 15 No. 16 INTERROGATORY NO. 70 17 State the date and the source form which you received 18 your first notice and awareness of TEV's pertaining to the 19 concentration of airborne asbestos fibers. 20 RESPONSE TO INTERROGATORY NO. 70 21 OSHA early 1970's. 22 INTERROGATORY NO, 71 23 Between 1930 and 1978, did you hear from any source of 24 an alleged association between asbestos exposure and the 25 development of cancer, asbestosis and pulmonary disease? 26 RESPONSE TO INTERROGATORY NO. 71 * 27 Yes. ( ) 28 027JUNG.2 31 <-L' ./VI 11.4JrtIVI KUSt, _ M 1 1N_&JVIAK 1A3 NO. 3921 P: 33 1 INTERROGATORY NO. 72 2 State when your knowledge as to the allegfed 3 association between the inhalation of asbestos fibers and 4 contraction of cancer an asbestosis was first acquired, and 5 state the source of that information. 6 RESPONSE TO INTERROGATORY NO. 72 7 Early 1970's, OSHA. 8 INTERROGATORY NO. 73 9 Do you subscribe to the United States Public Health 10 Bulletin Service? If so, please state the date when you first 11 so subscribed to the Public Health Service Bulletin. 12 RESPONSE TO INTERROGATORY NO. 73 13 No. 14 INTERROGATORY NO. 74 15 Please state the date when, if ever, you first 16 notified your employees working in your manufacturing plants and 17 factories as to the need to wear and use respirators. 18 RESPONSE TO INTERROGATORY NO. 74 19' 1968. 20 INTERROGATORY N O 75 21 Please state the date when your first notified workers 22 applying your floor-covering products as to the need to wear 23 respirators. 2 4 RESPONSE TO INTERROGATORY NO. 75 25 Not applicable. 26 ENTERROGATORY NO. 76 ' ' 27 Have you ever published bulletins warning your 28 amployees concerning the hazards of inhalating asbestos and 2 32 ju L. ZVV I ! I 'tortivi ' KUbt, J L t 1N_&_MAK1AS 3 . 3 9 2 1 p. 3 4 ' 1 coming into contact with your asbestos-containing product? If 2 so, describe sufficiently for purpose of' a notice to produce all 3 such bulletins, 4 RESPONSE TO INTERROGATORY NO. 76 5 Yes. Letters on the health effects of asbestos, the 6 need for safe handling of asbestos and the proper use and 7 benefits of dust masks or respirators were posted on plant 8 bulletin boards. 9 INTERROGATORY NO. 77 10 Have any of your officers, agents, servants or 11 employees ever testified before any governmental body regarding 12 the possible harmful effects of asbestos exposure? If so, 13 please state: 14 a* When and where such testimony was given. 15 b. A summary of said testimony. 16 c. If said testimony was recorded, and if so, attach 17 a copy to the answer to these interrogatories. 18 RESPONSE TO INTERROGATORY NO. 77 19 No. 20 21 DATE: 22 23 24 25 26 27 28 (LjiJ K . H f f BUCHALTER, NEMER, FIELDS & YOUNGER A Professional Corporation B y ___ 1lvV S T E V E N JfUNG/ Attorneys for Defendant KENTILE FLOORS, INC, 027JUNG.2 33 I'UVU, _l\LL 1M_fJ_lfr\(\1no NU. 3 9 2 1 -- P. 35- V 71g 965 071 3-* o CJ m t \y 'if ; ^ lV KWT1LE FLOORS HC. UMBBELLA 4 EXE8SS - gFTECTIVS I/1/J5 ( HiMIST - RATIONAL CATO* - OLA 19*0230 morula ( l n u M a m o n u L - avetcc EXCESS m s U l L A DwnwiTT os nil America - atsjico niMsroirr m a n m - avbecd (1/1/85-6/13/85) CRUUTS STATE - TACIT]C STABS (6/15/85-1/1/84) LIBIT 15HM 10HK p/n 1JW 5MH p/o 15WI 5AH p/o 15* 1/1/86-87 ^PKIMAHY - SAT108AL 1TOI0H - GIA 1803182 TOLICT t UKB 1672704 XTTP 15666? TEL OilRAC 6485-6458 ' n