Document 6O3dvDX4ryqdqDE95Grr7jx4

FILE NAME Armco ARM DATE 1998 DOC ARM013 DOCUMENT DESCRIPTION Legal Armco's Responses to Interrogatories Membership in IHF AIHA etc. IHF Card Says 1961-1971 1 || JAMES W. HUNT - Bar No. 122582 SUZANNE N. MCNULTYMCNULTY Bar No. 140263 2 | MENDES & MOUNT LLP 725 South Figueroa Street 3 } 19th Floor Los Angeles California 90017-5419 4 213 955-7700 5 | Attorneys for Defendant ARMCO INC 6 PARA " ATTY CLASS RECEIVED TH F APR 14 1998 BRAYTON HARLEY CURTIS OVERNIGHT HAND MAIL __ ___ 7 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 IN AND FOR THE COUNTY OF SAN FRANCISCO 9 10 || IN RE 11 | COMPLEX ASBESTOS LITIGATION 12 13 ) NO ARMCO ) ) DEFENDANT DEFNDAT INC.'S ) AMENDED RESPONSES TO ) PLAINTIFFS GENERAL ORDER NO 129 INTERROGATORIES 14 INTRODUCTION 15 Defendant Armco Inc. hereby responds to Plaintiff's General Order No. 129 16 Interrogatories as follows 17 Discovery is continuing Initial production and review of documents has just begun in 18 ; certain cases and these answers are based upon information presently known Other 19 information may become available and defendant reserves all of its rights to amend and 222 supplement these responses if and when additional information becomes known 222 GENERAL OBJECTIONS 222 1 Defendant's responses to these interrogatories are based upon information 23 currently available and are made without prejudice to defendant's rights to use subsequently 24 ~ discovered facts or facts currently known but for which the relevance significance or 25 applicability has not yet been ascertained If and as additional responsive information or 26 documents are discovered these responses will be supplemented to the extent that 27 supplementation may be required by law 28 GO129.AMD 1 A. Joseph Thompson v Abex Corporation et al Case No. 953830 2 B. Superior Court of the State of California County of San Francisco 3 C. The deposition of Ernest J. Blache Jr. taken October 12 1994 D. Brayton Gisvold & Harley presently known as Brayton Harley Curtis 5 E. Juliette F. Finley Tooker & Antz 131 Stewart Street San Francisco 6 California 94105 7 INTERROGATORY NO 13 8 For each of the following please state whether at any time within the time frame or 9 until such time as any defendant which had been engaged in MARKETING RAW 10 ASBESTOS or CONTAINING PRODUCTS discontinued the MARKETING of 11 such products this defendant was a member or paid dues for any representative of THIS 12 DEFENDANT excluding faculty members of educational institutions to be a member of the 13 following 14 A. 15 B. 16 B. 17 18 2222222 F. American Conference of Governmental Industrial Hygienists American Industrial Hygiene Association American Petroleum Institute American Railroad Association Asbestos Cement Producers Association Asbestos Information Association please answer through date of YOUR 2222222 answers 2222222 G. Asbestos Information Association America please answer 2222222 through date of YOUR answers 2222222 H. Asbestos Textile Institute ATI 2222222 I. Industrial Hygiene Foundation and Industrial Health Foundation IHF 2222222 Industrial Mineral Insulation Manufacturers Association L. 26 Magnesia Insulation Manufacturers Association 27 Magnesia Silica Insulation Manufacturers Association 28 M. Mineral Wool Institute GO129.AMD 7 N. National Insulation Manufacturers Association NIMA 0 National Safety Council P. New York Academy of Sciences 4 Q. Quebec Asbestos Mining Association QAMA : 5 R. Refractories Institute 6 S. Safe Building Alliance please answer through date of YOUR answers 7 T. Thermal Insulation Manufacturers Association TIMA 8 U. U.S. Maritime Commission 9 V. IDENTIFY any other organizations associations or groups of manufacturers 10 miners distributors importers labelers suppliers and sellers of ASBESTOS- . 