Document 5L98KE0r4KYeJMa9arX7g9mV5
ST00 I 04B I
PLAINTIFF'S EXHIBIT
Cook. Davis S McFall
ATTORNEYS AT LAW TWO HOUSTON CENTER 000 FANNIN. SUtTE 2600
Houston. Texas 77010-1003
TELEPHONE C713) 737-0*40
TELECOPIER <7131 737*1068
ICERRr CARL HACAN
June 16, 1987
ROBERT C. floy:
Ms. Frances Bennett District Clerk Brazoria County Courthouse 400 North Velasco Angleton, Texas 77515
0'
Re:
Cause No. 86-G-2460; Erma Faye Harris, et al vs. Dow Chemical Company, et al? In the 239th Judicial District Court of Brazoria County, Texas
Dear Ms. Bennett:
Enclosed for filing, please find Defendant, Combustion Engineering, Inc.'s Answers to Plaintiff's Interrogatories.
Please file mark the enclosed extra copy of the above-referenced pleading and of this letter and return to us in the enclosed stamped, self-addressed envelope.
By copy of this letter, all interested parties of this lawsuit have been notified of this action.
KCHrjb Enclosure CE38 (30.)
cc: All counsel of record
ST00 I 0482
NO. Bb G 2460
ERMA FAYE HARRIS, INDIVIDUALLY AND AS NEXT FRIEND OF WESLEY HARRIS, A MINOR, BETTY HARRIS ALLEN, PHYLLIS HARRIS KIRBY AND JAMES HARRIS, ADULT CHILDREN
VS.
THE DOW CHEMICAL COMPANY, ET AL
)
)
) ) ) )
)
) ) ) ) )
IN THE DISTRICT COURT OF BRAZORIA COUNTY, TEXAS 239TH JUDICIAL DISTRICT
DEFENDANT COMBUSTION ENGINEERING, INC.'S ANSWERS TO PLAINTIFF'S INTERROGATORIES
TO:
Erma Faye Harris, Individually and as next friend of Wesley Harris, a minor, Betty Harris Allen, Phyllis Harris Kirby and James Harris, adult children, Plaintiff herein, by and through her attorney of record, J. Ronald Tucker, 1100 Leeland, Houston, Texas 77002-7697.
Pursuant to Rule 168, of the Texas Rules of Civil
Procedure, Defendant Combustion Engineering, Inc. hereby
serves upon Plaintiff in the above cause these answers to
interrogatories propounded by the Plaintiff in this cause.
Respectfully submitted, COOK, DAVIS & McFALL
K^rry C/. Hagan State Bar No. 0884500 Two Houston Cerfter 909 Fannin, Suite 2600 Houston, Texas 77010-1003 713/757-0440
Attorneys for Defendant, Combustion Engineering, Inc.
,
q
__ CO
CO co
CERTIFICATE OF SERVICE
I hereby certify that Defendant1 s Answers to P forwarded to counsel for of record.
_, 1987, ave been
counsel
2
Interrogatories
1. Does your company manufacture asbestos insulation or asbestos containing mater-1 => 1 s? T* rhe ticwo- '<
piease describe in full, exact and precise derail wnac products you manufacture or have ever manufactured in the past, giving the dates that those products were manufactured and the brand name under which those manufactured asbestos containing products were marketed.
Answer: No.
co
2. Please state the beginning date on which your company began * manufacturing asbestos and/or asbestos containing products <=> and list each year after that date which your company ^
manufactured asbestos and/or asbestos containing products,
giving the brand names under which the products
were _
marketed in each year and if your company has stopped ^
manufacturing such products, give the date on which said
products were last manufactured or produced.
Answer: See Exhibit "A" attached hereto.
3. Please state your name, official title, address, and the capacity in which you are answering these interrogatories.
Answer:
Richard D. O'Connor, Director, Valley Forge
Services, Combustion Engineering, Inc., P. O. Box 828,
Valley Forge, Pennsylvania.
4. Please state the name, address and occupation of any and all parties who contributed any information to the answering of these interrogatories.
