Document 5Le7wv62bO6w9r9bYowdj50w0

FILE NAME Kaiser Gypsum KG DATE 1984 DOC KG039 DOCUMENT DESCRIPTION Plaintiff's 1st Set of Interrogatories GREENE O'REILLY BROILLET PAUL SIMON MCMILLAN WHEELER & ROSENBERG LAWYERS LOS ANGELES OFFICE 816 SOUTH FIGUEROA STREET LOS ANGELES CALIFORNIA 90017-2518 213 482-1122 213 482-1350 Attorneys for Plaintiffs SPACE BELOW FOR FILING STAMP ONLY SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 10 11 LOS ANGELES UNIFIED SCHOOL DISTRICT 12 Plaintiffs 13 VS. 14 CORNING FIBERGLAS 15 CORPORATION et al 16 Defendants 17 Smet CASE NO C 440 317 See? Smet PLAINTIFF'S FIRST SET OF | | Sa INTERROGATORIES PROPOUNDED Samet TO DEFENDANT my Subcontractors installers eae and applicators eet ) Nagel ewe 18 19 TO DEFENDANT KAISER GYPSUM COMPANY INC 20 AND TO THEIR RESPECTIVE ATTORNEYS OF RECORD HEREIN 21 provide 22 Plaintiff requests that you answers to the following 23 interrogatories pursuant to Section 2030 of the California Code 24 of Civil Procedure within thirty 30 days of service thereof 25 // 25 // 27 / 28 // GENERAL PROVISIONS These interrogatories ask not only for your knowledge and the contents of your own books and records but also knowledge of all other persons with whom inquiry may reasonably have been made from the contents of books and records available to you for examination Your answers to these interrogatories should be based on all the aforementioned sources 10 11 KUSENBERG KUSENBERG KUSENBERG KUSENBERG KUSENBERG KUSENBERG 9017-28KUSENBERG STRET KUSENBERG OFICE DA & ? IRNIA RSWHEELER WHEELER 482-12 482-1350 WHEELER 12 13 14 WHEELER LA WHEELER CA WHEELER AN CA 15 213 213 SOUTH WHELER ANGELES , ANGELES SOUTH 16 MCMILAN ANGELES MCMILLAN LOS ANGELES MCMILLAN ANGELES MCMIL AN 816 ANGELES MCMIL AN 816 ANGELES 17 MCMILLAN LOS MCMIL AN LOS 18 19 20 21 2 23 2 25 26 28 If following your exercise of due diligence to answer any interrogatory you are still unable to provide the information requested please state in detail a your answer to the fullest extent possible b why you are unable to answer more fully c d what efforts you have made to answer fully the anticipated date of your completion of said investigation and discovery necessary to answer fully When an interrogatory asks you to identify a writing you may in lieu of answering that interrogatory attach a copy of that writing with a statement in answer to the interrogatory that such copy is attached and such copy is a true copy of the original of the writing writing If you refuse to voluntarily then identify each such writing attach a in detail e copy of that so that it may // be produced by you in response to Plaintiff's Notice to Produce or other discovery device DEFINITIONS Acoustical insulation products as used herein means and refers to any product which is designed manufactured assem- 8 bled compounded prepared installed or applied for use in 9 separating conducting bodies by means of nonconductors So as to 10 prevent the transfer of sound 11 RosenbERG 9017-256 12 STRETCE STREET 13 482-1350482-12ENIA . . 14 LAWY FIG CAL 15 WHELR ANGEL 213 213 LOS SOUTH 16 ANGELS816 17 Mcilan LOS 18 |] 19 Sell or any tense of the verb as used herein means to give up something to consideration to pass another for money or other valuable title of something to another for a price Supply or any tense of the verb as used herein means give donate provide furnish offer or make available 20 Thermal insulation products as used herein means and 21 refers to any product which is designed assembled manufactured 22 compounded prepared installed or applied for use in separating 23 conducting bodies by means of nonconductors