Document 4JEORq33Q8YEBeGKX5Vg856jp

<> '/C . c PLAINTIFF'S EXHIBIT 1 II SEDGWICK,. DETERT, MORAN & ARNOLD STEPHEN JONES (Bar No. 040884) 2 || BERRIDGE R. MARSH (Bar No. 077304) 001 MAR 30 HOLLY A. HARRIS (Bar No. 132336) 3 || One Embarcadero Center, 16th Floor San Francisco, California 94111-3765 4 II Telephone : -(415) 781-7900 5 || Attorneys for Defendant POI- mt CHEVRON PRODUCTS COMPANY VfcKIF. 6 " LDF_ AH 8= 55 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO 10 11 " IN RE: COMPLEX ASBESTOS 12 || LITIGATION 13 14 ) NO. 828684 ) ) RESPONSES OF DEFENDANT CHEVRON ) PRODUCTS COMPANY TO PLAINTIFFS' ) STANDARD INTERROGATORIES TO ALL ) DEFENDANTS 15 PROPOUNDING PARTY: PLAINTIFFS 16 RESPONDING PARTY: 17 II SET NUMBER: DEFENDANT CHEVRON PRODUCTS COMPANY GENERAL ORDER 129 18 19 | Defendant CHEVRON PRODUCTS COMPANY, a division of 201| CHEVRON U.S.A. INC. (hereinafter "Chevron"), provides the 21 following objections and responses to San Francisco Superior 22 Court General Order No. 129 Plaintiffs' Standard Interrogatories 23 || to All Defendants as follows: 24 || 25 || PRELIMINARY STATEMENT Defendant's responses are based upon as diligent and 26 || complete an inquiry as possible as of this date and are subject 27 to corrections for errors, mistakes or omissions. Defendant SEOCWICK detert mou'ob anticipates that additional discovery, investigation, and & ARNOLD 1 One Embtrcvlero Center Sixteenth Floor Sw Francieco. Coliform* 94111-3765 Tel 415.781.7900 SDSF3/15506 1 analysis `may supply additional facts, add meaning to known facts, 2 or establish new factual and legal contentions. Accordingly, the 3 responses set forth herein are given without prejudice to 4 Chevron's right to produce evidence of any subsequently 5 discovered facts, writings, or interpretations thereof, or to 6 modify or amend the responses. 7 Chevron objects to each interrogatory to the extent that it 8 seeks information protected from disclosure by the attorney 9 client privilege, the attorney work product doctrine, Code of 10 Civil Procedure section 2018, Code of Civil Procedure section 11 2034, and/or any other applicable privilege. Chevron further 12 objects to each interrogatory to the extent that it seeks 13 disclosure of information'which is confidential business,' 14 proprietary or trade secret matter. 15 Subject to and without waiving the foregoing objections, all 16 of which are incorporated by reference into each and every 17 response below. Chevron responds as follows: 18 INTERROGATORIES 19 INTERROGATORY NO. 1: 20 IDENTIFY the person verifying these answers on YOUR behalf. 21 RESPONSE TO INTERROGATORY NO. 1: 22 23 24 25 /// 26 H.P. Walker Assistant Secretary Chevron U.S.A. Inc. 575 Market Street San Francisco, California 94105 (please contact through undersigned counsel) 27 28 2 1 INTERROGATORY NO. 2: 2 State the date of first employment with YOU, and the'dates 3 and titles of each job position the person verifying these 4 interrogatories has held while employed by YOU. 5 RESPONSE TO INTERROGATORY NO. 2: 6 First date of employment: 1977. 7 1977-1987: Mr. Walker worked for Chevron U.S.A. Inc. 8 and/or other Chevron entities as division manager and held other 9 related titles. 10 1987-present: Assistant Secretary of Chevron U.S.A. 11 Inc. 12 INTERROGATORY NO. 3: 13 State whether or not YOU are a corporation, and if s'o; 14 state: 15 A. YOUR correct corporate name; 16 B. YOUR state of incorporation; 17 C. The date of YOUR incorporation; 18 D. The address of YOUR principal place of business; 19 E. Whether or not YOU have ever held a certificate of 20 authority to do business in the State of California, and if so, 21 the inclusive dates of any certificate; 22 F. If YOU are wholly owned or the majority interest of YOUR 23 company is owned by another business entity, state the entity's 24 name and principal place of business; 25 G. Whether YOU have any business offices in California, and, 26 if so, YOUR principal place of business in California. 27 Ill 2'8 III SDSF3/15506 3 1 RESPONSE TO INTERROGATORY NO 3: 2 Yes 3 A. Chevron U.S.A. Inc. (dba) Chevron Products Company. 4 B. Pennsylvania. 5 C. August 19, 1922. 6 D. 575 Market Street, San Francisco, CA 94105. 7 E. Yes. January 18, 1965. 8 F. Not applicable. 9 G. 575 Market Street, San Francisco, California 94105. 10 INTERROGATORY NO. 4: 11 Have YOU ever been identified, known, or done business under . 12 any other name in the State of California? 13 RESPONSE TO INTERROGATORY NO. 4: 14 Yes. 15 INTERROGATORY NO. 5: 16 If your answer to Interrogatory No. 4 is in the affirmative, 17 please state such name or names and the time period during which 18 THIS DEFENDANT was so known or identified. 19 RESPONSE TO INTERROGATORY NO. 5: 20 Standard Oil Company of California was incorporated in 21 Delaware on January 27, 1926. Standard Oil Company of 22 California, Western Operations, Inc., was organized as a Nevada 23 corporation on December 10, 1956. Effective 1/31/62, it was 24 merged into the Standard Oil Company of California and then 25 operated as a.division until 12/31/76, with no name change. 26 Although "Inc." was included in the name, it was not a separate 27 corporation but functioned as a division. Chevron U.S.A. Inc. 28 was created effective 1/1/77 and Standard Oil Company of SDSF3/15506 4 1 California made a capital contribution of the division's assets 2 to Chevron U.S.A. Inc. effective that date. Western Operations, 3 Inc. and/or Standard Oil Company of California ran the Richmond 4 Refinery until Chevron U.S.A. Inc. was created. Pursuant to a 5 1985 merger. Chevron U.S.A. Inc. was also formerly known as Gulf 6 Oil Corporation. From 1992 to 1996, Chevron U.S.A. Inc. operated 7 as Chevron U.S.A. Products Company, and as Chevron Products 8 Company from 1996 to the present as to the Richmond Refinery. 9 INTERROGATORY NO. 6; 10 If YOU are not a corporation, what is YOUR business 11 structure (partnership, joint venture, sole proprietorship, 12 etc.) . 13 RESPONSE TO INTERROGATORY NO. 6: `- 14 Not applicable. Please see response to Interrogatory No. 3. 15 INTERROGATORY NO. 7; 16 If YOU are not a corporation, please IDENTIFY all persons or 17 other entities with an ownership interest in YOU. 18 RESPONSE TO INTERROGATORY NO. 7: 19 Not applicable. Please see response to Interrogatory No. 3. 20 INTERROGATORY NO. 8: 21 If you are not a corporation, please state the following: 22 A. The address where the HISTORICAL RECORDS of THIS 23 DEFENDANT are currently located; and 24 B. The name, job title and current address of the Custodian 25 for THIS DEFENDANT'S HISTORICAL RECORDS. 26 As used herein, "HISTORICAL RECORDS" shall include all 27 DOCUMENTS relating to the formation of THIS DEFENDANT, all 28 minutes of partners', general partners', or other owners' SDSF3/15506 1 meetings,- and all DOCUMENTS relating to THIS DEFENDANT'S merger 2 with, acquisition of or purchase, or sale of or by any other 3 COMPANY. 4 RESPONSE TO`INTERROGATORY NO. 8: 5 Not applicable. Please see response to Interrogatory No. 3. 6 INTERROGATORY NO. 9: 7 IDENTIFY YOUR custodian of Business Records. 8 RESPONSE TO INTERROGATORY NO. 9: 9 Chevron has offices located in many states. Business 10 records are located in many of these offices. Without greater 11 specificity as to the nature of the business records sought. 12 Chevron is unable to provide a Custodian of Business Records or a 13 location of these records. Subject to the foregoing statement. 14 documents which Chevron believes to be responsive to these 15 interrogatories are maintained by Steve A. Cavazos, who may be 16 contacted through the undersigned counsel of record. 17 INTERROGATORY NO. 10: 18 IDENTIFY the person or persons most knowledgeable about: 19 A. YOUR acquisition of RAW ASBESTOS and/or ASBESTOS 20 CONTAINING PRODUCTS; 21 B. YOUR use of RAW ASBESTOS and/or ASBESTOS CONTAINING 22 PRODUCTS; 23 C. YOUR contracting with others to do work involving use or 24 handling of RAW ASBESTOS or ASBESTOS CONTAINING PRODUCTS. 25 RESPONSE TO INTERROGATORY NO. 10: 26 A-B. Chevron has no one person who is most knowledgeable 27 SEOCvnCK, OETERT MORA^OP UVOIO One EnbtKi4ero Center Sixteenth Floor Son Frincuco. Celifonun 94111-3765 Tel 415.781 7900 regarding its acquisition and/or use of RAW ASBESTOS and/or ASBESTOS CONTAINING PRODUCTS. _ Any RAW ASBESTOS acquired by SDSF3/15506 6 1 Chevron would have been for use in the manufacture of certain 2 coating products which was discontinued in 1984. Chevron'does 3 not currently employ any person who would be most knowledgeable 4 about the acquisition of RAW ASBESTOS for use in its former 5 manufacture of such coating products. 6 As to ASBESTOS CONTAINING PRODUCTS, Chevron has employed 7 personnel whose responsibilities may have included the 8 acquisition of ASBESTOS CONTAINING PRODUCTS for Chevron's various 9 areas of operations. Chevron's primary business operation is and 10 always has been the exploration, production, transportation. 11 refining and marketing of petroleum products. It is likely that 12 the use of products which contained asbestos occurred as a result 13 of work performed by contractors who would have supplied "the 14 products used. Consequently, Chevron is unable to name a 15 particular person or defined `group of people to designate as a 16 "person most knowledgeable" about its acquisition and/or use of 17 ASBESTOS CONTAINING PRODUCTS. 18 C. Chevron has employed numerous personnel whose 19 responsibilities, at least at some time, may have included 20 contracting for work involving the use and/or handling of RAW 21 ASBESTOS and/or ASBESTOS CONTAINING PRODUCTS for Chevron's 22 various areas of operations. Consequently, Chevron is unable to 23 name a particular person or defined group of people to designate 24 as a "person most knowledgeable" about its contracting operations 25 during the relevant time period. 26 Ill 27 S E 0 C W 1 C K. OETERf MOftAN? & ARNOLD One Eaabtrctder* Center Sixteenth F^r Sen Fruteteco. Ctliforai* 94111-3765 Tel. 415.781.7900 III III SDSF3/15S06 1 1 INTERROGATORY NO. 11: 2 For DEFENDANTS involved in the MARKETING of ASBESTOS 3 CONTAINING PRODUCTS, state the IDENTITY of physicians, medical 4 directors and/or industrial hygienists employed by YOU during the 5 time frame or prior to the time YOU discontinued the marketing of 6 such products. All other DEFENDANTS need only respond as to 7 medical directors and/or industrial hygienists or physicians 8 employed in the area of employee health and safety. PREMISES 9 owners and domestic corporations need only respond as to the 10 United States. 11 RESPONSE TO INTERROGATORY NO. 11: 12 Industrial Hvaienists: S. Drvden, S.H. Judd and 13 J.A. Spence 14 Medical Directors: R.E. Swencicki 15 Chevron requests that the above persons be contacted through 16 the undersigned counsel of record. 17 INTERROGATORY NO. 12: 18 Has any employee of THIS DEFENDANT testified by deposition 19 or at trial on behalf of THIS DEFENDANT in a third party case, in 20 which THIS DEFENDANT was a party, wherein the plaintiff has 21 alleged an asbestos related injury? If so, for each such third 22 party case (except that Premises Defendants and Contractor 23 Defendants need answer only with respect to cases relating to 24 sites within the GEOGRAPHIC AREA) please state: 25 A. The caption and case number; 26 B. The court filing including state and county; 27 SEOCWICK,' OETERT M O R 6 ARNOLD H III III One Embtxccdero Center Sixteenth Floor Sen Frtftcuca. Cxliform* 94111-3765 Tel. 415 781.7900 SDSF3/15S06 8 1 Cl The date of deposition or trial testimony; 2 D. The name and address of plaintiff's counsel of record; 3 E. The name and address of the court reporter. 