JKUit, _ M t IN_4_MAK1A5 ; OUL. uu I .I I : n '-JUL. t. /DU I1.1! I : 4y AMr S. IKUS t, JU. 11N_&_MAK1 AS_ 718 885 07T8-* NO. 89 21 23SlL.I73 S' 1 <A 1 5i Vo I 4 sm I s i) 4 S 3 M o XM 9 8 M 8 MO 9 o tuJ s O CB hi ui w 91 VI td KEWTII-E FLOORS, IIIC. Ptabrella t Bxcew* - 1/1/83 - 1/i/m PRIHAHT - ATTONAL 1W10N - GW 9456746RA UHBBKT-T-A A l l i a i { S te w a r t S b iith ) IUL55S3 13 U n d e rw rite r P a t S ern a sc o n i (964- 2929) i j k i t or l i a b i l i t y 5x, c0e0aa,0 0p0rim ary - EXCESS OPBRgTJJ Layer 10,000 ex 5, 000,000 T ran sco n tin e n tal A i.lj.an r (Stew art S(AwVlRthBC) O)9X1|R5D5X9510409616542 6,000,000 1*0 10,000,000 2,000,000 PO 10,000,000 Layer 25,000,000 ex 15,000,000 Fireman's Fend IXLX 1481670 H artford AH I10XS102C101`6 <RVRro0> 1X1203722 10.000. 060 PO 25,000,000 10.000. 000 P0 25,400,000 5,000,000 PO 25,400,000 Layer 10,000,000 as 40,000,000 Allianz (Stewart Snith) 4x^X5 5 9 5 79 BEH LAYER IQ ex 50 FHiar ret fFo ur dn d X1 LDXX1SH49C50479541 5.000. 000 5.000. 000 JUL. /4. /(J 1 11: bOAM ' ROSE, _ K L E I N _&_M AR IAS `NO. 8 9 2 1 P. 39 KENTHfE FLOOR?, [NC, lerni 1/1/32-43 Iniranct Cosipany National Union rirt Insurance Company of Pittsburgh,, PA Polier No. GU94J6417RA let Uebrell Limit SS,000,Odo Alll.444 laaurtAC CAitpmy ULS,58313 2nd Umbrella Limit) SIO.OOO.OO wctai of S5.000.0ao 1/1/82-93 1/1/82-83 Transcontinental Ins. Company Alliina Insurance Company R0XOO9616542 XL559514 3rd Umbrella Limit* 825.000.000 excess of S15.OO0.000 1/1/82-83 V 1/82-83 1/1/82-83 Firemen's Fund Insurance company Hartford Accident A Indemnity Company Integrity Insurance Company XLXU81670 1QXSCB6993 20.203 722 1/1/11-82 National Union Fisa Insurance Cu<spauy of Pittsburgh, PA OUU^IGRA lit Umbrella Limits S5.Q0.0QQ i/i/ai-aa Some Insurance Company HEC991128 2nd Unbralla Limits $10.000.000 excess of $5.000.000 1/1/31-82 Firemen'a Fund Insurance Company XU1437275 3rd Umbrella Units $29.000,000 excess of S15.000.000 1/-1/S1-32 1/1/31-82 1/1/81-82 Firemen's Fuad Insurance Company Hartford Accident A Indemnity Company ' National Uaian Fire Insurance Compsny of Pittsburgh, PA XLX143727 10X910211 9910486 Linie* of Liability $1,000,000 Combined 8.1. & P.D. 93,000,000 $9,000,000 part Of $10,000,000 $2,000,000 part of 310.000,000 $10,000,000 part of $25,000,000 $5,000,000 part of $29,000,000 $10,000,000 pert of $29,000,000 $1,000,000 Combtoed 2.1. 6 P.D, $5,000.000 $10,000,000 $10,000,000 part $3l, 0$0290,,000000,p00a0rt Of $29,000,000 $10,000,000 part uf $29,000,000 --j u i . /4. /UU I I I : bUAM ' KUbt, _KLh 1N_&_MAKlAij NO. 8 9 2 1 'P. 40' - -- - - --- .4 r Term Insurance . Company Policy No. 1/1/50-81 National Union Tire Insurance Company of mtshurjn, r* GIA127Q028RA lee I'mbefll* Limit SS ,`000,000 i/i/o-si Horn Inurine Company HBC983&171 2nd Umbrella Limit* SlQ.OQO.Oqo excess of 93.000,000 1/1/80-81 Firemen's Fund Insurance Company XLX1372347 3rd Umbrella limits 823,000,000 excess ef 515,000.000 1/1/80-81 l/l/ao-ai i/i/ao-ai 1/1/79-80 Firemen's Fund insurance Company Karttoed Accident & Indemnity company National Union Fire Insurance Company of Pittsburgh, PA National Uaion Fi^re Insurance Company of Pittsburgh, PA XLX1372348 10XS100B95 9782437 GLA1269100 1st Umbrella Unit* $5.000,000 1/1/79-8C Hone Inauranc* Company HEC9802011 2nd Umbrella limit* $10.000.000 excess of SS.000.000 1/1/79-80 