so as to prevent the 24 transfer of heat or cold 25 26 Writing as used herein means and refers to that term as it has been used and interpreted pursuant to California Evi-| 28 dence Code Section 250 including transcripts of oral M were communications photographs videotapes audiotapes and record- ings and films You as used herein means and refers to you your agents servants employees officers directors subsidiaries divisions or representatives and anyone else acting on your behalf or at your request NOTE _ IF YOU ARE UNSURE AS TO THE INTENT OR MEANING OF ANY OF THE 10 AFOREGOING GENERAL PROVISIONS OR DEFINITIONS YOU ARE HEREBY 9017-2516 AUSENDERE 90017-2516 AUSENDERE 90 17-2516 AUSENDERE 90017-2516 AUSENDERE AUSENDERE AUSENDERE AUSENDERE AUSENDERE 2 , a,e 90017-2516 90 17-2516 STREET 90017-2516 90017-2516 NIA NIA 482-1122 482-1350 NIA 482-1350 482-1350 482-1122 482-1350 A 482-1122 482-1122 , , ,LAWYE LAWYE , , , LAWYE , ,LA,WYE AA AA NVI NVI NVI FIG ANGEL ANGEL SOUTH SOUTH SOUTH LOS 482-1350 CALE 482-1350 CALE CALE ) 213 , 213 ANGELES 213 ANGELES ANGELES ANGELES NVI NVI , , ANGELES 816 ANGELES 816 ANGELES ,,, LLOOSS 11 12 13 14 15 16 17 18 REQUESTED TO HAVE YOUR ATTORNEY CONTACT ATTORNEYS OF RECORD FOR PLAINTIFF WHO HEREBY OFFERS TO PROVIDE ANY NEEDED ASSISTANCE FOR YOU TO UNDERSTAND THE INTENT OR MEANING OF THE FOREGOING IF OBJECTIONS TO THESE INTERROGATORIES ARE NOT FILED WITHIN THIRTY 30 DAYS AS PROVIDED IN CODE OF CIVIL PROCEDURE SECTION 2030 SAID OBJECTIONS WILL BE WAIVED 19 INTERROGATORIES 20 21 1. Have you ever installed applied on cr within any | 22 property owned leased or maintained by the plaintiff any of the | 23 following products 24 25 a Acoustical insulation 22 b Thermal insulation c Wallboard 28 d Floor tiles 4 e Fire curtains f Fire doors g Ceiling tiles 8 9 10| 9017-2018 11 90017-2018 12 90 17-2018 90017-2018 RosenbERG STRET 90017-2018 90017-2018 90017-2018 90017-2018 NIA 482-1350 NIA 482-1122 482-1350 13 482-1350 J ~~ 482-1350 482-1350 14 482-1350 482-1350 FIGL 482-1350 LAWY CALIF 15 ) 213 WHELR ANGEL 213 213 SOUTHLOS 16 ANGELS816 17 MCILAN 1.OS 18 19 20 21 h Boiler lagging i Pipe coverings j Asbestos cloth k Spray wall or ceiling covering including but not limited to texturized paint and stucco 1 Spackling compound m Wall or ceiling joint compound or sealer n Spray structural fire retardant 0 p q Cement Wall or ceiling joint tape Insulation tape tive 2. If your answer to Interrogatory No. state with regard to each product installed 1 is affirma- | or or applied by you > installation a The address of each said property where each or application occurred and the respective dates for 22 such 23 b The location within each property where each 24 said product was installed or applied 22 c The brand name of each said product 26 d The name of the manufacturer c each said product 28 /// e The name of the person or entity of whom you 7 8 10 11 ROSENBERG ROSENBERG ROSENBERG ROSENBERG ROSENBERG ROSENBERG ROSENBERG 9017-256 ROSENBERG ROSENBERG IA ^' 12 13 482-1 482-1350CALIFC Wheeler CALIFC Wheeler FIGU Wheeler FIGU Wheeler ANGELES CALIFC CALIFC FIGU CALIFC Whe ler ANGELES 15 Wheeler ANGELES CALIFC 14 memes Wheeler , 213 213 ANGELES SOUTH SOUTH ANGELES LOS SOUTH ANGELES wdec McMillan McMillan LOS SOUTH ANGELES LOS SOUTH ANGELES 16 McMillan ANGELES V McMillan 816 ANGELES McMillan 816 ANGELES 17 QALI McMillan LOS McMillan LOS 18 19 20 acquired each said product f The identity sufficient for a Notice to Produce of each writing which refers to said installation g The identity sufficient for a Notice to Produce of each writing in your possession which describes promotes and