Answer: See answer to interrogatory no. 3 and Frank T. Christenson, Former Assistant to Vice President of Industrial Sales, C-E Refractories, Combustion Engineering, Inc., Valley Forge, Pennsylvania.
5. Did this Defendant, between the years of 1951 and present, manufacture and/or sell and/or furnish asbestos containing products for use by Dow Chemical Company and/or Dow Badische and/or Badische Corporation? If the answer is yes, please list the dates upon which such products were furnished and/or sold to Dow Chemical Company, Dow Badische, and/or Badische Corporation and attach any and
3
all sales invoices for asbestos containing products to these companies.
Answer:
This Defendant haH
s=ler t~ Brdirchr
Corporation or to Dow Badiscne. This Defendant has records
of one sale to Dow Chemical Company of $50.85 worth of
Stic-Tite. This was was made in 1971 in Ohio.
6. Give the name and trade name of all types of asbestos
containing materials manufactured or sold by you, giving
the dates that you began to manufacture or sell such
materials.
Include for each a description of the
materials, including the asbestos and silica content.
Answer: See Exhibit "A" attached hereto.
7. Before placing your asbestos containing products on the market, did you make, or cause to be made, any studies to determine whether your products would be hazardous to persons who would be handling them? If so, please state what study, or studies were done, by whom and what dates.
Answer: No.
8. When was your company first aware that asbestosis could occur among workers who were exposed to the inhalation of fibers from products manufactured or sold by you? __j
1969, exact date unknown.
i~T~ What--Step'S were insuinuned Eo prevent damage or further CD
damage to the workers exposed to asbestosis?
xr
co
Answer:
In 1969, warning labels were placed on the cn
packaging of all asbestos containing products. Defendant
required production employees in its own plants to wear
respirators when working with asbestos; and, in 1972
Defendant
discontinued the
manufacture
of all
asbestos-containing products.
10. Has your company been sued prior to this occurrence for any claim related to asbestos damage? If so, state:
a. Cause number and style of the case
B. City, county and state where filed
4
STOOI0U8S
c. List all parties to the suit
d. List all attorneys involved in the suit
e. The resulz cf the suir.
f. The dates of such filings.
Answer: Defendant objects to this interrogatory on the grounds that the answer, if given, would be entirely irrelevant to any of the issues involved in this case, and woul^^not be likely to lead to the discovery of relevant eyd^fence.\ This Defendant has been involved in an excess of (''40,000 asbestos cases throughout the United States, each Xcase^bartfing multiple parties and the claims made by the
vSTuous plaintiffs vary markedly from case to case. To require Defendant to prepare the information requested would be entirely burdensome, harassing to this Defendant in view of the possible relevancy of the material provided, and would be extremely expensive.
11. Have you ever been fined or otherwise forced to take corrective action regarding asbestos hazards as a result of an inspection by OSHA or any other governmental agency? If so, state when and by what agency.
Answer: No.
12. a.
How many current and previous employees of your company have made a claim or claims for damages as a result of exposure to asbestos prior to 1987?
b. List each employee or former employee and give the date of such claim and the disposition of the claim.
Answer: There have been a few workman's compensation claims, the first one having been made in 1973. Defendant does not have records of such claims.
13.
In accordance with Rule 166b2(d)(1), please state the name, address and telephone number of any expert witness(es) whom you intend to call upon to testify in your behalf in the trial of this cause and for each such expert, a brief synopsis of the expected testimony and subject matter said expert(s) will be testifying to.
5
Answer: Defendant will supplement this answer at such time as experts have been determined.
14. Do you maintain an OSHA log at your facility? If so, how many years do you keep sucn logs: In answering rnis interrogatory, please attach copies of all such logs as you have in your possession or under your care, custody and/or control.
Answer: No. In addition, during most of the time this Defendant manufactured asbestos-containing insulation products, OSHA was not in existence.
15. Please list your chief safety engineers or other type safety officers for the years 1951 to present with complete addresses for each such person.