Firemen's Fund Insurance Company XUC13894AA 3rd Umbrella limits $25,000,000 excess of 515.000,000 1/1/79-80 1/1/79-00 1/1/79-80 Aetna Casualty A 9urtty Company Hertford Accident A Indemnity Company National Union Firn Insurance Company of Pittsburgh, PA 01XNZ095WCA 10X9100747 1229374 . i Limits of Liability 51,000,000 Confined 8.1- 5 t.a. $5,000,000 $10,000,000 $10,000,000 part of 525,000,000 $5,000,000 part of $25,000,000 $10,000,000 part at $25,000,000 $1 ,000,000 Combined B.I. E. P.O. 55,000,000 $10,000,000 $10,000,000 part Of $25,000,000 $5,000,000 part ef $25,000,000 $10,000,000 part of $25,004,000 . . , J U L . 24. 2001 11:50AM ' ROSE, J L E I N J J I A R I A S NO, 8921 P. 41 Term 1/1/7S-79 Insurance Company Policy Mo. Aetna Insurance Company CG1J8612 1st Umbrella Limita 3S.OOO.OOO 1/1/79-79 Hama Insurance Compsny HEC9655432 2nd Umbrella Limits $10,000,000 excasa of Si.000,000 l/l/Tfl-79 firemen'J Fund Insurance Company 30X2199648 3rd Umbrella Ilmira 320,000,000 excess of $13.000.000 1/1/73-79 1/1/73-79 1/1/78-79 1/1/78-79 1/1/77-78 Acta* Casualty & Surety Company Hartford Accident & Indemnity Company Midland loauraae* . Company National Union Fir Insurance Company at Plttsburih, FA Aetna Insurance Company 0120(15 70WC 10X3100398 XIUO3O0 1229374 CC569390CC 1st Umbrella limits $10,000,000 exeasa of S3.000,000 1/1/77-78 Hoorn Insurance Company HEC9343894 2nd UmbreT".a Units 910,000,000 excess of $5.000.000 1/1/77-78 Aitna casualty & Juraty Company , oi3orii7w:A 3rd Umbrella Limita 53,000,000 xcris of 513,000,000 1/1/77-78 Hartferd Accident k Indemnity Campany 011(3100131 Limits of Liability SL,000,000 Combined b.i. & p.o, $5,000,000 $10,000.000 $10,000,000 part of $25,000,000 $3,000,000 part of $25,000,000 $3 ,000,000 part of $23,000,000 $5,000,000 pact of 25,000,090 . 51,000,000 Combined 3.1. Si P.D. $5.000,000 $10,000,000 $3,000,000 ( 1 T*rm 7navirune? Company Policy No. -th I'mbrallj Limits af Liability 520.000.000 exert of 1/1/77-78 1/1/77-78 1/1/77-78 1/1/77-78 Aetna Casualty 8 Suracy Company Firemen's Fund Insurance Company Hidlmd Insurance Company National Union Fire Insurance Company of Pittsburgh, PA 01XJT1339WCA X1X1267210 XL152151WW 1224281 1/1/7S-77 Aetna Insurance Company CC870877 1st Umbrella Limita of Liability $10,000,000 6/30/78*77 American Hone Assurance 3E1118800 Company . 2nd Ombrella Limit SIO.0 0 0 .0 0 0 acesa of $1 0 ,0 0 0.00 0 6 /30/74-77 Aetna Casualty fi OUOB72WCA Surety Company 1/1/75-76 Aetna Insurance Company CG67403O 1/1/78-73 Aetna Insurance Company CG299S90 lat Umbrella Limits 83,000,000 4/30/71-74 ' American i m Asaurancc 1E273073S Company 2nd Umbrella Limita 85.000.000 area of SS.000,000 4/1/73-6/30/74 Aetna Casualty Surety Company Q1XW393WCA 1/1/73-74 Aetna Insurance Company CG230385 finita of Liability .000,000 $5,000,000 part of $20,000,000 $5,000,000 part af $20,000,000 $5,000,000 part of $20,000,000 $3 ,000,000 part or $20,ooa,o0o $1,000,000 Combined B.l, & P.D. 310,000,000 $10, 000,000 $500,000 Combined! B.t. & f.a. $300,000 Combined 3.1. t P.ti. $5,000,000 $5.000,000 $500,000 Combined 3.1. i P.D. ** 60'3Std, TlOi ** liberty Mutual Liberty Mutuai Aetna In. Co Aetna Ins. co Aetna Ina. CO ISA American Korne National Union A e tn a CSB A itila CSS KENT TIE ' FLOORS srimar* 300,000 CIL 500,000 CSt WJl -12 3-010533-oj IS tCl-ia3~0105330022B 500,000 CSX, 