4 RESPONSE TO INTERROGATORY NO. 12; 5 Chevron is aware of the following employee depositions 6 as to the Richmond Refinery: 7 William M. Alberigi A. Harvey Steele v. Johns-Manvilie Corporation, et 8 al. Contra Costa Superior Court Case No.: 167271. B. Contra Costa County, California 9 C. March 12, 1980. D. George W. Kilbourne, Esq. 10 70 Doray Drive Pleasant Hill, CA 94523 11 E. Valerie L. Chedwick, CSR# 3081 Aiken & Cistaro 12 1404 Franklin Street Oakland, CA 94612 13 Kenneth T. Clapp 14 A. In Re: Bravton 11: Boone. Glen v. Abex Corporation, et al. 15 San Francisco Superior Court Case No.: 910118 Dennis. Harrold v. Abex Corporation, et al. 16 San Francisco Superior Court Case No.: 902130 Fairchild. Svcbert Steve and Louise v. Abex 17 Corporation, et al. San Francisco Superior Court Case No.: 925508 18 Gertz, Robert and Marvel v. Abex Corporation, et al. 19 San Francisco Superior Court Case No.: 911716 Gray, Michael v. Abex Corporation, et al. 20 San Francisco Superior Court Case No.: 897887 B. San Francisco County, California 21 C. February 28, 1992. D. Brayton, Gisvold & Harvey 22 999 Grant Avenue PO Box 2109 23 ' Novato,- CA 94948 E. Judy L. Macchello, #6060 24 Tooker & Antz 131 Steuart Street 25 _ San Francisco, CA 94105 26 III 27 S OCWICK peterr moga 0 6 *rnold One Emb*rc*4ro Center Sitttenth Floor Sen FraJKioc*. Caltfonu* 94111-3765 Tel. 415.761.7900 III III SDSF3/15506 9 1 ' John Driscoll A. In Re: Complex Asbestos Litigation 2 San Francisco Superior Court Case No.: 828864 B. San Francisco County, California 3 C. June 6, 1991. D._ Law Offices of Brayton & Associates 4 999 Grant Avenue Novato, CA 94948 5 E. Marjorie K. Forman, CSR #2783 Tooker & Antz 6 131 Steuart Street San Francisco, CA 94105 7 Stanley Bryden 8 A. In Re: Complex Asbestos Litigation San Francisco Superior Court Case No.: 828684 9 B. San Francisco County, California C. September 18, 1991. 10 D. Law Offices of Brayton & Associates 999 Grant Avenue 11 Novato, CA 94947 E. Frederick R. Tooker, CSR# 890 12 Tooker & Antz 131 Steuart Street 13 San Francisco, CA 94105 14 Stanley H. Judd A. Gene G. Blalock and Ellen Marie Blalock v. 15 Ravbestos-Manhattan. et al. San Francisco Superior Court Case No.: 938511 16 B. San Francisco County, California C. May 20, 1992. 17 D. Law Offices of Cartwright, Slobodin, Bokelman, Borowsky, Wartnick, Moore' & Harris 18 101 California Street, 26th Floor San Francisco, CA 94111 19 E. Juliette F. Finley, CSR# 2521 Tooker & Antz 20 131 Steuart Street San Francisco, .CA 94105 21 Raymond O. MeDown 22 A. Harvey Steele v. Johns-Manville Corporation, et al. 23 Contra -Costa Superior Court Case No.: 167271 B. Contra Costa County, California 24 C. May 19, 1980. D. Law Office of George W. Kilbourne 25 70 Doray Drive, Suite 20 Pleasant Hill, CA 94523 26 E. Valerie L. Chedwick, CSR# 3081 Aiken & Cistaro 27 1404 Franklin Street Oakland, CA 94612 8 SDSF3/1S506 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 __S D C W | c K o'etIrt MpgAij)g 6 ARNQL O One Emb*rctdero Center Sixteenth Floor Sen FnuKitco. Celifonuo 94111-376$ Tel 41S.781.7900 /// SDSF3/15506 Raymond McDown A. Corbett C. Redford Sr., and Dorothy M. Redford v. Ravbestos-Manhattan. Inc... et al. San Francisco Superior Court Case No.: 937761 B. San Francisco County, California C. March 27, 1992. D.~ Law Offices of Cartwright, Slobodin, Bokelman, Borowsky, Wartnick, Moore & Harris 101 California Street, Suite 2600 San Francisco, CA 94111 E. Renee Sera, CSR# 7435 Tooker & Antz 131 Steuart Street San Francisco, CA 94105 Raymond McDown A. Warren G. Savior v. Johns-Manvilie Sales Corporation, et al. Alameda County Superior Court Case No.: 533245-2 B. Oakland, Alameda County, California C. March 21, 1984. D. Law Offices of Steven Kazan 171 Twelfth Street Oakland, CA 94612 E. Susan Williams, CSR# 4784 - Aiken & Welch 1404 Franklin Street Oakland, CA 94612 John A. Spence .. A. Harold Dennis v. Abex Corporation, et al. San Francisco Superior Court Case No.: 902130 B. San Francisco County, California C. November 7, 1991. D. Law Offices of Brayton & Associates 999 Grant Avenue Novato, CA 94948 E. Cynthia L. Manning, CSR# 7645 CalNorth Reporting Service 3510 Unocal Place, Suite 111 Santa Rosa, CA 95403 Bill Torchia A. In Re: Complex Asbestos Litigation ' San Francisco Superior Court Case No.: B. San Francisco County, California C. June 6, 1991. D. Law Offices of Brayton & Associates 999 Grant Avenue Novato, CA 94948 E. Marjorie K. Forman, CSR #2783 Tooker & Antz 131 Steuart Street San Francisco, CA 94105 828864 11 1 INTERROGATORY NO. 13: 2 For each of the following, please state whether, at any time 3 within the time frame or until such time as any defendant which 4 had been engaged in MARKETING RAW ASBESTOS or ASBESTOS CONTAINING 5 PRODUCTS discontinued the MARKETING of such products, THIS 6 DEFENDANT was a member or paid dues for any representative of 7 THIS DEFENDANT (excluding faculty members of educational 8 institutions) to be a member of the following: 9 RESPONSE TO INTERROGATORY NO. 13: 10 Defendant and/or defendant's employees may have at some time 11 been a member or members of one or more of the above-referenced 12 associations or professional organizations. Given the large 13 number of employees employed by defendant during the relevant 14 time period, it is impossible to identify all such memberships. 15 Subject to the foregoing statement. Chevron is presently aware of 16 the following memberships: 17 A. American Conference of Governmental Industrial 18 Hygienists; 19 A. No. 20 B. American Industrial Hygiene Association; 21 B. Yes. 22 C. American Petroleum Institute; 23 C. Yes. 24 D. American Railroad Association; 25 D. No. _ 26 E. Asbestos Cement Producers Association; 27 III 28 III SDSF3/15506 12 E. - No. F. Asbestos Information Association (AIA) (please answer through date of your answers); F. No. G. Asbestos Information Association/North America (AIA/NA) 6 (please answer through date of your answers); 7 G. No. 8 H. Asbestos Textile Institute (ATI); 9 H. No. 10 I. Industrial Hygiene Foundation and/or Industrial Health 11 Foundation (IHF): 12 I. Yes. 13 J. Industrial Mineral Insulation Manufacturers Institute; 14 J. No. 15 K. Magnesia Insulation Manufacturers' Association; <-- 16 K. No. 17 L. Magnesia Silica Insulation Manufacturers Association; 18 L. No. 19 M. Mineral Wool Institute; 20 M. No. 21 N. National Insulation Manufacturers Association (NIMA); 22 N. No. 23 O. National Safety Council; 24 O. Yes. 25 P. New_York Academy of Sciences; 26 P. Unknown. 27 Q. Quebec Asbestos Mining Association (QAMA); Q. No. 13 1 R. . Refractories Institute; 2 R. No. 3 S. Safe Building Alliance (please answer through date of 4 your answers') ; 5 s. No. 6 T. Thermal Insulation Manufacturers Association (TIMA); 7 T. No. 8 U. U.S. Maritime Commission; 9 u. No. 10 V. IDENTIFY any other organizations. associations or 11 groups of manufacturers, miners, distributors, importers, 12 labelers, suppliers, and/or sellers of ASBESTOS CONTAINING 13 PRODUCTS of which THIS DEFENDANT was a member; -- 14 V. Chevron and/or its employees have been members of 15 various business groups and associations. Chevron is unaware of 16 whether any other members of those organizations may have been 17 manufacturers, miners, distributors, importers, labelers, 18 suppliers, and/or sellers of ASBESTOS CONTAINING PRODUCTS. 19 Consequently) Chevron is unable to identify at this time all of 20 the groups and associations that may be relevant to this 21 Interrogatory. Subject to the foregoing statement, Chevron does 22 not believe it was a member of any organizations, associations or 23 groups who were comprised solely of manufacturers, miners, 24 distributors, importers, labelers, suppliers, and/or sellers of 25 ASBESTOS CONTAINING PRODUCTS. 26 W. IDENTIFY any such representative of THIS DEFENDANT. Chevron is unable to determine the identity of all employees who attended any meetings of the above associations. Chevron is 14 1 aware that certain of its personnel attended conferences and 2 meetings of various organizations in an attempt to learn of 3 potential hazards in the workplace. 4 INTERROGATORY NO. 14: 5 For each organization, association or other entity 6 identified in YOUR Response to Interrogatory No. 13, please 7 state: 8 A. The dates during which THIS DEFENDANT was a member; 9 B. The name(s) of any publication(s) received by THIS 10 DEFENDANT from such association or organization; 11 C. The name of any committee or subcommittee of which THIS 12 DEFENDANT was a member, and the dates of such committee or 13 subcommittee membership. 14 RESPONSE TO INTERROGATORY NO. 14: 15 A. American Petroleum Institute: Approximately 1965 to the 16 present. 17 American Industrial Hygiene Association: Dates 18 Unknown. 19 Industrial Hygiene Foundation: 1955-1960. 20 National Safety Council: Dates Unknown. 21 B. Chevron and/or its employees subscribed to and 22 undoubtedly received numerous business, technical and 23 professional publications during the relevant time period. As to 24 this interrogatory, these include, but are not limited to: 25 American- Petroleum Institute: Abstracts of Petroleum 26 Refining and Petrochemicals: Abstracts of Refining Patents 27 III 28 III 15 1 C'. Membership in committees and/or subcommittees known at 2 this time include the Medical Advisory Committee, the Health & 3 Biological Science Committee and the Industrial Hygiene Committee 4 of the American Petroleum Institute. 5 INTERROGATORY NO. 15: 6 Had THIS DEFENDANT prior to 1973 received any DOCUMENTS 7 containing results or conclusions of any studies and/or tests 8 conducted by Bonsib for Standard Oil of New Jersey relating to 9 asbestos exposure in the work place or the human health 10 consequences of exposure to asbestos? If so: 11 A. Either (1) attach all DOCUMENTS evidencing the 12 information sought in this Interrogatory and its subparts to your 13 answers to these Interrogatories, or (2) attach disks containing 14 such data, or (3) describe such DOCUMENTS with sufficient 15 particularity that they may be made the subject of a request for 16 production of documents. 17 B. State the date upon which THIS DEFENDANT first received 18 such DOCUMENTS; 19 C. State the IDENTITY of the custodian of such DOCUMENTS. 20 D. This interrogatory does not apply to DOCUMENTS contained 21 in a library maintained by a DEFENDANT hospital or a DEFENDANT'S 22 library providing access to the general public. 23 RESPONSE TO INTERROGATORY NO. 15: 24 Chevron is not aware of having received any such 25 document(s) before 1973. 26 Ill 27 III III 16 INTERROGATORY NO. 16: Had THIS DEFENDANT prior to 1973 received a copy or any portion of any studies and/or tests conducted by' any insurance 4 company, including but not limited to Metropolitan Life Insurance 5 Company and Aetna Insurance relating.to asbestos exposure in the 6 work place or the human health consequences of exposure to 7 asbestos? If so: 8 A. Either (1) attach all DOCUMENTS evidencing the 9 information sought in this Interrogatory and its subparts to your 10 answers to these Interrogatories, or (2) attach disks containing 11 such data, or (3) describe such DOCUMENTS with sufficient 12 particularity that they may be made the subject of a request for 13 production of documents. ' ' 14 B. State the date upon which THIS DEFENDANT first received 15 such DOCUMENTS; 16 C. State the IDENTITY of the custodian of such DOCUMENTS. 17 D. This interrogatory does not apply to DOCUMENTS contained 18 in a library maintained by a DEFENDANT hospital or a DEFENDANT'S 19 library providing access to the general public. 20 RESPONSE TO INTERROGATORY NO. -16: 21 Chevron is not aware of having received any such document(s) 22 before 1973. 