Answer:
During the time this Defendant
asbestos-containing insulation products, i.e.
through 1972, it had no designated safety
officers.
manufactured from mid 1963 engineers or
16. What type of warnings regarding the dangers inherent in working around asbestos were disseminated to your employees from the time your company first became aware of the dangers of asbestos through the present? In answering this interrogatory, please attach true, correct and complete copies of all such warnings.
Answer: See answer to interrogatory no. 9 and Exhibit "B" attached hereto.
17. What safety measures and devices such as respirators, were implemented to protect your employees and required after your company first became aware of the dangers of asbestos and what years such measures and devices were required.
Answer: See answer to interrogatory no. 9.
18. What type of decontamination procedures were instituted, and when, to reduce the risk of exposure to asbestos of your employees?
Answer: See answer to interrogatory no. 9.
19. Please list your workers compensation carrier and address of same for each year from 1951 through the present.
ST00 t 0U87
6
88'iOIOOlS
Answer: During the time that this Defendant manufactured asbestos-containing insulation products, its workman's compensation carrier was Travelers Insurance Company, Hartford, Connecticut.
20. Has your company ever been a member of any of the below listed organizations or associations? If yes, give the dates in which your company was a member of each organization.
a. Therman Insulation Manufacturer Association, Inc.
b. National Insulation Manufacturers Association, Inc.
c. Asbestos Insulation Association.
d. Asbestos Textile Institute.
e. Industrial Hygiene Foundation of America or its successor. Industrial Health Foundation.
Answer: No.
21. Prior to 1960, did you or your predecessor ever have any labor inspectors or anyone from your company whose job it was to go into areas where your products were being used or installed, to make a dust level count? If so, state when this procedure started, the purpose of such procedure, and what action, if any, was taken in response to these findings.
Answer: Defendant has no predecessors as it understands
that
term,
and
Defendant
did not manufacture
asbestos-containing products prior to i960.
22. Please state whether or not any division of your company or subsidiary engaged in any activity involving the use of asbestos or asbestos products, had any claims for lung diseases or death from lung disease attributable from asbestosis, mesothelioma, lung cancer, broncogenic cancer or metastatic carcinoma. If the answer is yes, give the name of such employees and attach copies of such claims.
Answer: See answer to interrogatory no. 12.
23. Has your company, or its predecessor, ever conducted any studies concerning the effects of the inhalation of
7
STOOI0489
asbestos dust fibers on one using or being exposed to any of the asbestos materials manufactured, sold, or distributed by you. If your answer is yes, give the date and nature of such studies, the name of the Dersor= conducting sucn studies, me purpose of the study(ies), and attach a copy of any report based upon studies.
Answer: No.
24. State the year that this Defendant, or any predecessor, was first advised of either threshold limit values, or maximum allowable concentrations of both asbestos dust and total dust by the American Conference of Governmental Industrial Hygienist, and state the name of the employee-official of the company receiving such advice and attach copies of the instrument communicating such advice.
Answer: Defendant is unaware of the exact date of such communication if it did, in fact, occur.
25.
When do you contend the state of the medical literature was such that you had a duty to warn persons exposed to asbestos containing products or asbestos dust that such exposure could cause severe, disabling lung disease, including but not limited to, chronic obstructive pulmonary disease, asbestosis, mesothelioma, carcinoma and/or chronic bronchitis?
Answer: Defendant contends that it had no duty to warn of
alleged harmful effects of asbestos exposure until OSHA
published regulations in that regard.
However, this
Defendant did, in fact, warn of the dangers of asbestos
product prior to that time when it learned of the potential
health hazards associated with such products.
26. Does Defendant contend that asbestos manufactured so as to eliminate all hazards to workers working with them? fully.
products can be potential health
If yes, explain
Answer: Defendant does not have sufficient scientific knowledge with which to answer this interrogatory and therefore it objects to this interrogatory.
