Document 8V8x5Bj6kaz3rn1kV8O9w6OBy

I 1 (4) 1983 to date: Dennis Egnatz, M.D., 121 Lakewood 2 Circle, Burr Ridge, Illinois 60521. 3 INTERROGATORY NO. 35: 4 Please state the name, address, title and dates of employ 5 ment of the immediate superior(s) of the individuals identified 6 in the preceding interrogatory. 7 RESPONSE: 8 From 1944 to February, 1981, the Medical Director reported 9 to the corporate Vice President of Personn 1 and Industrial Rela 10 tions. From 1981 to the present, the Medi'al Director has re 11 ported to the corporate Vice President of luman Resources. 12 INTERROGATORY NO. 36: 13 Please describe in detail the duties and responsibilities of 14 the defendant's chief medical officer. 15 RESPONSE: 16 The Medical Director directs company-wide employee health 17 and safety programs. He provides guidance to corporate manage 18 ment. The Medical Director's position is administrative and his 19 responsibilities include employee health, safety, industrial 20 hygiene, loss prevention, and employee assistance. He directly 21 supervises a staff of non-medical personnel and functionally 22 supervises occupational health nurses throughout the company. He 23 also approves the appointment of, and coordinates the activities 24 of, independent medical practitioners conducting physical exami 25 nations or providing medical care locally. 26 INTERROGATORY NO. 37: 27 Please state the names and addresses of all physicians em NZO OS 28 ployed, retained or otherwise engaged by the defendant at any of ARO I <6 * -21-