advertises said products including but not limited to price sheets catalogs etc h The name address telephone number and title of each individual who participated in each said installation and application i The name address telephone number and title of each individual who on your behalf negotiated contracted and agreed to each said application 3. If your answer to any subpart of Interrogatory No. 1 is affirmative did any of said product contain asbestos regard 4. If your answer to to any product state Interrogatory with regard No. to 3 is yes with the asbestos- 21 containing product: 22 23 a The brand name of said product s 24 b The name of the manufacturer of said prod- 25 uct s 26 c The name address and telephone number of the person or entity from whom you acquired said product s 28 // d The address of each property of the plaintiff and the location within said property where you installed and applied said product and the date of said installation or 7 8 9 10 . ; 11 : } - Rosenbrg 9017-28 we 12 bey STRET ew & a STREET 13 482-1350482-12 oy CALIFONIA Ober 14 ANAS BF LAWYE FIGL CALIFONA 15 Whelr ANGEL 213 213 ... ... ... LOS SOUTH 16 ANGELS 918 17 McilanCALEN LOS 18 19 20 21 22 23 24 25 26 application e The name address telephone number and title of each individual who participated in each said installation or application referred to Interrogatory No. d herein above Whether said product contained any warn- ings cautions or caveats which referred to hazards associated with exposure to asbestos 5. If your answer to Interrogatory No. 3 is No with regard to any products state with regard to each said product a Each fact upon which you base your response b The name address telephone number and title of each individual who has knowledge of facts upon which your | response is based c The identity sufficient for a Notice to Produce of each writing which supports your response /// Tt // /// /// /// /// 28 /// See 6 Identify and describe the name business address home address business telephone number and home telephone number of each person who has knowledge of the facts documents and oral communications described in the preceding interrogatories DATED December 26 1984 GREENE O'REILLY BROILLET PAUL SIMON MCMILLAN WHEELER & ROSENBERG 10 11 KOSENBERG 9017-2516 KOSENBERG 90017-2516 KOSENBERG 9017-2516 12 KOSENBERG 90017-2516 KOSENBERG 90017-2516 KOSENBERG 90017-2516 KOSENBERG A 13 & 482-12 482-1350 Wheeler CALIF 14 LAWYER Wheeler 213 213 15 MMCCMMIILLLLAANN AANNGGEELLEESS 16 MCMILAN ANGELES MCMILLAN ANGELES 17 MCMILLAN LOS MCMILLAN LOS 18 19 20 21 22 23 24 25 26 28 AARON H. SIMON Attorneys for Plaintiffs PROOF OF SERVICE BY MAIL STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES SS I declare that I am employed in the County of Los Angeles State of California I am over the age of eighteen years and not a party to the within cause my business address is 816 South Figueroa Street Los Angeles California 90017 On December 27 1984 I served the within document entitled RosenbrgCESTRET 9017-28 NIA 482-1350482-12 | |)~~ WHELEDLAWY ANGEL FIG CAL^ 213 213 LOS SOUTH ANGELS816 MCILAN LOSLOS 18 || PLAINTIFF'S FIRST SET OF INTERROGATORIES PROPOUNDED TO DEFENDANT Subcontractors installers and applicators on the interested parties by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid in the United States mail at Los Angeles California addresseads follow 19 KINCAID GEANUNZIO CAUDLE & ee HUBERT 200 Webster Street Second Oakland CA 941604-0828 Attn Patrick Hagan Esq Fl I declare under penalty of perjury that the foregoing is true and correct Executed this 27th day of December 1984 at Los Angeles California