500,000 CSt 500,000 . CG S301M CG 259590 CG 674030 4 BU3 UMBRELLA 1/ 1/71-72 1/73-73 1/1/73-74 1/1/74-75 1/1/7S-7S 3MM . xac 4193a ima 10 MM *X 2730735 BE X11BS00 EXCES* UMBRELLA y/ 5MM X 5MM <Uf393 MCA 10KH X 10MM 01xn3?2 WCA 4/30/69-71 iV V/30/Xlx74' 6/30/74-77 4/1/73-6/30/74 5/30/74-1/1/77 _ T, ' (tk.Vn-t-'l. ~ k *& P u- asioi -j ^J lUi t..J1ijM -W 13 > L U A ( -^_ w U i u- W'i Hy- t-hii k-rH'-e- ..24 2001 1 1 : 5 1 A M ` ROSE, _ K L E I N _ & _ M A R 1AS NO. Wl 1 R. 44 1 VERIFICATION 2 I, ROCCO SERGI am an agent of Kentije Floors, Inc. I have 3 read the attached Responses of Kentile Floors, Inc. dated 4 April 25, 1988, to plaintiff Herman Kort's Interrogatories to 5 Kentile Floors, Inc. I am informed and believe that the matters 6 stated therein are true. 7 I declare under penalty of perjury under the laws of the 8 State of California that the foregoing is true and correct. 9 Executed on the 10 New York. 11 Ttt day of April, 1988, in Brooklyn, 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UL. IWOC, _M Ll HC ivu. m i I r. 45 {VERIFICA TION - 446 and 2015.5 C.CJ'J STATE OF CALIFORNIA, 1 County o f_______________ /, the Undersigned, say: I am the 2 43 intheabove entitled action; I have read the foregoing 5 and know the contents thereof; and that the same u true of m y own knowledge, except as to the matterr which are 6 therein stated upon my information or belief, and as to those matters that I believe it to be true. 7 I certify (or declare) under penalty o f perjury, that the foregoing is true and correct. 98 Executed on (d(c) (piece) 1110 Type or Print Name _____ .__________ Signature (PROOF OF SERVICE BY MAIL 1013,2015.5C.C.P.) 12 STATE OF CALIFORNIA y county nr Los Angelas____ 13 I m a retident of/employed in the county aforesuid; I am over the age of eighteen years and not a party to fit within 14 entitled action, my business address/residence address is: 15 700 South Flower, Suite 700, Los Angeles CA 90017,____________ 16 Qn _______^ ^____________________________ 9 I served the within RESPONSES OF__________ 17 DEFENDANT KBNTILE FLOORS, INC. TO INTERROGATOR!F.S PROPOONTIPn_____ BY PLAINTIFF HERMAN KORT on (Ai interested parties_________________ ________________ . 18 in said action, by placing a true copy thereof enclosed in a sealed envelope with portage thereon fully prepaid, in the 19 United States mail a t ____ Los Angeles,-- California/------------------------20 addressed as follows: 21 SEE ATTACHED SERVICE LIST 22 23 24 I certify (or declare), under penalty o f perdry,* that the foregoing is true and correct. 25 Executed on 26 April 28 , 1988 (date) .at- Loa Angeles (Piece) ., California 27 BONNIE BAILEY 28 Type or Print Name lAA--- Signature f H. UUl J 1:bW ROSE. JLEINJJARIAS 1 SERVICE LIST 2 Rose, Klein & Marias 3 801 South Grand Avenue, 18th Floor 4 Los Angeles, CA 90017 . Gary Sharp, Esq. 5 Shield & Smith 1055 Wilshire Blvd., 19th Floor 6 Los Angeles, CA 90017 7 Andrew Stein, Esq. Yusim, Stein & Hanger 8 16501 Ventura Blvd. Suite 300 9 Encino, CA 91436 10 Norby & Brodeur 21535 Hawthorne Blvd. 11 Suite 200 Torrance, CA 90503 12 13 Alvin Cassidy, Esq., Cassidy, Warner, Brown, Combs & Thurber 14 600 West Santa Ana Blvd. Suite 400 15 Santa Ana, CA 92701 16 Kincaid, Gianun2 io, Caudle & Hubert P. O. Box 1828 17 Oakland, CA 94604 18 19 20 21 22 23 24 25 26 27 28 NO. 89 21 P. 46'