23 INTERROGATORY NO. 17: - 24 Had THIS DEFENDANT prior to 1973 received any DOCUMENTS 25 containing results or conclusions of any studies and/or tests 26 conducted by any laboratory, including but not limited to, the 27 III 28 III 17 1 Saranac Laboratory relating to asbestos exposure in the work . 2 place or the human health consequences of exposure to asbestos? 3 If so: 4 A. Either (1) attach all DOCUMENTS evidencing the 5 information sought in this Interrogatory and its subparts to your 6 answers to these Interrogatories, or (2) attach disks containing 7 such data, or (3) describe such DOCUMENTS with sufficient 8 particularity-that they may be made the subject of a request for 9 production of documents. 10 B. State the date upon which THIS DEFENDANT first received 11 such DOCUMENTS; 12 C. State the IDENTITY of the custodian of such DOCUMENTS. 13 D. This interrogatory does not apply to DOCUMENTS contained 14 in a library maintained by a DEFENDANT hospital or a DEFENDANT'S 15 library providing access to the general public. 16 RESPONSE TO INTERROGATORY NO. 17: 17 Chevron is .not aware of having received any such document(s) 18 before 1973. 19 INTERROGATORYNO. 18: 20 Had THIS DEFENDANT (except for a defendant that is an 21 educational institution) prior to 1973 ever maintained a library 22 (or libraries) which contained books, articles, periodicals, 23 journals, and/or reference materials that related to the subjects 24 of asbestos, industrial hygiene, medicine, safety and/or 25 occupational disease. If so, state: 26 III 27 III III 18 A. The date each such library was established; B. The location of each such library; C. The IDENTITY of each librarian or other person in charge of such library. RESPONSE TO INTERROGATORY NO. 18: A-C. Chevron did not maintain a particular "library" dedicated in whole or substantial part to the retention of 8 materials related to the subjects of "asbestos exposure, 9 industrial hygiene, medicine, safety, and/or occupational 10 disease" during the relevant time period. There are collections 11 of publications located at various Chevron facilities which 12 relate to the subject matter of the operations of those 13 facilities. In addition, some of Chevron's industrial ' ' 14 hygienists, safety officers, and corporate medical directors may 15 have had in their possession various materials relevant to their 16 duties, which may have addressed topics referenced in this 17 Interrogatory. 18 INTERROGATORY NO. 19: 19 With the exception of OSHA compliance, had THIS DEFENDANT 20 (except for a defendant that is an educational institution) prior 21 to 1980 exchanged DOCUMENTS or communicated with any person or 22 other COMPANY expressly regarding the results of tests and/or 23 studies relating to asbestos exposure in the work place or the 24 human health consequences of exposure to asbestos? If so, state: 25 A. Each person or COMPANY with whom the information was 26 exchanged or to whom it was communicated. 27 B. The date(s) of any such exchanges or communications; C. The IDENTITY of the custodian of such DOCUMENTS. 19 1 RESPONSE TO INTERROGATORY NO. 19: 2 Defendant objects to this interrogatory to the extent that 3 it calls for information which is protected by the attorney 4 client privilege and the attorney work product doctrine. Without 5 waiving these objections. Chevron is aware of the following non6 privileged information: 7 A. Johns-Manvilie Corporation. 8 B. June 28, 1971. 9 C. The undersigned counsel of record has a copy of 10 the referenced document. 11 INTERROGATORY NO. 20: 12 Has any employee or designee of THIS DEFENDANT testified as 13 a representative of THIS DEFENDANT before the Occupational' Safety 14 and Health Administration, the National Institute of Occupational 15 Safety and Health, or any committee or subcommittee of the United 16 States Congress relating to asbestos exposure in the work place 17 or the human health consequences of exposure to asbestos? If so, 18 please state: 19 A. The entity before whom such testimony was given; 20 B. The date(s) and location(s) of such testimony; 21 C. The IDENTITY of the individual(s) who so testified; 22 D. Whether any DOCUMENTS were presented to the entity before 23 which testimony was given; 24 E. Whether copies of DOCUMENTS presented were retained by 25 THIS DEFENDANT and, if so, state the IDENTITY of the custodian of 26 such DOCUMENTS. 27 RESPONSE TO INTERROGATORY NO. 20: Not to the best of Chevron's knowledge at this time. 20 1 INTERROGATORY NO. 21: 2 Has THIS DEFENDANT (except for a defendant that is an 3 educational institution) conducted, or caused to be conducted, 4 tests, and/or studies of ambient asbestos dust created during the 5 manufacture, processing and/or assembling for sale of ASBESTOS 6 CONTAINING PRODUCTS? If so, state: 7 A. Each manufacturing facility, including location and 8 address, at which any such test and/or study was conducted; 9 B. The date of each such test and/or study; 10 C. The individual(s) or entity conducting each such test 11 and/or study; 12 D. Whether THIS DEFENDANT has any DOCUMENTS containing the 13 results and/or conclusions of each such study; `' 14 E. The IDENTITY of the custodian of such DOCUMENTS. 15 RESPONSE TO INTERROGATORY NO. 21: 16 Chevron objects to this interrogatory on the grounds that it 17 seeks information protected from disclosure because it is 18 confidential, proprietary and/or contains trade secret matters. 19 Without waiving this objection. Chevron responds that information 20 responsive to this interrogatory is contained in certain 21 documents, copies of which will be produced to plaintiffs' 22 counsel upon reasonable notice on a one time basis at a mutually 23 convenient time. 24 INTERROGATORY NO. 22: 25 Has THIS.DEFENDANT (except for a defendant that is an 26 educational institution) conducted, or caused to be conducted, 27 any tests and/or studies on ambient asbestos dust levels at any III 21 3 location .or job site where ASBESTOS CONTAINING PRODUCTS were installed, utilized or removed? If so, for the first 5 tests 3 and/or studies, state: 4 A. The `location, including name and address, at which each 5 such test and/or study was conducted; 6 B. The individual(s) or entity conducting each such test 7 and/or study; 8 C. The date of each such test and/or study; 9 D. Whether THIS DEFENDANT has any DOCUMENTS containing the 10 results and/or conclusions of each such test and/or study; 11 E. The IDENTITY of the custodian of such DOCUMENTS. 12 RESPONSE TO INTERROGATORY NO. 22: 13 The following information is provided, as to the first-five 14 tests identified to date, although it is unknown whether these 15 tests represent the first five tests performed: 16 1. A. R-3580 Reactor, Richmond Refinery. B. A.F. Christopher; Evan O'Reilly. 17 C. 11/3/72. D. Yes. 18 E. Undersigned counsel of record. 19 2. A. R-3560 and R-3580 Reactor, Richmond Refinery. B. A.F. Christopher; Evan O'Reilly. 20 C. 11/6/72. D. Yes. 21 E. Undersigned counsel of record. 22 3. A. E-3570A and E-3570B, Richmond Refinery. B. A.F. Chris t opher; Evan O'Reilly. 23 C. 11/7/72 .. D. Yes. 24 E. Undersigned counsel of record. 25 4. A. Area by Channel Street, Richmond Refinery. B. A.F. Christopher; Evan O' Reilly. 26 C. 11/8/72. D. Yes. 27 E. Undersigned counsel of record. /// 15506 22 1 5. A. Point Orient Wharf, Richmond Refinery. B. A.F. Christopher; Evan O'Reilly. 2 C. 11/16/72. D. Yes. 3 E. Undersigned counsel of record. 4 INTERROGATORY NO. 23: 5 Did THIS DEFENDANT (except for a defendant that is an 6 educational institution) have any laboratory or other similar 7 type of facility anywhere in the United States at which it 8 conducted, or caused to be conducted, any tests and/or studies of 9 ASBESTOS CONTAINING PRODUCTS or RAW ASBESTOS relating to the 10 health consequences of asbestos or the dust generated by any use 11 of asbestos or ASBESTOS CONTAINING PRODUCTS. If so, state: 12 A. The location, including name and address, at which each 13 test and/or study was conducted; 14 B. The individual(s) or entity conducting each such test 15 and/or study; 16 C. The date of each such test and/or study; 17 D. Whether THIS DEFENDANT has any DOCUMENTS containing the 18 results and/or conclusions of each such test and/or study; 19 E. The IDENTITY of the custodian of such DOCUMENTS. 20 RESPONSE TO INTERROGATORY NO. 23: 21 Chevron is unaware of any such tests or studies. 22 INTERROGATORY NO. 24: 23 Has THIS DEFENDANT made available to its employees a medical 24 examination program to determine the absence or presence of 25 asbestos related disease? If so, state: 26 A. Whether chest x-rays or pulmonary function tests were 27 part of such program(s); 28 /// 23 1 B'. Whether participation in any such program was a mandatory 2 condition of employment or was voluntary; 3 C. Whether THIS DEFENDANT has DOCUMENTS of such program(s),- 4 D. The IDENTITY of the custodian of such DOCUMENTS. 5 RESPONSE TO INTERROGATORY NO. 24: 6 A. Yes. 7 B. Voluntary. 8 C. Chevron objects to this Interrogatory to the extent that 9 it seeks information that may be confidential, privileged, 10 private, or otherwise protected from disclosure. Without 11 waiving this objection. Chevron responds: Yes. 12 D. To the extent that responsive, non-privileged documents 13 exist. Chevron will provide copies to the undersigned counsel of 14 record. 15 INTERROGATORY NO. 25: 16 Prior to 1973, did any person file a Workers' Compensation 17 claim for asbestos related injury against THIS DEFENDANT or 18 against any Workers' Compensation insurance carrier which 19 provided coverage for THIS DEFENDANT? If so, state the total 20 number of such claims and, for the first 20 such claims state: 21 A. The date of such claim; 22 B. The name of the claimant; 23 C. The case number; 24 D. The court in which the claim was filed; 25 E. The IDENTITY of THIS DEFENDANT'S custodian of DOCUMENTS 26 evidencing such claims. 27 Ill III SDSF3/15506 24 RESPONSE TO INTERROGATORY NO. 25: Defendant objects to this interrogatory on the grounds that seeks information that is confidential, privileged and protected from disclosure by the California Constitution, Article I, section 1. Chevron does not index or maintain the information sought by this interrogatory in a manner that would permit it to determine the number and dates of asbestos-related workers' compensation claims made against Chevron. Accordingly, to respond fully to this interrogatory, Chevron would have to 10 conduct a full review of every workers' compensation claim ever 11 filed against it. On this basis. Chevron further objects to this 12 interrogatory on the grounds that it is unduly burdensome. 13 Without waiving this objection, and subject thereto,- Chevron 14 states that it is not aware of any workers' compensation claim 15 for asbestos related injury having been filed against it prior to 16 1973. 17 INTERROGATORY NO. 26: 18 Does THIS DEFENDANT have insurance available to cover 19 judgment(s) entered against it in asbestos related personal 20 injury lawsuits? If so, state: 21 A. The name and principal*place of business of any insurance 22 carrier who has issued such policy of insurance; 23 B. The number and effective date of each policy; 24 C. The amount(s) of coverage of each policy; 25 D. The applicable dates of coverage. 