Document 6RaJEggwqvENMgqw4043ZNL96
FILE NAME: Shell (SHEL) DATE: 0000
DOC#: SHEL018 DOCUMENT DESCRIPTION: Excerpt - Defendant's Responses to Plaintiffs Interrogatories
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SEDGWICK, DETERT, MORAN & ARNOLD STEPHEN JONES {Bar No. 040884) 2 BERRIDGE R. MARSH (Bar No. 077304) HOLLY A. HARRIS (Bar No, 132336) 3 One Embarcadero Center, 16th Floor San Francisco, California 94111-3765 4 Telephone: (415) 781-7900
5 Attorneys for Defendant SHELL OIL COMPANY
6
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
litigation 12
13
14 ------------------ ----------------15
) NO. 828684
)
) RESPONSE OF DEFENDANT SHELL OIL ) COMPANY TO PLAINTIFFS' STANDARD ) ASBESTOS CASE INTERROGATORIES TO ) ALL DEFENDANTS
)
16 PROPOUNDING PARTY: 17 RESPONDING PARTY: 18 SET NUMBER:
PLAINTIFFS SHELL OIL COMPANY GENERAL ORDER 129
19
Defendant SHELL OIL COMPANY (hereinafter "Shell")
20 provides the following objections and responses to San Francisco
21 Superior Court General Order No. 129 Plaintiffs' Standard
22 Interrogatories to All Defendants as follows:
23
PRELIMINARY STATEMENT
24
Defendant's responses are based upon as diligent and
25 complete an inquiry as possible as of this date and are subject 26 to corrections for errors, mistakes or omissions. Defendant
27
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anticipates that additional discovery, investigation, and analysis may supply additional facts, add meaning to known facts,
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INTERROGATORY NO. 2:
State the date of first employment with YOU, and the
dates and titles of each job position the person verifying these interrogatories has held while employed by YOU. RESPONSE TO INTERROGATORY N O . 2 :
Ms- Johnson has been employed at the Martinez facility since 1962. Her current job title is Senior Office Assistant, Human Resources, Legal Support. INTERROGATORY N O . 3 =
10
State whether or not YOU are a corporation, and if so.
11 state:
12
A. YOUR correct corporate name;
13
B. YOUR state of incorporation;
14
C. The date of YOUR incorporation;
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D. The address of YOUR principal place of business;
IS
E. Whether or not YOU have ever held a certificate of
17 authority to do business in the State of California, and if so,
IS the inclusive dates of any certificate;
19
F. If YOU are wholly owned or the majority interest of
20 YOUR company is owned by another business entity, state the
21 entity's name and principal place of business;
22
G. Whether YOU have any business offices in
23 California, and, if so, YOUR principal place of business in
24 California.
25 RESPONSE TO INTERROGATORY NO. 3 .
26
Yes.
21
A. Shell Oil Company.
*8
B . Delaware.
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.
1
C. September 30, 1949.
2
D. One Shell Plasa, 910 Louisiana S t r e e t , Houston,
3 Texas 77002.
4
E. Shell has been certified to do business in the
5 State of California continuously since September 30, 1949.
6
P. SPNV Holdings, Inc., a Delaware corporation.
7
G. Shell does not maintain a principal business office
8 in California. Its address for service of process is CT
9 Corporation System, 818 West Seventh Street, Los Angeles, 10 California 90017. 11 INTERROGATORY MO. 4 :
12
Have YOU ever been identified, known, or done business
13 under any other name in the State of California?
14 RESPONSE TO INTERROGATORY NO. 4 :
15
Yes.
16 INTERROGATORY M O . 5 :
17
if your answer to Interrogatory No. 4 is in the
18 affirmative, please state such name or names and the time period
19 during which THIS DEFENDANT was so known or identified.
2 0 RESPONSE TO INTERROGATORY MO. 5 :
21
Shell Company of California (1912 to 1922); Shell Union
22 Oil Corporation (1922 to 1939); Shell Oil Company, Inc. (1939 to
23 1949).
24 I N T E R R O G A T O R Y N O . fi-
25
26 structure
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If Y O U are not a corporation, what is Y O U R business (partnership, joint venture, sole proprietorship,
4 .
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P .1S
1
L. No.
2
M- No.
3
N. No.
4
O. Yes.
5
P . No.
S
Q- No.
7
R. No.
8
S. No.
9
T. No.
10
U. No.
11
V. Shell and/or its employees have been members of
12 various business groups and associations, but Shell is unable to
13 identify at this time all of the groups and associations that may
14 be relevant to this Interrogatory.
15
(w) Unknown. Shell is aware that certain of its
16 personnel attended conferences and meetings of various
17 organizations in an attempt to learn of potential hazards in the
18 workplace, including its former Industrial Hygienist, Howard
19 Kusnetz, who attended American Petroleum Institute meetings.
20 INTERROGATORY NO. 14-
21
For each organization, association or other entity
22 identified in YOUR Response to Interrogatory No. 13, please
23 state:
24
A. The dates during which THIS DEFENDANT was a member,-
25
B. The name (si) of any publication(s ) received by THIS
26 DEFENDANT from such association or o r g anization;
27 U&Cw'icK,^
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.
1
C.
The name o any committee or subcommittee of w
2 THIS DEPENDANT was a member, and the dates of such committee or
3 subcommittee membership.
4 RESPONSE TO INTERROGATORY N O . 14:
5
A. American Petroleum Institute - approximately 1949
6 (the limit of API's records) to present.
7
National Safety Council - December 1943 to present.
8
Industrial Hygiene Foundation - approximately 1972 to
9 approximately 1977.
10
The dates of Shell's memberships in other organizations
11 listed in response to Interrogatory No. 13 are presently unknown.
12
s. Shell is currently unaware o the title(s) of any
13 publications it may have received from the organizations listed
14 in its response to Interrogatory No. 13. The records of those
15 organizations may contain this information.
IS
C. Shell has been a member of the American Petroleum
17 Institute's Medical Advisory Committee since approximately 1972
18 (the limit of Shell's records). Membership in other committees
19 and/or subcommittees is unknown at this time.
20 INTERROGATORY N O . 1 5 :
21
Had THIS DEFENDANT prior to 1973 received any DOCUMENTS
22 containing results or conclusions of any studies and/or tests
23 conducted by Bonsib for Standard Oil of New Jersey relating to
24 asbestos exposure in the workplace or the human health
25 consequences of exposure to asbestos? if so-.
2 6
27
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A. Either (1) attach all DOCUMENTS evidencing the information sought in this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach diek<; containing
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