Document 85zgoga1dYkJ8YZno3R813nda
IN THE CIRCUIT COURT OF THE r ELEVENTH JUDICIAL CIRCUIT IN
AND FOR DADE COUNTY, FLORIDA
CASE NO.: 84-45245 CA 42
MICHAEL SCAvELLA, Personal Representative of the Estate and Survivors of
EL3RIDGE SCAVELLA, Deceased,
FLORIDA BAR NO. 046600
(
Plaintiff,
vs. .
ARMSTRONG WORLD INDUSTRIES, INC., et al.,
Defendants.
/
NOTICE CF -SERVICE OF ANSWER TQ_ INTERROGATORIES
COMES NOW Defendant, GEORGIA-PACIFIC CORPORATION, by
and through its undersigned attorneys and files this its Notice
of Service of Answer to Plaintiff's Interrogatory number 13.
I HEREBY CERTIFY that a true and correct copy of the
foregoing was mailed this
day of October, 1987 to all
counsel of record on the attached Service List.
"
.
SHUTIS & BOWEN Attorneys for Georgia Pacific 100 Chopin Plaza - Miami Center 1500 Edward Ball Building Miami, Florida 33131 <305)358-6300
013 6N
By:. RICHARD M. LESLIE, P.A.
13. If the answer to one or more of the last five i
questions is in the affirmative, please state as to #ach affirmative answer the following:
(a) The name of the Company manufacturing, mining, marketing, distributing or selling such products.
(b) The trade or brand name of each such product mined, manufactured, distributed, marketed or sold during the period 1935 to present. .
(c) The date each of such products was placed on the market.
(d) The date each of such products was withdrawn from the market.
(e) A description of the physical (the chemical) composition of each such product including the type of asbestos contained in each such product (e.g., amosite, chrysotile, or crocidolite) and the quantative percentage of asbestos in each product.
' (f-) A description of the physical appearance of each such product.
(9) A detailed description of the intended use of each such product.
(h) The name of the manufacturer of each such product. ANSWER: Part 1; - products manufactured by Georgia-Pacific Corporation or Bestwall Gypsum Company. All Purpose Joint Compound
J (a) Georgia-Pacific Corporation.
(b) All Purpose Joint Compound. (c) Approximately 1967. (d) Still available. Asbestos-free formulation introduced in 1974.
(e) Chrysotile; approximately 4.5%
(O White to off-white; dry.
(
(g) The product was designed to conceal and reinforce
the joints between sheets of gypsum wallboard in order to
provide a smooth and monolithic surface.
(h) Georgia-Pacific Corporation.
(a) Bestvall Gypsum Company, Georgia-Pacific Corporation. .
(b) Bedding Compound. (C) 1556. (d) Still available. Asbestos-free formulation introduced in 1974. (e) Chrysotile; approximately 3.0% to 7.0%. (f) White to off-white; dry. (g) The product was designed to conceal and reinforce the joints between sheets of gypsum wallboard in order to provide a smooth and monolithic surface. (h) Bestwall Gypsum Company, Georgia-Pacific Corporation.-
gfintcal -Mil-(> Georgia-Pacific Corporation. (b> Central Mix. (c) Approximately 1970. Approximately 1973. (e) Chrysotile; approximately 3.0% to 6.,0%. (f> White to off-white; dry. (9) The product was designed to conceal and reinforce
the joints between sheets of gypsum wall-board in order to provide a smooth and monolithic surface.
, (h) Georgia-Pacific Corporation.
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(a) Georgia-Pacific Corporation. (b) Drywall Adhesive. (c) Approximately 1972.
(d) Approximate 1972.
(e) Chrysotile; approximate O.B*. <f) White to off-white; dry.
(g) The product was designed to be used to attach wallboard to wood studs.
(h) Georgia-Pacific Corporation. Joint Compound;
(a) Corporation.
Bestwall Gypsum Company, Georgia-Pacific .
(b) Joint Compound.
Cc) 1956.
(d) Still available. Asbestos-free formulation
introduced in 1974.
'
(e) Chrysotile; approximately 2.5* to 6.0*.
(f) white to off-white, dry.
(?) The product was designed to conceal and reinforce
the joints between sheets of gypsum wallboard in order to
provide a smooth and monolithic surface.
(h) Bestwall Gypsum Company, Georgia-Pacific
Corporation.
Kalite:
<a> ;w
Bestwall Gypsum Company. Kalite.
(c) 1956.
(d) Approximately 1959.
(e) Chrysotile; approximately 2.6*.
(f) Gray and white to off-white; dry. (9) The product was designed as a ceiling finishing material with noise reduction properties.
(h) Bestwall Gypsum Company.
Laminating Compound - Ready Mix:
(a) ' Georgia-Pacific Corporation.
(b) Laminating Compound - Ready Mix.
(c) Approximately 1969. (d) Approximately 1969.
(e) Chrysotile; approximately 4.0%.
(f) White to off-white; paste.
(g) The product was designed to conceal and reinforce
the joints between sheets of gypsum wallboard in order to
provide a smooth and monolithic surface.
(h> Georgia-Pacific Corporation.
Lite Acoustic!
(a) Bestwall Gypsum Company.
(b) Lite Acoustic.
(c) Approximately 1953.
(d) Approximately 1964.
(e) Chrysotile; approximately 25% to 29.09%.
(f) White to off-white; dry.
' (g) The product was designed as ceiling finishing
material with noise reduction properties.
(h) Bestwall Gypsum Company.