26 Ill 27 III 25 1 RESPONSE:TO INTERROGATORY NO. 26: 2 Chevron objects to this interrogatory as being unduly 3 burdensome in that it would require Chevron to review every one 4 of its insurance policies to provide responsive information, and 5 there has been no showing that the requested information is 6 necessary or relevant to any potential judgment which may be 7 entered against Chevron in this litigation. Chevron further 8 objects to this interrogatory on the grounds that it seeks 9 information that may be confidential or protected from disclosure 10 by the attorney client privilege and/or attorney work product 11 doctrine. Without waiving these objections, and subject thereto. 12 Chevron does not carry insurance for the claims and injuries of 13 the nature and extent asserted by plaintiffs. Chevron does carry 14 catastrophic liability insurance, but its retention exceeds 15 potential exposure to liability in this lawsuit. 16 INTERROGATORY NO. 27: 17 State whether YOU have controlled, purchased, or in any way 18 acquired any controlling interest in any corporation or business 19 entity which has mined, manufactured, produced, processed, 20 compounded, sold, supplied, distributed and/or otherwise placed 21 RAW ASBESTOS of ASBESTOS CONTAINING PRODUCTS in the stream of 22 commerce. If so, state: 23 A. The name and address of said corporation or business 24 entity; 25 B. The dates YOU controlled, purchased or acquired any 26 interest; and 27 C. The nature of the business as it pertains to asbestos. iii i 26 1 RESPONSE TO INTERROGATORY NO. 27: 2 A-B. Socotex Company: November 27, 1936-December 15, 1936; 3 Bitumuls Company, Inc.: December 15, 1936-December 28, 4 1936; 5 American Bitumuls Company: December 28, 1936-August 13, 6 1951. 7 Stancal Bitumuls and Asphalt: Exact dates unknown. 8 American Bitumuls and Company: August 13, 1951-July 1, 9 1965. 10 Chevron Oil Company of California: January 3, 196111 December 31, 1976. 12 Chevron Asphalt Company: July 1, 1965-January L, 1977. 13 Standard Oil Company of California, Western Operations, 14 Inc.: December 10, 1956-February 1, 1962; 15 Western Operations, Inc. of California, a division of 16 Standard Oil Company of California: February 1, 196217 January 1, 1977. 18 C. Chevron has never been involved in the mining or 19 manufacturing of asbestos. Any asbestos used in the 20 manufacturing of any products was provided by outside vendors. 21 Some of the asbestos-containing coating products manufactured by 22 Chevron contained a minimal amount of chrysotile asbestos fiber 23 to increase the durability of the product when exposed to the 24 elements. The fibers were used as a bonding and temperature 25 resistant agent to ensure the structural integrity of the 26 components in which they were used. In each and every case where 27 asbestos fiber was used in a Chevron product, the fibers were 28 completely encapsulated and trapped in a benign matrix when it 27 entered the stream of commerce. No Chevron product incorporated asbestos as a primary ingredient in the composition of the product. Chevron's asbestos-containing coating products were sold in pre-mixed, liquid form. As such, it was physically impossible for asbestos fibers to escape from the matrix during 6 the installation of the product. 7 INTERROGATORY NO. 28: 8 State whether THIS DEFENDANT, between 1930 and 1985, has 9 ever engaged in the following activities with regard to RAW 10 ASBESTOS, and if so, state the inclusive dates of such activity: 11 A. Mining; 12 B. Milling; 13 C. Supply; 14 D. Importing; 15 E. Processing; 16 F. Distribution; 17 G. Marketing; 18 H. Sale; 19 I. Brokering. 20 RESPONSE TO INTERROGATORY NO. 28: 21 Chevron has not engaged in any of the listed activities. 22 INTERROGATORY NO. 29: 23 If YOUR answer to any of subparts of Interrogatory 28 24 regarding RAW ASBESTOS is in the affirmative, state: 25 A. The trade, brand name, and/or generic name of such RAW 26 ASBESTOS milled or MARKETED in any form or quantity between 1930 27 and 1985; III 28 B: The date(s) such RAW ASBESTOS was first placed on the market, including the date(s) such RAW ASBESTOS was first marketed; 1.* On an experimental basis; 2. On a test basis; 3. For sale. 7 C. The date(s) such RAW ASBESTOS: 8 1. Ceased to be produced; or 9 2. Was recalled from the market, if ever. 10 D. A description of the chemical composition of such RAW 11 ASBESTOS, including the type and/or grade of asbestos; 12 E. A description of the physical appearance and nature of 13 such RAW ASBESTOS, including any color coding, distinctive14 marking and/or logo on the packaging or container; 15 F. A detailed description of the intended use of such RAW 16 ASBESTOS, including any temperature limits for each such use; 17 G. Whether such RAW ASBESTOS was on the U.S. Government's 18 "Qualified Products List," and if so, the inclusive dates it was 19 on such list; 20 H. IDENTIFY to whom such RAW ASBESTOS has, at any time, been 21 sold. As to each such, state: 22 I. Whether any of THIS DEFENDANT'S RAW ASBESTOS has, at any 23 time, been sold, shipped, or otherwise distributed, used or 24 installed to or at any COMPANY (including power company or 25 utility), governmental agency or entity, shipyard, distributor, 26 refinery, contractor, supplier, PREMISE owner or occupant, ship 27 owner, or other PREMISE or site in the GEOGRAPHIC AREA and 28 III 29 1 whether any of THIS DEFENDANT'S RAW ASBESTOS has at any time, 2 been sold to any manufacturer, or manufacturing facility, of 3 ASBESTOS CONTAINING PRODUCTS. If so, state: 4 1. The names of each such COMPANY, governmental agency 5 or entity, shipyard, distributor, supplier, manufacturer or 6 refinery; 7 2. The inclusive dates of each such sale, and the 8 amount (quantity) and the trade brand name of such RAW ASBESTOS 9 sold; 10 3. The manner of shipment (e.g. boat, rail, etc.) 11 4. Whether you have any records indicating any such 12 sale or shipment and, if so, the name, address and job 13 classification of each person who currently has possession of 14 such records. 15 5. Either (1) attach all DOCUMENTS evidencing the 16 information sought in this Interrogatory and its subparts to your 17 answers to these Interrogatories, or (2) attach disks containing 18 such data, or (3) describe such DOCUMENTS with sufficient 19 particularity that they may be made the subject of a request for 20 production of documents. 21 RESPONSE TO INTERROGATORY NO. 29: 22 Not applicable. Please see response to Interrogatory No. 23 28. 24 INTERROGATORY NO. 30: 25 Between 1930 and 1985, did YOU ever engage in any of the 26 activities listed below with regard to ASBESTOS CONTAINING 27 PRODUCTS? If so, state the inclusive dates of such activity: III 30 A; Supply; B. Importing; C. Distribution; D. Marlceting; E. Sale; F. Labeling; G. Manufacturing; 8 H. Brokering. 9 RESPONSE TO INTERROGATORY 10 A. Yes. 11 B. No. 12 C. Yes. 13 D. Yes. 14 E. Yes. 15 F. Yes. 16 G. Yes. 17 H. No. 18 Please see defendant's response to Interrogatory No. 31 19 regarding specific dates. 20 INTERROGATORY NO. 31: 21 If your answer to any subpart of Interrogatory No. 31 22 regarding "ASBESTOS CONTAINING PRODUCTS" is in the affirmative, 23 state: 24 A. The trade, brand name, and/or generic name- of each such 25 kSBESTO CONTAINING PRODUCT MARKETED in any form or quantity 26 between 1930 and 1985; 27 III III 31 B. The date(s) each such ASBESTOS CONTAINING PRODUCT was first placed on the market, including the date(s) each such ASBESTOS CONTAINING PRODUCT was first MARKETED; 1. On an experimental basis; 2. On a test basis; or 3. For sale. C. The date(s) each such ASBESTOS CONTAINING PRODUCT: 1. Ceased to be produced; or 2. Was recalled from the market, if ever. D. A detailed description of the chemical composition of each such ASBESTOS CONTAINING PRODUCT, including the type and/or grade of asbestos and/or asbestos fiber contained in each such 13 product and the quantitative percentage of asbestos or asbestos 14 fiber in each such product, and all non-asbestos components of 15 the ASBESTOS CONTAINING PRODUCT, and if the chemical composition IS changed over time, the inclusive dates of each formulation; 17 E. A description of the physical appearance and nature of 18 each such ASBESTOS CONTAINING PRODUCT, including any color 19 coding, distinctive marking and/or logo, either on the product or 20 on the packaging; 21 F. A detailed description of the intended use of each such 22 ASBESTOS CONTAINING PRODUCT, including any temperature limits for 23 each such use; 24 G. Whether any such ASBESTOS CONTAINING PRODUCT was on the 25 J.S. Government's "Qualified Products List," and if so, the 26 inclusive dates it was on such list; 27 H. The name and address of the supplier of the RAW ASBESTOS 28 ased in each such product and the time period of such supply; 32 1 II Whether any of THIS DEFENDANT'S RAW ASBESTOS OR ASBESTOS 2 CONTAINING PRODUCTS have, at any time, been sold, shipped, or 3 otherwise distributed to any COMPANY (including power company or 4 utility), governmental agency or entity, shipyard, distributor, 5 refinery, contractor, supplier, manufacturer, PREMISE owner or 6 occupant, ship owner, or other PREMISE or site in the GEOGRAPHIC 7 AREA. If so, state: 8 1. The names of each such COMPANY, governmental agency 9 or entity, shipyard, distributor, supplier, manufacturer, 10 refinery, contractor, PREMISE owner or occupant, ship owner, 11 PREMISE or site; 12 2. The inclusive dates of each such sale, shipment, 13 distribution, use or installation and the amount (volumef and the 14 trade or brand name of each such ASBESTOS CONTAINING PRODUCT 15 sold; 16 3. Whether you have any records indicating any such 17 sale, shipment, distribution, use or installation and, if so, the 18 name, address and job classification of each person who currently 19 has possession of such records. 20 J. Either (1) attach all DOCUMENTS evidencingthe 21 information sought in this Interrogatory and its subparts to your 22 answers to these Interrogatories, or (2) attach disks containing 23 such data, or (3) describe such DOCUMENTS with sufficient 24 particularity that they may be made the subject of a request for 25 production of-documents. 26 Ill 27 III III 33 1 RESPONSE .TO INTERROGATORY NO. 31: 2 A. To the best of Chevron's knowledge, three of its 3 asbestos-containing coating products were used at the Richmond 4 Refinery during the relevant time period: Chevron Asbestos Roof 5 Coating, Chevron Aluminum Asbestos Coating, and Weathercoat 6 (formerly known as Laykold Weathercoat) (hereinafter collectively 7 referred to as the "three products" or the "three asbestos 8 products.") 9 B. 1. Not applicable for all three asbestos 10 products. 11 2. Chevron Asbestos Roof Coating was tested and 12 approved in 1934. 13 Chevron Aluminum Asbestos Coating was first - tested 14 in 1945. 15 Weathercoat: Dates unknown. 16 3. Chevron Asbestos Roof Coating was first sold 17 in 1940. 18 Chevron Aluminum Asbestos Coating was first sold 19 in 1947. 20 Weathercoat was first manufactured and sold in the 21 1940's. The specific date is unknown at this time. 22 C. 1. Chevron Asbestos Roof Coating was last sold in 23 approximately i.984. 24 Chevron Aluminum Asbestos Covering was last sold 25 in approximately 1985. 26 Weathercoat was last sold in approximately 1982. 27 Ill 28 III 34 - 2. Not applicable. In addition, the following products contained asbestos but were not used at the Richmond Refinery, nor have they been the subject "of any asbestos personal injury lawsuit filed against Chevron in this jurisdiction: 6 Standard Plastic Cement Heavy from approximately 1947 7 to approximately 1952. 8 Chevron Blind Nail Cement from approximately 1968 to 9 approximately 1982. 10 Chevron Colorcast Base from approximately 1978 to 11 approximately 1982. 12 13 1982. Chevron Colorcoat 200 from about 1962 to approximately -- 14 Dry Turf Premix from approximately 1969 to 15 approximately 1973. 16 Chevron Coating Dry Turf from approximately 1969 to 17 approximately 1973. 