11 CONTAINING PRODUCTS of which THIS DEFENDANT was a member 12 W. IDENTIFY any such representative of THIS DEFENDANT 13 RESPONSE TO INTERROGATORY 13 14 A. Yes 15 B. Yes 16 Yes C. 17 Upon information and belief no 18 Upon information and belief no B. 19 Upon information and belief no 20 Upon information and belief no 21 Upon information and belief no 22 I. I. Yes K. 23 Upon information and belief no 24 Upon information and belief no 25 Upon information and belief no 26 Upon information and belief no N. 27 Upon information and belief no 28 Yes GO129.AMD 8 1 P. Upon information and belief no 2 Q. Upon information and belief no 3 R. Upon information and belief no 4 S. Upon information and belief no 5 T. Upon information and belief no 6 U. Upon information and belief no 7 , Upon information and belief none 8 W. Not applicable - 9 | INTERROGATORY NO 14 10 For each organization association or other entity identified in YOUR Response to 11 || Interrogatory No. 13 please state 12 A. The dates during which THIS DEFENDANT was a member 13 B. The name of any publication received by THIS DEFENDANT from such 14 || association or organization 15 C. The name of any committee or subcommittee of which THIS DEFENDANT 16 |) was a member and the dates of such committee or subcommittee membership 17 | RESPONSE TO INTERROGATORY NO 14 18 A. American Conference of Governmental Industrial Hygienists 19 Defendant is uncertain when it was a member of the American Conference of 2 || Governmental Industrial Hygienists Additionally defendant has been unable to find any 2 || information responsive to subparts B and C of this interrogatory If information 2 || pertaining to this defendant's membership in the American Conference of Governmental 23 || Industrial Hygienists becomes available this defendant will supplement this response at a 24 || later time 25 B. American Industrial Hygiene Association 26 Defendant is uncertain when it was a member of the American Industrial Hygiene 27 | Association Additionally defendant has been unable to find any information responsive to 28 || subparts B and C of this interrogatory If information pertaining to this defendant's MMCASES GO129.AMD 9 membership in the American Industrial Hygiene Association becomes available this defendant will supplement this response at a later time C. American Petroleum Institute 4 5 6 7 1961-71 1961-71 1961-71 1961-71 8 1961-71 9 10 11 12 13 14 15 Armco Steel Corporation is listed as a member on the API company membership roll for 1972 1973 and 1974 I. Industrial Hygiene Foundation Upon information and belief Armco Steel Corporation was a member of the Industrial Hygiene Foundation in 1961 1963 1964 1966 1967 1968 and 1969 as to other particular years Armco Steel Corporation's membership is undetermined O. National Safety Council American Rolling Mill Company is listed as a charter member beginning in 1935 and is listed on the membership rolls for 1936 1937 1944 and 1945. Armco Steel Corporation is listed as a member in 1951 through 1954 1960 and 1961 through 1964. Armco Inc. was a member of the Metals Committee in 1935 through 1936 and chairman in 1936 through 1937. Armco Inc. was a member of the Council Service Committee in 1944 and an 16 Advisory Chairman to the Metallic Coating Industry Committee for the metal section in 1951 17 and 1952. Armco Inc. was a member of the Steel Industry Committee in 1961 through 18 1964 and chairman in 1951 and on the Trade Associations Liaison Committee in 1952 an 19 Advisory Chairman to the Metal Section Steel Industry Committee in 1953 1961 and on the 20 Research and Advisory Committee in 1962 through 1964. Armco Inc. was a member of the 21 Metals Section Engineering and Consulting Committee in 1961 and 1962 and then a member 22 of the Metal Section Technical Publications Committee in 1963 and 1964 23 INTERROGATORY NO 15 24 Had THIS DEFENDANT prior to 1973 received any DOCUMENTS containing 25 results or conclusions of any studies and tests conducted by Bonsib for Standard Oil of 26 New Jersey relating to asbestos exposure in the workplace or the human health consequences 27 of exposure to asbestos If so 28 GO129.AMD 10