27. Is it possible for a layman to distinguish your asbestos containing products from those manufactured or distributed by your competitors when such products have been removed
8
from their container or containers? If so, please describe how you contend your product can be distinguished from those of a competitor.
n,~sv>' r
Ueiencant is unaware oi tne pnysicaj.
characteristics of products manufactured by other
defendants and therefore cannot answer this interrogatory,
nor can it answer as to what a layman would find to be
distinguishable.
28. Was such threshold limit value or maximum allowable concentration inquired about in interrogatory no. 25 total dust or just asbestos dust?
Answer: Defendant asumes that this interrogatory refers to the inquiry in interrogatory no. 24. See answer to interrogatory no. 24.
29. Please state what percentage of the total market for
asbestos and/or asbestos containing products, including
asbestos insulation your company has realized from the date
which your company first began manufacturing and marketing
asbestos containing products and each year thereafter,
until the present date or until the date that you last
manufactured
these
products.
In answering this
interrogatory, answer first on the basis of nationwide
sales and secondly, on the basis of sales within the State
of Texas, either . direct sales, or sales through
distributors and/or retailers.
Answer: At one time, Defendant made an attempt to estimate its national market for asbestos product. As best as could be determined, at no time was Defendant's percentage of the national market in excess of one-tenth of one percent. Defendant has never attempted to estimate its market share in Texas, and could not do so without knowing the total market of Texas which would include all manufacturers.
30. What relationship has existed since 1951 and continuing to the present, between your company and Dow Chemical Company and/or Dow Badische and/or Badische Corporation? In answering this interrogatory, give the information for each year from 1951 to 1987.
Answer: See answer to interrogatory no. 5.
0 6 *10 I 0 0 1 S
9
THE STATE OF .PENNSYLVANIA
COUNTY OF MONTGOMERY
)
j
)
BEFORE HE, the undersigned authority, on this day personally appeared Richard D. O'Connor, Director of Valley Forge Services, Combustion Engineering, who, being by me duly sworn, upon oath stated that he is authorized to make this Affidavit on its behalf, and that each of the foregoing answers to Plaintiff's Interrogatories is true and correct.
TOO!049 I
C.30 KCH/rg
Notary Public n and fdir /V7 -r-T-- County,
Hymoutn Twp.. Montgomery Co Hy Commission Expires Nov. 20 1988
Printed name of Notary
26`l0 1001S
SERVICE LIST
Re: cause No. 86-G-2460; Erma Faye Harris, Individually and as Next Fnena of Wesley Harris, a Minor, Betty Harris Allen, Phyllis Harris Kirby and James Harris, Adult Children vs. The Dow Chemical Company, et al? In the 239th Judicial District Court of Brazoria County, Texas
Attorney for Plaintiffs:
J. Roland Tucker J. Roland Tucker & Associates Powell Building 1100 Leeland Houston, Texas 77002-7697
Attorney for Defendants:
Mr. Raymnd T. Matthews 3600 Two Houston Center 909 Fannin Houston, Texas 77010
Mr. Wilton Chaulker Lorance & Thompson 303 Jackson Hill Houston, Texas 77007
Mr. Frank Harmon, III Crain, Caton, James & Womble 3300 Two Houston Center 909 Fannin Houston, Texas 77010
Mr. Robert C. Floyd Floyd, Taylor & Riley 1301 McKinney Street, Suite 3660 Houston, Texas 77010
Ms. Martha Lawley Ryan & Shoss 1331 Lamar, Suite 1560 Houston, Texas 77010
Mr. Jeffrey Scott Giessel, Stone, Barker & Lyman 2700 Two Houston Center 909 Fannin Houston, Texas 77010
STOOI 0493
Cook. Davis 8 McFall
attorneys at Law TWO HOUSTON CENTER 909 FANNIN. SUITE 2600
Houston. Texas 77010-1003
r?r> f? &
Ifli JUK ID 087
TUiFHOWE (7131 737-OmO
TtLECOPIl* (7131 757-tOM
kiary caw. hacan
June 18, 1987
Ms. Frances Bennett District clerk Brazoria County Courthouse 400 North Velasco Angleton, Texas 77515
/
ROBERT C. FLOYD
; 1'
A r .n
I
! <)
Re: Cause No. 86-G-2460; Erma Faye Harris, et al vs. Dow Chemical Company, et al; In the 239th Judicial District Court of Brazoria County, Texas
Dear Ms. Bennett;
)sed for filing, please find Exhibits "A'S and "B" of Defendant, Combustion Engineering, Inc.' s Answers to]Plaintiff's Interrogatories, which were inadvertently left out when this pleading was submitted to your office on June 16, 1987.
file mark the enclosed extra copy o^^this letter and return to~~uS~-ic^fehe enclosed ^tamped, self^addfessed envelope.