18 Chevron Fibrated Clay Emulsion from approximately 1951 19 to approximately 1982. 20 Chevron Fibrecoat from approximately 1948 to 21 approximately 1982. 22 Chevron Grasstex Surfacing Compound from approximately 23 1948 to approximately .1982. 24 Chevron Grasstex Surfacing Compound (Rubberized) from 25 approximately_1965 to approximately 1982. 26 Laykold Heavy Duty Color from approximately 1962 to 27 approximately 1966. Ill 35  Chevron Heavy Duty Resurfacer from approximately 1961 to approximately 1973. Chevron Plastic Cement from approximately 1961 to approximately 1982. Step Grip from approximately 1952 to approximately 1960. Chevron Tennis Top-3000 from approximately 1976 to approximately 1982. Chevron Tile Set (Cutback) from approximately 1956 to approximately 1976. Chevron Walk Top Surfacing Compound Black from 12 approximately 1961 to approximately 1982. 13 Chevron Walk-Top Surfacing Compound Red from ' 14 approximately 1961 to approximately 1982. 15 Chevron Walk-Top Surfacing Compound Green from 16 approximately 1961 to 1982. 17 Chevron Wet Patch from approximately 1967 to 18 approximately 1982. 19 D. Defendant objects to this subparagraph to the extent 20 that it seeks disclosure of confidential, proprietary and/or 21 trade secret information regarding the chemical formulation of 22 its products. Without waiving these objections, defendant 23 responds that none of .the three products contained unbound, 24 individual or friable asbestos fibers. The fibers were used as a 25 bonding and temperature resistant agent to ensure the structural 26 integrity of the surrounding components. In each and every case 27 tfhere asbestos fiber was used in a Chevron product, the fibers tfere completely encapsulated and trapped in a benign matrix when 36 it entered the stream of commerce. No Chevron product incorporated asbestos as a primary ingredient in the composition of the product. These coating products were sold in pre-mixed, liquid form." As such, it was physically impossible for asbestos fibers to escape from the matrix during the installation of the product. To the extent that this interrogatory seeks non-proprietary information, defendant further responds as follows: 9 1. Chevron Asbestos Roof Coating was manufactured 10 under two formulas which contained 8% and 9% asbestos fibers by 11 mass, respectively. Asbestos fiber content ranged in the various 12 formulations from 7% to 11%. During the relevant time period, 13 the various formulations have included the following types and 14 grades of chrysotile asbestos fiber: 15 (1) 1930 to 1948: Philip Carey 3x (7% to 9%) 16 (2) 1948 to 1949: Philip Carey 3X (7% to 10.2%) 17 (3) 1950 to 1954: JM (Johns-Manville) 6D (9%) 18 (4) 1955 to 1956: JM 7M06 (9%) 19 (5) 1957 to 1975: JM 7R05 (11%) 20 (6) 1976 to 1978: JM 7R05 (8%) 21 (7) 1979 to 1980: Calidiria HPO (Union Carbide) 22 (11%) and Calaveras 7R (9%) and 23 (8) 1981 to approximately 1982: JM 7R05 (8%) and 24 Calaveras 7R (9%). 25 2. ..Chevron Aluminum Asbestos Coating was manufactured under two formulas, each of which contained 9% asbestos fiber by mass. The asbestos fiber content ranged from 6% to 10.6%. Ill 37 During the relevant time period, the various formulations have included the following types and grades of asbestos fiber: (1) 1947 to 1949: Philip Carey 3X (6% to 7.2%); (2) 1951 to 1953 : JM 6D-20 (7.5%) (3) 1954 to 1956: JM 7M06 (7.5%) (4) 1957 to 1975: JM 7R05 (10.6%) (5) 1976 to 1978: JM 7R05 (9%) 8 (6) 1979 to 1980: Calidiria HPO (9%); and 9 (7) 1981 to approximately 1982: JM 7R05 (9%) 10 3. Weathercoat was manufactured under a formula that 11 contained 15% asbestos fiber by mass. Historically, Johns12 Manville asbestos fiber (JM 7M05) was used in the formulation. 13 Calidiria HPO and Calaveras 7R were also approved for use.' 14 E. Asbestos Roof Coating was a heavy black liquid that 15 weighed 8.4 pounds per gallon. Aluminum Asbestos Coating was a 16 heavy gray liquid with a gel consistency that weighed 9.5 pounds 17 per gallon. Weathercoat was a black or dark brown, viscous 18 material of easy toweling consistency. 19 F. The products were intended for use as coatings to a 20 maximum temperature limit of approximately 200 F. 21 G. Unknown. 22 H. Please see response to subparagraphs B, C and D. 23 I. (1)- (3) . Chevron does not have records of sales, 24 shipment, or distribution of the above-referenced products, 25 although it is in possession of certain records which indicate 26 where such products may have been used. 27 J. Chevron will provide copies of responsive, nonprivileged documents to the undersigned counsel of record. 5DSF3/1S506 38 INTERROGATORY NO. 32 (PREMISES DEFENDANTS only) Did YOU install, remove, or handle or contract to have others install, remove, or handle RAW ASBESTOS or ASBESTOS CONTAINING PRODUCTS at any PREMISES in the GEOGRAPHIC AREA which PREMISES is at issue as to YOU in San Francisco Superior Court asbestos litigation as of the date of your answers to these interrogatories? If so: A. IDENTIFY the PREMISES. B. For each of the PREMISES: 1. State the nature of your ownership or possessory 11 interest; 12 2. State the inclusive date of that interest; 13 3. IDENTIFY the party from whom that interest"was 14 acquired; 15 4. IDENTIFY the party, if any, to whom that interest 16 was transferred. 17 C. IDENTIFY every contract to which YOU were a party or of 18 which you have knowledge wherein the performance of such contract 19 involved the installation, removal, disturbing or handling of any 20 RAW ASBESTOS or ASBESTOS CONTAINING PRODUCTS at YOUR PREMISES. 21 For each such contract: 22 1. IDENTIFY the parties to the contract; 23 2. Provide-a general description and specific location 24 of the work to be performed by each party to the contract; 25 3. -IDENTIFY and describe the NATURE of the RAW 26 ASBESTOS or ASBESTOS CONTAINING PRODUCTS installed, removed, 27 disturbed or handled in the performance of the contract; III 39 ' 4. State the dates of the contract and the dates of performance; D. Except as provided in response to subpart (c) , has any work other than routine maintenance been done on or to the PREMISES that involved the installation, removal, disturbing or handling of RAW ASBESTOS or ASBESTOS CONTAINING PRODUCTS? If so, for each such instance: 1. State the inclusive dates of the work; 2. Provide a general description and specific location 10 of the work; 11 3. State whether the work was done by YOU and/or YOUR 12 employees; 13 4. IDENTIFY and describe the NATURE of the RAW 14 ASBESTOS or ASBESTOS CONTAINING PRODUCTS installed, removed, 15 handled or disturbed; 16 5. IDENTIFY from whom the RAW ASBESTOS OR ASBESTOS 17 CONTAINING PRODUCTS were acquired. 18 E. Has any asbestos abatement effort been made at the 19 PREMISES? If so, for each such effort: 20 1. IDENTIFY who did the work; 21 2. State the inclusive dates thereof; 22 '3. State whether samples were taken, and,. if the 23 samples still exist, IDENTIFY the custodian of the samples; 24 4. State whether any material was tested, and, if so, 25 vhat were the results of each test; 26 HI 27 III 'll 40 5. IDENTIFY each test result with sufficient particularity for purposes of a request for production of' documents, or, in the alternative, attach a copy' to YOUR answers to these interrogatories. F. Except for insurance coverage litigation, have you filed suit against, or otherwise sought to recover from, any person or entity for some or all of the cost' of asbestos abatement or for the property damage allegedly caused by the presence of RAW ASBESTOS or ASBESTOS CONTAINING PRODUCTS on the PREMISES identified in response to subpart (A) above? If so: 1. IDENTIFY the person or entity against whom YOU have, filed suit or otherwise sought to recover; 13 2. If YOU have filed suit, state the court in'which 14 the action was filed, the date on which it was filed, IDENTIFY 15 all Plaintiffs and Defendants and their counsel of record; 16 3. State whether or not the case has been resolved, 17 and, if so, what was the status or disposition. 18 G. Either (1) attach all DOCUMENTS evidencing the 19 information sought in this Interrogatory and its subparts to your 20 answers to these Interrogatories, or (2) attach disks containing 21 such data, or (3) describe such DOCUMENTS with sufficient 22 particularity that they may be made the subject of a request for 23 production of documents. 24 H. IDENTIFY the person(s) presently most knowledgeable about 25 the information sought in this interrogatory or its subparts. 26 'll 27 III 28 'll 41 1 RESPONSE TO INTERROGATORY NO. 32: A. Richmond Refinery, California.17 3 B. 1. Chevron is the sole owner and operator. 4 2. Throughout relevant time period. 5 3. Not applicable. 6 4. Not applicable. 7 C. 1-4. Chevron entered into numerous contracts for work at 8 the Richmond Refinery during the relevant time period. Some of 9 that work may have involved the installation, removal, 10 disturbance, or handling of products which contained asbestos. 11 Chevron is in possession of contract documents for work at its 12 facilities within the GEOGRAPHIC AREA which may be responsive to 13 this interrogatory. Chevron is unable to determine at this time, 14 however, the extent to which the work that it contracted for 15 during the relevant time period involved ASBESTOS CONTAINING 16 PRODUCTS without reviewing each and every contract document in 17 its possession. On that basis. Chevron objects to this 18 interrogatory as unduly burdensome. In addition. Chevron may 19 have previously disposed of some of the requested information and 20 documents in accordance with its document retention policy. 21 Without waiving the foregoing objection, to the best of 22 Chevron's knowledge based on the present state of its records, 23 the following contractors who performed pipe insulation or boiler 24 work at the Richmond Refinery include, but may not be limited to 25 the following.-. 26 27 8 Chevron has been sued as a premises owner in asbestos litigation in San Francisco Superior Court with respect to its Richmond Refinery. The majority of claims filed against iu involve this facility, although there are occasional claims made as to other Chevron facilities. Chevron's response here concerns the Richmond Refinery. 