PatcSlpg Plaster: (a) Bestwall Gypsum Company, Georgia-Pacific
Corporation.
(b) Patching Plaster.
(c) Approximately 1956.
(d) Still available. Asbestos-free formulation
introduced7in 1976.
(e> Chrysotile; approximately 2.0%.
(f) White to off-white; dry.
(g) The product was designed to patch wallboard.
() Bestwall Gypsum Company, Georgia-Pacific
Corporation.
Rfcady.Mi*: (a) Bestwall Gypsum Company, Georgia-Pacific
Corporation.
(b) -Ready Mix.
(c) Approximately 1963.
(d) Still available. introduced in 1976.
Asbestos-free formulation
(e) Chrysotile; approximately 1.5% to 12.0%. (f) white to off-white; paste.
(9) The product was designed to conceal and reinforce the joints between sheets of gypsum wallboard in order to
provide a smooth and monolithic surface.
(h) Bestwall Gypsum Company, Georgia-Pacific Corporation.
(a) Corporation.
Bestwall Gypsum Company, Georgia-Pacific
(b) Spackling Compound.
<c> Approximately 1956.
(d) Approximately 1970 or 1971.
(e) Chrysotile? approximately 5.5% (} White to off-white? dry.
(g) The product was designed to be used to fill small
holes and creeks in wallboard.
(h) Bestwall Gypsum Company, Georgia-Pacific
Corporation.
.
Speed Set:
(a) Bestwall Gypsum Company, Georgia-Pacific
Corporation.
(b) Speed Set.
<e) Approximately 1962.
(d) Still available. Asbestos-free formulation
introduced in 1974.
(e) Chrysotile? approximately 2.75% to 6.75%.
(f) White to off-white; dry.
(g) The product was designed to conceal and reinforce
the joints between sheets of gypsum wallboard in order to
provide a smooth and monolithic surface.
(h) Bestwall Gypsum! Company, Georgia-Pacific
Corporation. Texture: I
I
(a) Corporation.
Bestwall Gypsum Company, Georgia-Pacific
(b) Ceiling Texture, Wall Texture, Certex Texture, Bestex 1, Bestex 2, Bestex A, Bestex S, Bestex c, Bestex D, Ceiling Texture - Perlite, Ceiling Texture Polystyrene and Ceiling Texture - Vermiculite.
(C) 1956.
(d) Still available. introduced in 1974.
Asbestbs-free formulation
(e) Chrysotile; approximately 2.0% to 22.5%. (f) White to off-white; dry.
(g) The product was designed to provide a decorative finish to walls and ceilings.
(h) Bestwall Gypsum Company, Georgia-Pacific
Corporation.
.
TQPring_.Comp.Qund:
(a) Bestwall Gypsum Company, Georgia-Pacific
Corporation. (1>) Topping Compound.
(c> 1956.
(d) Still available. Asbestos-free formulation
introduced in 1974.
(e) Chrysotile; approximately 3.0% to 7.0%.
J`) White to off-white; dry.
. (g) The product was designed to provide a decorative
finish to walls and ceilings.
(h) Bestwall Gypsum Company, Georgia-Pacific
Corporation.
Triple Duty Joint Compound:
(a) Bestwall Gypsum Company, Georgia-Pacific
Corporation.
(b) Triple Duty Joint Compound.
(c) Approximately 1965.
(d) Still available.. Asbestos-free formulation
introduced in 1974.
.
(e) Qhrysotile; approximately 2.5% to 7.0%. (f) White to off-white; dry.
(g) The product was designed to conceal and reir.fc rce the joints between sheets of gypsum wallboard in order to provide a smooth and monolithic surface.
(h) Bestwall Gypsum Company, Ceorgia-Pacific
Corporation.
'
Part 2 - Products sold by Bestwall Gypsum Company that were manufactured by other companies.
None
.
Part 3 - Products sold by Georgia-Pacific that were
manufactured by other companies.
.
Georgia-Pacific Corporation has, from time to time, sold a
limited number of asbestos containing products through its
Distribution Division that were manufactured by other
companies. The product types were limited to conventional
building products, and did not include commercial or industrial
products such as industrial insulation products, fireproofing,
asbestos cloth, or raw asbestos. Georgia-Pacific Corporation
has maintained a large number of Distribution Centers for many
years (there are currently 148 such Centers), and discretion
for sales of non-G-P manufactured products has been retained at
the level of the individual Distribution Center Manager. There
are no centrally located records regarding sales of non-G-P
manufactured products. The only records available are the
/ sales records located at the individual branches. Those
records consist principally of large volumes of sales invoices,
for the most part organised chronologically by customer name.
After making reasonable inquiry, counsel represents that
the only non-G-P manufactured asbestos-containing products sold
through its distribution centers were as follows:
(a) Asbestos-cement board, manufactured by Johns-Manville
Corporation, was sold out of one distribution center, not
:ated in or near the state cf Florida.
(b) Asphalt based roof cements and roof coatings containing asbestos, from various manufacturers, were sold at a
'. number o distribution centers, including some sales in sputh Florida. Sales of these products began in approximately 1975.
(c) Asbestos siding, manufactured by Superdur Corporation, was sold out of one distribution center, not located in or near the state of Florida.
Records at the various distribution centers are extremely voluminous, and they are not segregated by product type, and therefore they have not been reviewed. It is unknown at present how complete the records are, but all records at locations relevant to this litigation will be made available to Plaintiffs' counsel upon reasonable notification.
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