By copy of this letter, all interested parties of this lawsuit have been provided with copies of these exhibits.
Thank you for your time and assistance on this matter.
KCH:jb Enclosures CE38 (31.) cc: All counsel of record
V
cccc
oo oo
XJ 4J XJ XJ
uuuu
2 <0 (0 (0 10 W CJ cj o o
2
M
<&
o Lx
13 Lx
"uO
*u0
10 10 (0 (0
2
or
cj
oooo
-Q
T3
J3
TJ
XoI
--Qo
Lx Lx Lx lx
a
o
a
cj
u10
ua
cntnoiaiionointnnmnmainnnn
OO'OO'OO'OO'OO'OO'OO'OO'OO'OO'OO'OO'fOllO'O'OO'OO'OO'OO' axixixjxjjaxijaxlijjaxijaxixijajaxi
jaxtxij3ijijxjj3xijajjx3jaxij3jaxix3
rlHHHHrtHHHHHHHHHHHrt
oooooooooooooooooo
E x h ib it "A"
Q 2 cot <2 o
,, o eH cn ZW W uas O > cn a e-< <
aw>
< < cj cj (M VO O O VO Tf IN N
Q M
3^ J
EM*
C
w
U
VO VO CM rX vo vo rOV 01 Ol 0v
CJ CJ CJ
(N (N* H*
^ *--T
non --**-.-
O -- m
I , I -wOO--OO--.n'-'O-~~O~C^J<--H.(<^C'-J.y
>o a\ in <n t"
o ww^ i <[>.--
co o o o o h co IN co
co h vrn r) * co n n
novrXr-trXrHinininvonovxroonxrt^
nnncannn
vo
r- n- r- vo r- r" r*
n
vo
WW\r-l WOl CO P00 VO vo VO \ VO o
nonoNrH-ooro'iMocUNOoVj'aOivooo\ovvoovvo ovovovovoHv ovoior-i
\W--,'v.rXWrX.-X\i-Xi-X,-X^-l\rXr-X
co co vo >-t vo nn
vo
<h
-Page l -
EWX 1< O t*
cn
* nn O vo vo vo C Ov OV Ov JD H H rt C
3
in t ^OvOVOOVU)VOyO ^ ^ \o vo yj u) \o VO vo
O' OV H H H S, H H ri H HHHHHHHH rX rX
CO
--ImTtm cn
o o o 1---- CO
K
2 o o aTST 0
rH
2 XX 0
CJ o 0 o
Q 0 02Q ^ i--4
0 0 0 i-X
2
o O' CP Lx O 2 cco M xx Ch Ex O O-x DO
( to a X
. H H
o 3 3* X
cn m m x z cga u
M H M XJ ffl
0l'Hp.Xa
p4 iX W 10
o
aa aa
Q* a
x--4J
4J
Ow CO
c 002 --
--a 2 C CJ
So 2
-- OO -^x
-- O JJ 4-> a cc o
Q 0) '--+J 1 "X
OX <0 to rX -rX
x- O' ffl caa
4-1 -'H ffl ffl
VO n rX
~^4J
3 C -- C x CJ CJ 1
w >--2 1
n-xQ 0
<
ex 2
O^O * --X ----
CL'- a o O' O' M Q 01 lx C C JJ
w2*
W i e xj 2
xx a x-o a-x-x c
X -- XJ cn 0 2 --x
O ffl 0
4J XJ
a Ex XJ O' Li <8 Id
ffl xj a 82 c ^
o -O .C .C Q XJ lx C CXHH ffl o
i 01 m v-- co o tj ffl TX 2 3 3 CJ a o
u uxx 10 JS lx 3C ffl 0)
Xi 9 n
z 81 --x c CHHEx Id onxi c c 2 >i cj U w ffl
E- -x cn 2 r >i
cm
xj <-x Q.XJ
< iJ
lx XJ Lx ov-x o a> ov o cn xa 3 ffl
1 lx Lx lx W 41 -*x c 2 cn u ov tn ia U Lx
M tiax gx o
Ji *i Vx o
co
2w
CL CL CL 0**x *X X (A Q L
2 o m iH -X
*J3333-WflK covicooiinKDK'
>*-x
Cu x
I
<
Q co
3 ca
ffl
cj
XJ
cn
<0 cj
BaaaaBaaaaaaaaaaaa
2 t--.