42 CONTRACTOR START DATE COMPLETION DATE Associated Insulation of California 05-10-66 07-01-66 Associated Insulation of California 07-18-66 08-01-66 Armstrong Contracting and 6 Supply Corporation 05-23-66 06-10-66 7 Conseco, Inc. 06-13-69 06-13-72 8 Conseco, Inc. 05-15-66 05-15-69 9 Conseco, Inc. 01-25-66 01-25-69 10 Charles Ayers Company 12-16-60 12-20-60 11 Labor Force, Inc. 06-30-66 06-30-69 12 California Steel Tank Co. 03-18-66 04-01-67 13 California Steel Tank Co. 05-11-66 06-30-66 14 The Babcock and Wilbey Company 11-30-65 Boiler Division, Westcoast CP. 15 Western MacArthur Company 12-04-70 16 Pacific Mechanical Corporation 12-14-70 17 Plant Asbestos Company 12-07-70 18 Richardson Chemical Cleaning 01-18-71 19 C. Norman Peterson Company 02-08-71 20 Delta-Tech Service, Inc. 10-08-71 21 Delta-Tech Service, Inc. 10-21-71 22 Richardson Chemical Cleaning 10-28-71 23 Service, Inc. 11-30-65 12-13-70 01-31-71 12-11-70 01-29-71 02-15-71 10-11-71 10-22-71 10-31-71 24 Baldwin-Warren Company 03-28-66 05-11-66 25 Baldwin-Ehret-Hill, Inc. 12-15-65 12-17-65 26 MGM Construction Company 05-09-66 07-01-66 27 MGM Construction Company 03-22-66 04-25-66 MGM Construction Company 12-20-65 01-19-66 43 Labor Force, Inc. Bechtel Corporation 3 Baldwin-Warren Co. 4 D.W. Nicholson Corporation 5 Dow Industrial Service 6 Dow Industrial Service 7 Dow Industrial Service 8 Rosendahl Corporation 9 Rosendahl Corporation 10 Rosendahl Corporation 11 Rosendahl Corporation 12 Rosendahl Corporation 13 Associated Insulation of California 14 Associated Insulation of 15 California 16 Albay Construction Company 17 Pacific Mechanical Corporation 18 Pacific Mechanical Corporation 19 Pacific Mechanical Corporation 20 Pacific Mechanical Corporation 21 Pacific Mechanical Corporation 22 Plant Asbestos Company 23 Plant Asbestos Company 24 Plant Asbestos Company 25 Plant Asbestos Company 26 Plant Asbestos Company 27 Plant Asbestos Company Plant Asbestos Company 44 09-01-69 04-09-62 05-09-66 10-17-66 05-22-65 12-18-65 02-08-61 09-09-63 05-07-62 06-06-71 04-26-61 03-15-61 09-01-69 03-20-69 12-24-70 12-01-66 05-16-66 11-12-63 10-01-63 01-13-64 02-03-70 07-05-67 02-01-65 03-01-67 01-16-67 06-13-66 04-01-65 09-01-72 08-31-62 06-24-66 10-31-66 05-24-65 12-18-65 02-09-61 09-20-63 06-15-62 07-10-61 05-31-61 05-03-61 07-31-70 08-01-69 02-15-71 01-13-67 06-10-66 02-18-64 10-31-63 02-21-64 02-22-70 07-28-67 02-01-68 03-01-70 01-27-67 06-20-66 05-01-65 Plant Asbestos Company Plant Asbestos Company Plant Asbestos Company Plant Asbestos Company Plant Asbestos Company Plant Asbestos Company 7 Plant Asbestos Company 8 Plant Asbestos Company 9 Plant Asbestos Company 10 Plant Asbestos Company 11 Plant Asbestos Company 12 Plant Asbestos Company 13 Plant Asbestos Company 14 Western Asbestos Company 15 Western Asbestos Company 16 Fiberglas Engineering and Supply Division, 17 Owens-Corning Fiberglas Corporation 18 Fiberglas Engineering 19 and Supply Division, Owens-Corning Fiberglas 20 Corporation 21 Fiberglas Engineering and Supply Division, 22 Owens-Coming Fiberglas Corporation 23 Elmco Division, 24 Swinerton and Walberg Co. 25 Elmco Division, Swinerton and Walberg Co. 26 Elmco Division, 27 Swinerton and Walberg Co. 28 Ehrhart and Associates, Inc. 45 01-20-66 06-10-63 05-31-63 05-27-63 05-13-63 02-18-63 01-28-63 02-04-63 02-01-63 12-03-62 12-05-61 07-10-61 09-28-60 12-10-62 07-09-62 04-04-66 ' 02-04-66 06-21-63 06-14-63 06-03-63 05-20-63 03-18-63 03-01-63 02-22-63 03-01-63 01-11-63 12-13-61 07-28-61 10-14-60 01-11-62 03-03-62 05-01-66 07-17-61 07-28-61 12-27-66 01-15-67 06-12-69 05-31-66 05-31-66 01-03-62 06-30-69 07-01-66 07-01-66 02-09-62 Ehrhaft and Associates, Inc. 09-18-61 01-15-62 Scott Company of California 02-26-70 03-27-70 Scott Company of California 09-08-69 10-03-69 S and Q Contractors 03-03-69 05-01-69 Pacific Mechanical Corporation 04-20-70 06-05-70 Pacific Mechanical Corporation 04-15-70 04-30-70 Pacific Mechanical Corporation 02-18-70 03-27-70 Pacific Mechanical Corporation 07-17-69 08-15-69 Pacific Mechanical Corporation 04-04-67 05-05-67 C. Norman Peterson Company, Contractors 05-02-66 06-10-66 C. Norman Peterson Company, Contractors . 07-25-66 08-19-66 13 A.P. Green Servicesi Division, Bigelow-Liptak Corporation 02-09-70 02-18-70 14 To the best of Chevron's knowledge based on the present 15 state of its records, therfollowing contractors who performed 16 heating, ventilation, sheetmetal, fireproofing, acoustical or 17 plastering work at the Richmond Refinery include, but may not be 18 limited to the following: 19 20 CONTRACTOR START DATE COMPLETION DATE 21 United Acoustics 04-17-72 Unknown 22 United Acoustics 04-03-72 Unknown 23 Copperheat 12-29-71 01-03-72 24 Western MacArthur Company 11-02-71 11-30-71 25 Air Filter_Sales and Service Co., Inc. 26 Air Filter Sales and 27 Service Co., Inc. 03-20-71 03-20-70 03-20-72 03-20-71 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 8 Associated Insulation of California Associated Insulation of California Associated Insulation of California Associated Insulation of California Associated Insulation of California Associated Insulation of California Associated Insulation of California Associated Insulation of California Associated Insulation of California Armstrong Contracting and Supply Corporation Granholt Sheet Metal Works Associated Insulation of California Pacific Mechanical Corporation Reed and Simonsen Albay Construction Company Simonsen Air Conditioning and Heating Mastercraft' Tile and Roofing Company Mastercraft Tile and Roofing Company Bechtel Corporation Bechtel Corporation D.W. Nicholson Corporation 5DSF3/1SS06 47 05-12-69 05-01-69 06-30-69 07-07-69 05-01-69 01-06-69 07-11-66 11-15-65 12-10-64 03-17-67 09-01-61 05-12-69 06-16-70 09-09-70 12-03-70 12-14-70 12-01-64 08-01-67 02-13-61 03-15-61 03-20-67 05-23-69 05-15-69 07-21-69 07-31-69 05-15-69 02-21-69 07-29-66 12-10-65 12-10-67 03-17-68 09-05-61 05-23-69 08-14-70 10-30-70 12-18-70 Unknown 12-01-67 08-01-70 06-01-62 07-01-61 04-28-67 Rosendahl Corporation Rosendahl Corporation CSB Construction Reed and Simonsen C. Overaa and Company Plant Asbestos Company Plant Asbestos Company Plant Asbestos Company Plant Asbestos Company Plant Asbestos Company Plant Asbestos Company 12 Plant Asbestos Company 13 Plant Asbestos Company 14 Plant Asbestos Company 15 Plant Asbestos Company 16 Plant Asbestos Company 17 Plant Asbestos Company 18 Plant Asbestos Company 19 Plant Asbestos Company 20 Plant Asbestos Company 21 Plant Asbestos Company 22 Plant Asbestos Company 23 Plant Asbestos Company 24 Simonsen Air Conditioning and Heating Company 25 Western Asbestos Company 26 Western Asbestos Company 27 Western Asbestos Company 28 ;DSF3/1SS06 48 01-02-62 Unknown 02-13-68 04-06-70 06-14-71 08-04-69 11-28-66 05-10-65 01-01-64 04-01-63 01-30-63 12-10-62 02-01-62 01-01-61 01-12-59 02-01-64 02-01-63 02-01-61 05-28-62 03-28-62 02-09-62 02-26-62 12-07-60 07-31-72 02-12-62 02-28-62 05-03-68 06-30-70 08-31-71 09-01-69 12-07-66 06-15-65 ' 01-01-65 04-19-63 02-15-63 01-11-63 02-01-63 01-01-62 01-12-60 02-01-65 02-01-64 02-01-62 06-01-62 04-04-62 03-09-62 03-05-62 12-20-60 09-01-72 08-01-66 02-01-65 02-01-64 09-16-66 02-01-68 02-01-65 1 Western Asbestos Company 2 Western Asbestos Company 3 Western Asbestos Company 4 Western Asbestos Company 5 Western Asbestos Company 6 Western Asbestos Company 7 Western Asbestos Company 8 Western Asbestos Company 9 Western Asbestos Company 10 Western Asbestos Company 11 Western Asbestos Company 12 Fiberglas Engineering and . Supply Division, 13 Owens-Corning Fiberglas Corporation 14 Fiberglas Engineering and 15 Supply Division, Owens-Corning Fibergias 16 Corporation 17 Fiberglas Engineering and Supply Division, 18 Owens-Corning Fiberglas Corporation 19 Fiberglas Engineering and 20 Supply Division, Owens-Corning Fiberglas 21 Corporation 22 Fiberglas Engineering and Supply Company 23 The Fluor Corporation, Inc. 24 Fiberglas Engineering and 25 Supply Division, Owens-Corning Fiberglas 26 Comoration 27 III III 49 04-01-63 06-18-62 05-05-61 01-16-61 09-08-60 01-12-59 02-01-62 02-01-61 06-18-62 02-01-64 02-01-63 03-16-66 04-15-65 06-22-64 08-31-64 02-01-65 09-11-61 02-15-68 04-12-63 06-25-62 05-18-61 01-31-61 09-23-60 02-01-63 02-01-63 02-01-62 06-23-62 02-01-65 02-01-64 03-23-66 05-01-65 06-30-64 09-04-64 02-01-68 02-11-62 02-15-71 Fiberglas Engineering and Supply Division, Owens-Corning Fiberglas Corporation Fiberglas Engineering and Supply Division, Owens-Corning Fiberglas Corporation Fiberglas Engineering and Supply Division, Owens-Corning Fiberglas Corporation Fiberglas Engineering and Supply Division, Owens-Corning Fiberglas 10 Corporation 11 Fiberglas Engineering and Supply Division, 12 Owens-Corning Fiberglas Corporation 13 Fiberglas Engineering and 14 Supply Company 15 Fiberglas Engineering and Supply Company 16 Fiberglas Engineering and 17 Supply Division, Owens-Corning Fiberglas 18 Corporation 19 Fiberglas Engineering and . Supply Division, 20 Owens-Corning Fiberglas Corporation 21 Fiberglas Engineering and 22 Supply Division, Owens-Corning Fiberglas 23 Corporation 24 Fiberglas Engineering and Supply Company 25 Plant Asbestos Company 26 Fiberglas Engineering and 27 Supply Company 06-20-63 06-26-63 11-26-62 12-05-62 03-18-62 06-29-62 05-07-62 05-14-62 12-06-61 12-19-61 01-05-59 08-29-60 06-18-62 01-05-60 10-01-60 06-29-62 05-07-62 05-14-62 12-06-61 12-19-61 08-29-60 11-13-61 02-01-62 10-01-60 11-17-61 02-01-63 50 Fiberglas Engineering and Supply Company 02-01-61 02-01-62 Fiberglas Engineering and Supply Company 01-05-59 01-05-60 Scott Company of California 02-01-70 1974 Scott Company of California 1965 1969 6 Scott Company of California 10-22-64 Unknown 7 Scott Company 01-25-63 01-25-64 8 Scott Company 01-25-62 01-25-63 9 Scott Company 01-23-61 01-25-62 10 Scott Company 06-10-63 06-21-63 11 Scott Company 01-15-62 02-15-62 12 C. Overaa and Company 01-06-69 04-01-69 13 C. Norman Peterson Company, Contractors 14 Associated Insulation of 15 California 07-24-68 11-17-72 10-11-68 Unknown 16 Associated Insulation of California 02-01-72 02-11-72 17 At this time. Chevron identifies the following entities 18 from whom certain asbestos-containing products were acquired for 19 use at the Richmond Refinery: Johns-Manvilie Sales Corporation; 20 Pabco; Fibreboard Corporation; Pittsburgh-Corning Corp.; Owens- 21 Corning; Raybestos-Manhattan, and others. In addition, the 22 following products were used at the Richmond Refinery and are 23 believed to have contained asbestos at some point in time: 24 Felt #15 Asphalt - Saturated Asbestos 25 Johns-Manville- No. 55 Asbestos Base Felt Johns-Manvilie #15 Perforated Asbestos Base Felt 26 Two Ply Asbestos Flashing Material Standard Aluminum Asbestos Coating 27 Asbestile Plastic Cement Johns-Manville Asbestile Flashing Cement 28 Johns-Manville Asbestile Cement 51 AsbestosRoofing Coating Johns-Manville J Spray Asbestos Corrugated Asbestos Roof and Plastic Skylights Johns-Manville Transite Corrugated Asbestos Roofing AAA Asbestos Cloth Armstrong Limpet Spray Asbestos Laykold Weathercoat Kaylo Pipe Covering Kaylo Block Asbestos Cement Board Thermobestos Unibestos Asbestos Cement Sheets Asbestos Sponge Pelt D. 1-5. To the best of Chevron's knowledge, information 10 responsive to this interrogatory would likely be contained in its 11 contract records as referenced in response to subpart C. above. 12 At some point in time, Chevron employees may have performed work 13 at the refinery which would have involved the installation', 14 removal, disturbing, use or handling of products which may have 15 contained asbestos, however, Chevron has not located documents 16 which would describe such work. 17 E. 1-5. Chevron has identified the location of asbestos 18 containing products within the Richmond Refinery and has 19 attempted to control exposure to such products by removal or 20 encapsulation in accordance with applicable laws, rules and 21 regulations. Chevron is in the process of reviewing documents in 22 its possession which may be responsive to this interrogatory. 23 F. No. 24 1-3. Not applicable. 25 Ill 26 III III III 52 i  G. Chevron is in possession of certain contractor records including contracts, memoranda, and correspondence which may be responsive to this interrogatory and which will be produced to plaintiffs' counsel on a one time basis upon reasonable notice and at a mutually convenient time. H. Chevron's primary business operation is the exploration, production, transportation, refining and marketing 8 of petroleum products. Chevron does not currently employ a 9 particular person or defined group of people presently most 10 knowledgeable about the scope and variety of information 11 requested by this interrogatory during the relevant time period. 12 INTERROGATORY NO. 33 (CONTRACTOR DEFENDANTS only) 13 At any time between 1930 and 1985, did YOU hold a 14 contractor's license in the State of California? If so: 15 A. IDENTIFY each license by type, date and number. 