Document 710QbEGY48ooV3o7GQeKeqRYj

CLAYTON H. THOMAS, Jr. BY, IDENTIFICATION NO. 03353 suite 1502 TWO GIRARD PLAZA Philadelphia. Pennsylvania 19102 (215) 569-7070 attorney for Defendant, Abex Corporation _ VERNELL LONDON, Executrix of the Estate of BIRK REED v. NICOLET INDUSTRIES, et al., including ABEX CORPORATION COURT OF COMMOS'PLEAS DIV1SIOS May TERM. 19 8 3 ASBESTOS CASE . No. 6849 (2268) SUPPLEMENTAL ANSWERS OF DEFENDANT, ABEX CORPORATION, TO PLAINTIFF'S INTERROGATORIES Defendant, Abex Corporation, hereby files, by its attorney, Supplemental Answers to Plaintiff's Interrogatories, as follows. 6. Defendant, Abex Corporation, reiterates its objections to this 'Interrogatory as set forth in its original Answer thereto. Abex has no record of selling or shipping any automotive asbestos friction products to any of Plaintiff's employers during the periods identified in the introductory paragraph to Plaintiff's Interrogatories. Abex objects to this Interrogatory as irrelevant, immaterial and not likely to lead to the discovery of admissible evidence. Without waiving this objection, Abex states that it has manufactured, sold and distributed asbestos-containing automotive friction products. (a) The trade names, brand names, logos and trademarks for Abex automotive and truck brake linings include but are not limite to the following: American Brakeblok, Abex, Esline, Stopper, Crossing Guard, 121 Super Brake, Logger, Protector and private labels such as Paccar, Trailmobile, Great Dane and Mack Truck. (b) Abex began producing and marketing automotive brake lining products from about 1926 to the present. (c) Each product is intended to stop a moving vehicle. (d) The composition is of chrysotile asbestos. The cuar titative percentage of asbestos in the products varies from 25% to 655 by weight. The appearance would be in the form of rigid blocks and' strips or in rolls as well as flat sheets. (e) Answering Defendant incorporates by reference hereir its Answer to Interrogatory No. 6(d) above. The products are generall dark gray or black in color. The products have always been sold in a solid form. (f) Friction Products Division, 2410 Papermill Road, Winchester, VA 22601. 18. (a) through (c) Abex has used corrugated cardboard and regular cardboard boxes to package their automotive brake products. These boxes vary in size, color and design. Various types of boxes a: available for inspection at the offices of Clayton H. Thomas, Jr., Esquire, Counsel for Abex Corporation, Suite 1502, Two Mellon Bank Center, Philadelphia, PA 19102, during regular business hours at a mutually convenient time. (d) and (e) From 1972 to the present, Abex has printed conspicuous warnings in boldface black lettering on all boxes and carte containing Abex's asbestos friction products. A copy of said warning is attached hereto and marked Exhibit "A." Abex reserves the right to supplement this Answer at a later date if necessary. r'ljMyfn id tJrmno^ Cvj. CLAYTON H. THOMAS, JR., Attorney for Defendant, Abex Corporation ESQUIRE l i 11 1 1 * ll | "EXHIBIT A" tU Q LI& 'k& ltfi VERIFICATION | CLAYTON H. THOMAS, JR., ESQUIRE, hereby verifies that he is j| counsel for Defendant Abex Corporation; that he is authorized to sign this verification for Abex Corporation since it has no officer present within the jurisdiction; and that the information contained in the fore going Supplemental Answers to Plaintiff's Interrogatories is true and correct to the best of his knowledge, information and belief. This verification is made subject to the Pennsylvania Statute relating to ) sworn statements and falsification to authorities. 18 Pa. C.S. 4904. Date; January 24, 1985 CLAYTON H. THOMAS, JR., ESQUIRE I CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Supplemer. tal Answers of Defendant, Abex Corporation to Plaintiff's Interrogator^ was served on all counsel appearing on the attached list by first-class mail, postage pre-paid, on January 24, 1985. CLAYTON H. TFOMAS, JR., ESQUIRE clavton m Thomas, jR JAMCS WM.TON OALT Law OrriCES CLAYTON H. THOMAS JR. COoN5CuOS AT CAW . *OCTOS IN ADNiPAlT* Suite 1502 Two Girard Plaza PhIi.ADC1.PHIA, PENNSYLVANIA l9'02 January 24 , 1985 :2'5 566-7CTC Robert E. Paul, Esquire 235 S. 17th Street Philadelphia, PA 19103 RE: Vernell London, Exec. v. Nicolet Industries, Inc., et al., including Abex Corporation May Term, 1983, No. 6849 Our File No. AC-244 Dear Mr. Paul: Enclosed please find a copy of Defendant, Abex Corporation' Supplemental Answers to Plaintiff's Interrogatories, the original of which has been filed with the Court. I have received Plaintiff's Motion for Sanctions to compel more specific answers to Plaintiff's Interrogatories. As you have now received Abex's Supplemental Answers, said Motion is rendered moot. I would therefore appreciate your immediately notifying the Clerk of the Motion Court that theseAnswers have been served and that you are therefore withdrawing this Motion as moot. Very truly yours, CLAYTON H. THOMAS, JR., ESQUIRE JWD:eds Enclosure cc: All Counsel