w0
0
2 0a M Pu
O'
< oa P E- c
2 -p O r-( a P
G 0 P *H
0* c
0O
vo u in
m O' u u A0
c -H .a -h a rH 4) P
0C O po -*r u o
f-H
0 0n Pp a0
c
-rH
rH 0
0P
O' c o
in 0
0 O' 0 P
JO pH
in IN
2
20 n 2 O' o* H0 0 <PP
2
O O
rPH
P
rH
OO
in in
p
H
rH
0
0P
o O' 0
o
rH
N* rH -rcH
in 0 0
o 0 P
0 U> P C
rH u o
P in o
E x h ib it "A "
-Page 2 -
a
2 CO
*c &. a
O Eh
r->* --* <
Eh CO 2WW w o* m u x
o o
X rr o< P " ao
a o
o '
o
*
o O
o
o
2 Eh < Ol
a
in
o
o
W 1 <N
< rH VO rH
r>
H
2
a
w cs
(M
Eh r*
0. 2o
\ GO
VO VO
N in
f* vo
(N P*
VO VO
t-H Eh
fM
a
CN ov
O'
a*
h CO
\
rH
N. rH
rH
rH
CO VO
VO
2
Q 2 CO H2o
O EEh CO 2 MW 2 2 CO O X CO OS Eh < W 2
a u Eh < a. 2o M h Eh CO CO 2
\
og
oo
O pr
rH IN
o
o
o H
m
\ <N VO r* CN ov \ rH vo
o
o X~ a OG
P o 0.0 o a rH < r>
m vo r*
O' ov
rH rH
Eh
2 2 r> r> <n
n
1 < VO
vo
vo VO
VO
vo
G Eh
CV
c\
c\ as
ov
c\
col rH
rH rH *H rH
u~> cr>
cd
CD H2n--r 2Nw-H
CD P rH
I-- CO
C0 0 iH
GO Eh gI
,,--,
a 0
P 0
2ao1
-Q-r G 0
P 0 X
2 0 rH
2 CO ^2r
r>H
p
p c
0 X -H
D 000
O -X
2
P rH >D
2 -ruH
d 0 HU 2
c
P rH X
0
CO 3
*n
0. -rH
P n 3e0
2 .X c * O 0 c
Go
-rH
G Eh
0
CO o c X P
1
a
M rH
3 *H -*H
XX
X ffl
O
X Cu
2
u
,_. ___
a a Ba a a
Hr -- w --
--
E-l
2 2 O' as 1 < VO vo G Eh O' a>
CO rH rH
VO vo av as
rH rH
2| G
CO 2
aX
M 2
a ,--.
