Document 8VnkvVXzzN7eYYG1xjXrD9Xmy

FILE NAME: Kaiser Gypsum (KG) DATE: 1996 DOC#: KG046 DOCUMENT DESCRIPTION: Legal - Response to Request for Production g>lA|'fe4 -K 1<-U fT CV*. a ll DILLINGHAM & MURPHY PATRICK J. HAGAN, ESQ. - BAR NO. 68264 2 ELIZABETH B. MORI, ESQ. - BAR NO. 178688 Fourteenth Floor 3 625 Market Street 41 San Francisco, (415) 896-0400 California 94105-3315 5 Attorneys for Defendant KAISER GYPSUM COMPANY, INC. 6 7 8 IN THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF SAN FRANCISCO 10 11 BART DOUGLAS STOCKMAN, 12 Plaintiff, 13 v s . 14 ABEX CORPORATION, et al., 15 Defendants. CASE NO.: 962298 DEFENDANT KAISER GYPSUM COMPANY, INC.'S RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS 16 17 _____________________ ___ ___________ / 18 PROPOUNDING PARTY: PLAINTIFF, BART DOUGLAS STOCKMAN 19 RESPONDING PARTY: DEFENDANT, KAISER GYPSUM COMPANY, INC. 20 SET NO .: ONE 21 GENERAL OBJECTIONS 22 Responding defendant KAISER GYPSUM COMPANY, INC. 23 (hereinafter referred to as "KAISER GYPSUM") hereby objects to 24 plaintiff s Request for Production of Documents, set number one, 25 served by hand on November 22, 1996, on the grounds that said 26 request is irrelevant, overly broad, compound, burdensome, 27 oppressive and harassing and it is not reasonably calculated to 28 - 1- lead to the discovery of admissible evidence. Without waiving 2 these objections, KAISER GYPSUM responds as follows: 3 RESPONSE TO REQUEST NO. 1 : 4 KAISER GYPSUM incorporates its general objections as stated 5 above and specifically objects to this request as vague and 6 ambiguous as well as overly broad in terms of time and products, 7 and as to the meaning of the term "appearance." KAISER GYPSUM 8 further objects to this request as overly broad in that it 9 requests information relating to products to which the plaintiff 10 was never exposed. Without waiving said objections, KAISER 11 GYPSUM responds that it has located the documents attached as 12 Exhibit A which appear responsive to plaintiff's request and 13 which depict both asbestos-containing and non-asbestos-containing 14 products. 15 RESPONSE TO REQUEST NO. 2 : 16 KAISER GYPSUM incorporates its general objections as stated 17 above and specifically objects to said request as vague and 18 ambiguous as well as overly broad in terms of time and products, 19 and as to the meaning of the term "appearance." KAISER GYPSUM 20 further objects to this request as irrelevant and not reasonably 21 calculated to lead to the discovery of admissible evidence in 22 that it requests information regarding non-asbestos-containing 23 products. Without waiving said objections, KAISER GYPSUM 24 responds that it has located the documents attached hereto as 25 Exhibit B which appear responsive to plaintiff's request. In 26 addition, to the extent that any of the documents produced 27 pursuant to Request Number 1 may be responsive to said request, 28 KAISER GYPSUM refers plaintiff to those documents. - 2- KAISER GYPSUM incorporates its general objections as stated above and specifically objects to this request as vague and ambiguous as well as overly broad and unintelligible in that responding defendant cannot identify which documents, if any, might be responsive to said request. KAISER GYPSUM further objects that in the absence of an inquiry more precisely formulated, KAISER GYPSUM cannot respond to this request. Without waiving these objections, KAISER GYPSUM refers plaintiff to those documents produced pursuant to Requests Number 1 and 2 to the extent that they may be responsive to this request. RESPONSE TO REQUEST NO. 4; See Response to Request No. 3. DILLINGHAM & MURPHY By: Attorneys for Defendant KAISER GYPSUM COMPANY, INC.