16 B. If on the date of your answers YOU are a defendant in 17 four or more asbestos actions in San Francisco Superior Court, 18 IDENTIFY each job or contract that YOU performed (directly or 19 through one of more subcontractors) during this time period for 20 work in any PREMISES which is at issue as to YOU on such date, 21 and in any PREMISES of 50,000 square feet or more in the 22 GEOGRAPHIC AREA which job or contract involved installation, 23 removal, disturbing or handling RAW ASBESTOS or ASBESTOS 24 CONTAINING PRODUCTS. (Alternatively, at your option, you may 25 IDENTIFY each-job or contract YOU performed (directly or through 26 one or more subcontractors) during this time frame for all work, 27 or for all work on PREMISES of 50,000 square feet or more, in the 3EOGRAPHIC AREA.) As to each such job or contract: 53 1 1. IDENTIFY the location (including name of ship, if 2 applicable) where the job or work was performed; 3 2. State the date of the contract or the inclusive 4 dates of the work; 5 3. IDENTIFY the person or entity with whom you 6 contracted; 7 4. State your job or contract number. 8 C. If on the date of your answers you are not a defendant in 9 four or more asbestos actions in San Francisco Superior Court, 10 IDENTIFY each job or contract that YOU performed (directly or 11 through one or more subcontractors) during this time period for 12 work in any PREMISES which is at issue as to YOU on such date. As 13 to each such job or contract: 14 1. IDENTIFY the location (including name of ship, if 15 applicable) where the job or work was performed; 16 2. State the date of the contract or the inclusive 17 dates of the work; 18 3. IDENTIFY the person or entity with whom you 19 contracted; 20 4. State your job or contract number. 21 RESPONSE TO INTERROGATORY NO. 33: 22 Not applicable. 23 INTERROGATORY NO.' 34: - 24 Did any cf the distributors identified in your Answer to 25 Interrogatory ,,Nos. 29 and 31 above have an exclusive 26 distributorship? If so, state the relevant time period. 27 SEOCVICK. DETERr MORAV)Q 0 ARNOLD One Embercedero Center Sixteenth Floor Sen FranctKO, California 94111-3765 Tel. 415.781.7900 /// /// 5DSF3/15506 54 RESPONSE TO INTERROGATORY NO. 34: Not applicable; please see defendant's responses to Interrogatory Nos. 29 and 31. INTERROGATORY NO. 35: If THIS DEFENDANT entered into any agreements for the rebranding of any ASBESTOS CONTAINING PRODUCTS by THIS DEFENDANT for resale or distribution by another person or entity, describe each agreement's terms and the parties to said agreement, the duration of the agreement, and name of each product(s) and/or material(s) covered by each such agreement. RESPONSE TO INTERROGATORY NO. 35: 12 Not applicable. 13 INTERROGATORY NO. 36: -- 14 If THIS DEFENDANT entered into any agreements for the 15 rebranding of ASBESTOS CONTAINING PRODUCTS manufactured, sold, 16 supplied or distributed by another person or entity for resale or 17 distribution by YOU, describe each of the agreements and the 18 parties to said agreement, the terms, the duration, and the names 19 of each product(s) and/or material(s) covered by each such 20 agreement. 21 RESPONSE TO INTERROGATORY NO. 36; 22 At some time between approximately 1984 and 1986 23 Chevron entered into an agreement or agreements for the 24 rebranding of Chevron Asbestos roof Coating, Chevron Aluminum 25 Asbestos Coating and Chevron Plastic Cement manufactured by 26 3ibson-Homans Company to be sold by Chevron. 27 Ill 28 III 55 1 INTERROGATORY NO. 37: 2 As to RAW ASBESTOS and to each such ASBESTOS CONTAINING 3 PRODUCT listed in YOUR responses to Interrogatories No. 29 and 31 4 did DEFENDANT warn of the health hazards of asbestos? If so. 5 state for each such warning: 6 A. The content, size, color, and location; whether the 7 warning appeared on the material and/or on the container, and/or 8 was placed on a tag; whether the warning was included in 9 contracts; whether the warning was included in advertising or 10 other promotional materials. 11 B. State whether you have any photographs thereof; 12 C. The inclusive dates on which you used each such warning; 13 D. State all changes you made in such warnings and the dates 14 of such changes; and 15 E. identify the person most knowledgeable about your 16 warnings and warning policy. 17 RESPONSE TO INTERROGATORY NO. 37: 18 Although warnings regarding certain health hazards were 19 placed on labels affixed to the containers for the three asbestos 20 products, there were no warnings specifically referencing 21 asbestos. These products contained a minimal amount of 22 chrysotile asbestos fiber to increase the durability of the 23 product when exposed to the elements. The fibers were used as a 24 bonding and temperature resistant agent to ensure the structural 25 integrity of the surrounding components. In each and every case 26 where asbestos fiber was used in a Chevron product, the fibers 27 S E0C1C K DETERT MORAfJQ C ARNOLD One Embireftdero Center Sixteenth Floor Son Frxncueo, California 94111-3765 W *15 781.7900 were completely encapsulated and trapped in a benign matrix when it entered the stream of commerce. No Chevron product SDSF3/15S06 56 1 incorporated asbestos as a primary ingredient in the composition 2 of the product. Chevron's asbestos-containing coating products 3 were sold in pre-mixed, liquid form. As such, it was physically 4 impossible for asbestos fibers to escape from the matrix during 5 the installation of the product. 6 INTERROGATORY NO. 38: 7 With respect to each of YOUR ASBESTOS CONTAINING PRODUCTS, 8 state whether THIS DEFENDANT'S name, a trademark, logos, color 9 coding, or other identifying markings ever appeared on the actual 10 product itself. If so, IDENTIFY each such product, state when the 11 practice to place such identifying markings upon the product was 12 begun and when it ended, if applicable, and describe in detail 13 the pertinent marking(s) and the purpose, if any, of such 14 markings. 15 RESPONSE TO INTERROGATORY NO. 38: 16 Not applicable. 17 INTERROGATORY NO. 39: 18 Between the years 1930 to 1985, did THIS DEFENDANT purchase 19 or otherwise acquire any ASBESTOS CONTAINING PRODUCT lines from 20 another person or entity? If so, state for each such purchase: 21 A. Date of purchase or acquisition; 22 B. Terms of purchase or acquisition agreement; 23 C. Either' (1) attach all DOCUMENTS evidencing said 24 acquisition, or (2) attach disks containing such data, or (3) 25 describe such.DOCUMENTS with sufficient particularity that they 26 may be made the subject of a request for production of documents. 27 seocwicic/ DETERT MORA*OQ & AXNOLO D. Trade, brand, and/or generic name of each such product line so acquired; Oix Ettbarcidro Center Sixteenth Fleer Sea Frencuco, California 94U1-376S Tel. 41S.78I.7900 SDSF3/1S506 57 1 E'. Name of the person or entity from whom YOU purchased or 2 acquired each such ASBESTOS CONTAINING PRODUCT line; and 3 F. Location of any manufacturing facilities so acquired, and 4 the type of ASBESTOS CONTAINING PRODUCTS manufactured therein. 5 RESPONSE TO INTERROGATORY NO. 39: 6 Other than as referred to in response to Interrogatory No. 7 27 A. & B., unknown. 8 INTERROGATORY NO. 40: 9 Between the years 1930 to 1985, did THIS DEFENDANT sell any 10 ASBESTOS CONTAINING PRODUCT line to another person or entity? If 11 so, state for each such sale: 12 A. Date of sale; 13 B. Terms of sales agreement; 14 C. Either (1) attach all DOCUMENTS evidencing said sale, or 15 (2) attach disks containing such data, or (3) describe such 16 DOCUMENTS with sufficient particularity that they may be made the 17 subject of a request for production of documents. 18 D. Trade, brand, and/or generic name of each such product 19 line sold; 20 E. Name of person or entity to whom you sold each such 21 ASBESTOS CONTAINING PRODUCTS line; and 22 F. Location of any manufacturing facilities so sold, and the 23 type of ASBESTOS CONTAINING PRODUCTS manufactured therein. 24 RESPONSE TO INTERROGATORY NO. 40: 25 No. 26 Ill 27 S E 0 1 WICK DETERf MORAHJQ 6 ARNOLD III III One Embtrcftdtr* Center Sixteenth Fleer Sen Froacuce. Ctlihnna 94111*3765 Tel. 415.711.7900 SDSF3/1S506 58 ' 1 INTERROGATORY NO. 41: 2 IDENTIFY all brochures, pamphlets, catalogs or other 3 advertising relating to ASBESTOS CONTAINING PRODUCTS and/or RAW 4 ASBESTOS which THIS DEFENDANT manufactured, sold, distributed or 5 supplied from the year 1930 to 1985. For each such document, 6 state: 7 A. A description of the document; 8 B. The year it was printed; 9 C. The period of time in which it was used; 10 D. The purpose of such document;^ 11 E. Whether the documents or copies of said documents 12 presently exist; 13 F. If said documents or copies still exist, where they are 14 located; and 15 G. The IDENTITY of the custodian of such documents. 16 RESPONSE TO INTERROGATORY NO. 41: 17 A-G. Chevron will produce responsive, non-proprietary 18 documents to plaintiffs' counsel on a one time basis at a 19 mutually convenient time. 20 INTERROGATORY NO. 42: 21 State if YOU have or had within YOUR corporate or other 22 business structure any CONTRACT UNITS. 23 RESPONSE TO INTERROGATORY NO. 42: 24 No. 25 INTERROGATORY NO. 43: 26 State whether or not any of YOUR CONTRACT UNITS installed 27 S EOCw1C K DETER T. MORA fO ft & ARNOLD and/or removed RAW ASBESTOS and/or ASBESTOS CONTAINING PRODUCTS in the GEOGRAPHIC AREA at any time between 1930 and 1985. If so: One Embareedero Center Sixteenth Fleer Sen Frtneuce, Caltforau 94111.3765 Tel. 415.781.7900 SDSF3/15506 59 A. State the business addresses and name of the CONTRACT UNIT; B. State the inclusive periods of time the CONTRACT UNITS were working in the GEOGRAPHIC AREA; C. State the name and address of each job site within the 6 GEOGRAPHIC AREA and the dates the CONTRACT UNIT worked at those 7 job sites, and, IDENTIFY the RAW ASBESTOS and/or ASBESTOS 8 CONTAINING PRODUCTS installed or removed on each occasion; 9 D. Either (1) attach all DOCUMENTS evidencing' the 10 information sought in this Interrogatory and its subparts to your 11 answers to these Interrogatories, or (2) attach disks containing 12 such data, or (3) describe such DOCUMENTS with sufficient 13 particularity that they may be made the subject of a request for 14 production of documents. 15 RESPONSE TO INTERROGATORY NO. 43: 16 Not applicable. Please see response to Interrogatory No. 17 42. 18 INTERROGATORY NO. 44: 19 When do YOU contend that THIS DEFENDANT first became aware 20 that there is an association between asbestos exposure and 21 disease in human beings? 22 RESPONSE TO INTERROGATORY NO. 44; 23 The medical and scientific knowledge regarding the potential 24 hazards of asbestos exposure in different contexts was developed 25 over many years, and is the subject of expert testimony in this 26 litigation. Accordingly, Chevron objects to this interrogatory to the extent that it seeks information protected from disclosure at this time by Code of Civil Procedure section 2034, the /1S506 60 1 attorney client privilege and/or the attorney work product 2 doctrine. Without waiving these objections. Chevron responds 3 that it is not possible to identify a specific time as to when 4 Chevron's awareness of the potential hazards of asbestos exposure 5 occurred, or a specific method or medium by which Chevron 6 acquired knowledge of these various hazards. 7 INTERROGATORY NO. 45: 8 How do YOU contend that THIS DEFENDANT first became aware 9 that there is an association between asbestos exposure and 10 disease in human beings. 