O wC
Eh Eh
G<s
2
2
2 2 w
-roH 0 rH
2
--2
3
2 IN O Eh 0 E
2 CN in CO a 0
Mo
C3 0 0 Q 2 C
2P P
rH -H
H 0 0 CO 0 0
E* 2
2
h 0 GP
0 0
0U
2 P P D 0 rH 0
3 CO 2 t-H
P -rOH'
P rOH' P
Oo
2
0 P 0
EP C -H 0 H
2 < 2 Hr
a Har
__
TJ ---
V
--
oc
u
2 H
<
EZo
V
in p-h a
m
a au
u ac
o
a
-4haJ
rl c
in Oa' oo
in r-t a
in <4
4aaa4
-hLaci
rO> 4(48
rH C
in aCP oo
iinn
pH a a
aLi a
ro> in
u
a
cH
H a
4a4 c0
O' o
in pH a in a Li <* 4a4 ac
a -pH mo 4a-i
pH c -a o in o' o
E x h ib it "A"
-P age 3 - ,
o 22 cu Cofl
O - Eh COj ZMW U CL CD o >* cn Eh <
u CL
Xo -u*
u --0.0 a < r>
Q W Eh
<2 CoM HEh WEh
W
W
rCl pH
Xo u
ao a < r>
r rCh H
XO pCJp
Li 0.0 Q. < r>
VO o pH
X0o Li ao a r>
pH C H
Eh
W DC 1<
m vo
vO
VO
n
vO
O Eh cn
oHv
Ov H
acH\
ai
LD cn 1H4-
Cl-
VO
o /Cp-">l
cn
EUh
^ oH
.--..
.--..
.___-
1-- oo
3
a o
CocL
c
ow
a
p(H0 -cH
co
-pH
a
pH
oC
pH
a
pH
co
-pH
a
pH
3 10
cn e
MDO
4a0J
a "cH
4XoaJ
3 6 a
c
pH
3 S j-i a a oc O -pH
3 aa .X "cH
.X pH pH
.J lai ao aa aa aLi
W O cm
43 a G l 43 a a "H
aa 43-pH Li -pH
ph a ao aa Ga -xpH}
0 aa 43 Li ua
43
U -pH
M a HH Eh 3 HH
.3 <HH
-pH H
Z z -- Q --
Eh --
<--
TJ a -a -c
*w
a
pH
c a >
pH
>a1
c
a
L-pH
i
C a
cl
co-pH
3 oa
ph
pH
a
-H
a
pH
TX3 pWH S
44-pH a
a-
o 44
c
c
a- --aH
aLID-*h
a Li 3
Li O
X OLi J0 TJ 4O3 aa
4> 3 a -o
Li < . Li a O' O'
COL
a-
4W4
43O4
44343
C c-pH
C c-pH
XLai
* O -p (0 -pH -pH -pH B
M-H43<wLaaa
Ll a 3 44 44 44 -a
>44pHcacca
a a a -H o o m
CCQSS-TJOOEh
1 1 1 11111
Q Z B -o O < *
s-p --P
W
--P
>*
w X
rH wo
H o o o X
I
EXHIBIT "B"
m
OO* HOSPITAL
J1
y. v
\nV
j'epoV.of A^aagHT ; ' -
A" ' J'V
3 <?-y
jtlXX'X
// .L.X. , -oc.c.u..p..ar (O^H
fOUCMAN
/A
*~JXl.3
aui or FATtiKT fyir^/*iA^yjF.&rpur U.J-.
ii^
*7 c.oc,
T-- j/zys
klativc on mkno
i> ^
CMncorc* /< c*rc*ri cX*e _XU
OAT. //-
^ZuK a J^-T ^___ - .'!
/7 f}
f Ct&t , r
STOO 10685
27
,T.UI<I
m>m bnouoht to hospital , ,~
ArV --* r"
wAttlBf AMO fXTINT OP IMJUfllKB
"
_ ._
IT ?& vM
t i~.i.. . -J*--'
" `'I n
.Z________________________________
. -":5^|J
TBIATMI ht ahjx oispositiom op CAM W*^U-s a*" #4*.
---^-pJ -^-rr jfp.Q.
^
----------_" * ....... r-^s
I IT . OitABIUTV
/ 'A' / T
%OA-T* OIIAIILITV KBAN
. 1'
p<c.vo*
* .
fon. cor cohomm nmifuo *
-'>7 -
^ - //^O
__________________ ...A.-^V
*
STOO10686
STOO10687
ST00I0689