11 RESPONSE TO INTERROGATORY NO. 45: 12 The medical and scientific knowledge regarding the potential 13 hazards of asbestos exposure in different contexts was developed 14 over many years, and is the subject of expert testimony in this 15 litigation. Accordingly, Chevron objects to this interrogatory 16 to the extent that it seeks information protected from disclosure 17 at this time by Code of Civil Procedure section 2034, the 18 attorney client privilege and/or the attorney work product 19 doctrine. Without waiving these objections. Chevron responds 20 that it is not possible to identify a specific time as to when 21 Chevron's awareness of the potential hazards of asbestos exposure 22 occurred, or a specific method or medium by which Chevron 23 acquired knowledge of-these various hazards. 24 INTERROGATORY NO. 46: 25 Either (1) attach all DOCUMENTS evidencing the information 26 upon which YOUR contentions in YOUR answers to Interrogatories 27 No. 44 and No. 45 are based, or (2) attach disks containing such S E 0 C W 1 C K. DETER T. MORA 0 ARNOLD III One Enbtfci^ere Center Sixteenth Floor Sen FrinciMA, Celiforaie 94111-3765 Tel. 415.781.7900 SDSF3/XSS06 61 1 data, or-(3) describe such DOCUMENTS with sufficient 2 particularity that they may be made the subject of a request for 3 production of documents. 4 RESPONSE TO INTERROGATORY NO. 46: f 5 Chevron acquired its knowledge of potential asbestos 6 hazards over time and through many different sources. It would 7 be impossible for Chevron to identify each and every document 8 and/or source of information which may have contributed to its 9 collective corporate knowledge of these potential hazards. 10 Please see response to Interrogatory Nos. 44 and 45, above. 11 INTERROGATORY NO. 47: 12 When did THIS DEFENDANT first warn its employees that 13 exposure to asbestos could be hazardous to human health? State: 14 A. Whether the first such warning was written or oral; 15 B. Whether copies of DOCUMENTS containing such warning 16 exist; 17 C. The IDENTITY of the custodian of such DOCUMENTS ,- 18 D. The content of the warning. 19 RESPONSE TO INTERROGATORY NO. 47: 20 A. As the medical and scientific knowledge regarding the 21 potential hazards of asbestos exposure was developed over many 22 years and from many different sources. Chevron cannot identify a 23 specific date when it "first warned its employees that exposure 24 to asbestos could be hazardous to human health." 25 B. Unknown. 26 C. Not applicable. 27 S EOCWICK DETEST MOR A*Q g & ARNOLD D. above. One Embircidtre Center Sixteenth Fleer Sea Frencuco, California 94111.3765 Tel 415 781 7900 SDSF3/15506 Not applicable. See response to subparts A and B, 62 I 1 INTERROGATORY NO. 48: 2 Did THIS DEFENDANT ever issue a written COMPANY policy 3 discontinuing warning its employees that exposure to asbestos 4 could be hazardous to human health? If so, 5 A. Provide the date; 6 B. Describe the circumstances; and 7 C. Either (1) attach all DOCUMENTS evidencing the 8 information sought in this Interrogatory and its subparts to your 9 answers to these Interrogatories, or (2) attach disks containing 10 such data, or (3) describe such DOCUMENTS with sufficient 11 particularity that they may be made the subject of a request for 12 production of documents. 13 RESPONSE TO INTERROGATORY NO. 48: 14 No. 15 INTERROGATORY NO. 49 : 16 Did THIS DEFENDANT provide any Independent Contractor or 17 Subcontractor within the GEOGRAPHIC AREA with a written warning 18 that exposure to asbestos could be hazardous to human health. 19 RESPONSE TO INTERROGATORY NO. 49; 20 Yes. 21 INTERROGATORY NO. 50: 22 Has THIS DEFENDANT been cited for or otherwise charged by a 23 public agency with a violation in the GEOGRAPHIC AREA of any 24 statute, ordinance, safety order, regulation, or law pertaining 25 to asbestos exposure? For each occasion, IDENTIFY: 26 A. The code section, safety order, statute, or regulation SEOCWICIC DETEKT 0 ARNOLD 27 One Enbercedere Center Sixteenth Sen Franettee, Cebforaui 94111-3765 Tel. 415 781 7900 for which THIS DEFENDANT had been cited or otherwise charged; B. The date(s) thereof. SDSF3/15506 63 C. The agency or other governmental unit which issued the citation or otherwise charged YOU. D. All persons known to YOU with information relevant to the incident. E. What was the ultimate resolution. RESPONSE TO INTERROGATORY NO. 50: Chevron objects to this interrogatory to the extent that it seeks information protected from disclosure by the attorney client privilege and the attorney work product doctrine. 10 Without waiving this objection. Chevron responds that it has 11 documents in its possession which may be responsive to this 12 interrogatory and which will be produced to plaintiffs' counsel 13 on reasonable notice on a one time basis and at a mutually' 14 convenient- time. 15 INTERROGATORY NO. 51: 16 If THIS DEFENDANT has ever owned or operated a railroad, 17 state: 18 A. The IDENTITY of each such railroad, including the name(s) 19 of such railroad during the time period of YOUR ownership and/or 20 operation, the principal place of business of such railroad and 21 the dates of YOUR ownership and/or operation; 22 B. The geographic area of operation of such railroad; 23 C. The name(s) of such railroad prior to YOUR ownership 24 and/or operation; 25 D. The IDENTITY of the person or entity from whom YOU . 26 purchased your ownership or operating interest, and the date of 27 such purchase; 28 /// 64 * - 0, E. The IDENTITY of the person or entity to whom YOU sold your ownership or operating interest, and the date of such sale; F. Whether copies of DOCUMENTS evidencing your ownership/operation and/or sale exist; G. The IDENTITY of the Custodian of such DOCUMENTS; H. To the extent that information has not been given in answers to Interrogatory Nos, 32 and 33, the information requested in Interrogatory Nos. 32 and 33, for each railroad owned or operated by YOU. RESPONSE TO INTERROGATORY NO. 51: Not applicable. INTERROGATORY NO. 52; 13 If DEFENDANT has ever owned or operated a shipyard, "state: 14 A. The IDENTITY of each such shipyard, including the name(s) 15 of such shipyard during the time period of YOUR ownership and/or 16 operation, the place of business of such shipyard and the dates 17 of YOUR ownership and/or operation; 18 B. The name(s) of such shipyard prior to YOUR ownership 19 and/or operation; 20 C. The IDENTITY of the person or entity to whom YOU sold 21 /our ownership or operating interest, and the date of such sale; 22 D. Whether copies of DOCUMENTS evidencing your . 23 ownership/operation and/or sale exist; 24 E. Whether any representative of THIS DEFENDANT attended the 25 Maritime Commission Conference in December 1942 in Chicago, 26 Illinois? If so, IDENTIFY any such representative of THIS 27 28 F. The IDENTITY of the Custodian of such DOCUMENTS; 65 G. To the extent that information has not been given in answers to Interrogatory No. 32, the information requested in Interrogatory No. 32, for each shipyard owned or operated by YOU. RESPONSE TO~INTERROGATORY NO. 52: Not applicable. INTERROGATORY NO. 53: At any time between 1930 and 1985, did you import, export, 8 ship, transship or otherwise transport RAW ASBESTOS or ASBESTOS 9 CONTAINING PRODUCTS into, out of or through any port in the 10 GEOGRAPHIC AREA? If so, for each occasion: 11 A. IDENTIFY and describe the NATURE and amount of RAW 12 ASBESTOS and/or ASBESTOS CONTAINING PRODUCTS; 13 B. IDENTIFY the ship or ships (including the owners' and 14 operators thereof) onto or from which the RAW ASBESTOS and/or '15 ASBESTOS CONTAINING PRODUCTS were loaded, unloaded or 16 transshipped; 17 C. State the dates, port and pier involved for each 18 occasion; 19 III 20 III 21 III 22 III 23 III 24 III 25 III 26 ill 27 III 28 III 66 D. Either (1) attach all DOCUMENTS evidencing the information sought in this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents. RESPONSE TO INTERROGATORY NO. 53: 8 Chevron is not aware of any such occasions. 9 Dated: August 1997. 10 SEDGWICK, DETERT, MORAN & ARNOLD 11 12 Holly A. Harris 13 Attorneys for Defendant CHEVRON PRODUCTS COMPANY 14 15 16 17 18 19 20 21 22 23 24 25 26 27 67 1 VERIFICATION 2 I, Hilman. P. Walker, declare as follows: 3 4 1. I am the Assistant Secretary for Chevron U.S.A. Inc., (of which Defendant Chevron 5 Products Company is a division), and I am authorized to make this verification on its 6 behalf. I have read the foregoing RESPONSES TO PLAINTIFFS' STANDARD 7 ASBESTOS CASE INTERROGATORRIES to all defendants, and know the contents 8 thereof. 9 10 2. Certain matters stated in the foregoing answers are not entirely within my personal 11 knowledge. The information provided in the foregoing answers was assembled by 12 authorized personnel and counsel. 13 14 3. The answers are given subject to subsequent correction of inadvertent errors or 15 omissions, if such errors or omissions shall later be found to exist. Consequently, 16 Chevron U.S.A. Inc., reserves the right to make any changes in this response, if it appears 17 at any time that inadvertent errors or omissions have been made, or additional or more accurate information becomes available. 18 19 4. Subject to the limitations set forth in paragraphs 2 and 3 above, I am informed and 20 believe that the matters in the foregoing answers are true, and on that ground assert that 21 the matters stated are true to the best of my present knowledge, information and belief. 22 23 I declare under penalty of peijury that the foregoing is true and correct. 24 25 Executed this 22nd day of August, 1997, at San Francisco, California. 26 27 28 29 Hilman P. Walker IN RE: COMPLEX ASBESTOS LITIGATION San Francisco Superior Court No. 828684 CERTIFICATE OF SERVICE BY MAIL I, Karin England, declare: I am a resident of the State of California and over the age of eighteen years, and not a party to the within action; my 8 business address is SEDGWICK, DETERT, MORAN & ARNOLD, One 9 Embarcadero Center, 16th Floor, San Francisco, California 10 94111-3765. 11 On August 22, 1997, I served the within: 12 RESPONSE OF CHEVRON PRODUCTS COMPANY TO PLAINTIFFS' STANDARD ASBESTOS CASE INTERROGATORIES TO ALL _ 13 DEFENDANTS 14 by placing a true and correct copy thereof in a sealed envelope, 15 with postage prepaid, addressed as shown below. 16 See Attached Service List 17 I am readily familiar with the firm's practice of 18 collection and processing correspondence for mailing. Under that 19 practice, it would be deposited with the U.S. Postal Service on 20 the same day with postage thereon fully prepaid at San Francisco, 21 California, in the ordinary course of business. 22 I declare under penalty of perjury"that the foregoing 23 is true and correct. Executed on August 22, 1997, at San 24 , California. 25 26 27 Karin England 8 IN RE: COMPLEX ASBESTOS LITIGATION San Francisco Superior Court No. 828684 PLAINTIFFS' COUNSEL SERVICE LIST Law Offices of Bruce L. Ahnfeldt P.O. Box 6978 Napa, CA 94581 Brayton Harley Curtis Attorneys at Law 222 Rush Landing Road P.O. Box 2109 Novato, California 91948 Law Offices of Jack K. Clapper Marina Office Plaza 2330 Marinship Way, Suite 140 Sausalito, CA 94965 Law Offices of Christopher Grell The Monadnock Building 685 Market Street, Suite 540 San Francisco, CA 94105 Harrison & DeQarmo One Daniel Burnham Court, Suite ; San Francisco, CA 94109 -C Visse & Yanez One Daniel court, Suite 220C San Francisco, CA 94109 Wartnick Chaber Harowitz Smith & Tigerman 101 California Street, Suite 2200 San Francisco, California 94111 r._ " T: (707) 224-6547 F: (707) 224-2518 T: (415) 898-1555 F: (415) 898-1247 T: (415) 332-4262 F: (415) 331-5387 T: (415) 541-9866 F: (415) 541-9869 T: (415) 441-1707 F: (415) 441-0340 T:. (415) 441-0340 F: (415) 441-1707 T: (415) 986-5566 F: (415) 986-5896 S EOGWICK- DETECT MORAN 6 UNOL SDSF3/2S61 One Embercedero Center Sixteenth Floor Sen Frenciece* Celifontte 94111-3765 Tel. 415.781.7900