Document 8d0KvGVnXd3yMeRqwV4xRwQo
FILE NAME: Carlisle (CARL)
DATE: 1995
DOC#: CARL070
DOCUMENT DESCRIPTION: Legal - Further Defendant Answers to Plaintiffs' 2nd Set of Interrogatories
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT
CASS COUNTY, ILLINOIS
ROSE SPEARS, As Special Administrator )
for WILLIAM SPEAR, Deceased,
)
)
Plaintiff,
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v.
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A. P. GREEN, et al.,
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Defendants.
)
No.92-L-3
FURTHER SUPPLEMENTAL ANSWERS OF DEFENDANT CARLISLE CORPORATION TO CERTAIN OF PLAINTIFF/S SECOND SET OF INTERROGATORIES Defendant Carlisle Corporation, by its attorneys, provides the following supplemental answers to plaintiff's Second Interrogatories in the above-captioned matter as follows: I . PRELIMINARY STATEMENT These questions or requests are answered with respect to Motion Control, Inc., a subsidiary of Carlisle Corporation. These questions or requests are answered on the basis of informa tion presently known to the person or persons who prepared the answers. Because much of the information which is the subject of these questions or requests is historical in nature, and consid erable time may have passed since the events or dates in ques tion, these answers are subject to the discovery of any addition al information. These answers are intended to be accurate to the best of the answering person's knowledge and belief as of the time of the answer. To the extent that they are not consistent with any previous answers, including answers and discovery in other cases,
these answers are intended to supplement and supersede such
earlier answers. Defendant reserves the right to supplement
these answers. Furthermore, the information contained in these
answers may be superseded by further discovery in this or future
matters.
Unless otherwise stated, this further supplemental response
incorporates all prior answers to discovery by answering
defendant.
II. FURTHER SUPPLEMENTAL ANSWERS TO CERTAIN OF PLAINTIFF'S SECOND INTERROGATORIES
17. Please state whether or not Defendant ever obtained any knowledge concerning the likelihood of asbestos being hazardous to human health. If so, please state:
(a) When Defendant first became aware of the hazardous potential of asbestos dust and asbestos fibers;
(b) The manner In which the Defendant, Defendant's predecessor, or Defendant's subsidiary companies first obtained this knowledge and became aware of said hazards and from what source this Information was obtained.
ANSWER: Unknown at this time.
18. Please state when Defendant first became aware of the possible association between Inhalation of asbestos dust and/or fibers and the contraction of cancers including, but not limited to gastrointestinal cancer, laryngeal cancer, renal cancer, lymphoma and lung cancer. As to each cancer, state the source of that information, including a description of all tests conducted relative to the possibility of such a relationship.
ANSWER: See answer to Interrogatory 17.
19.
Please state when Defendant first became aware of the
possible association between inhalation of asbestos dust and/or
fibers and the contraction of mesothelioma and peritoneal
mesothelioma. State the source of that information including a
description of all tests conducted relative to the possibility of
such a relationship.
ANSWER: See answer to Interrogatory 18
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20.
Please state when Defendant first became aware of the
association between the inhalation of asbestos dust and/or fibers
and contraction of lung disease known as asbestosis and state the
source of that information including a description of all tests
conducted relative to possibility of such a relationship.
ANSWER: See answer to Interrogatory 18.
28. Does Defendant maintain a library dealing with industrial hygiene, medicine, safety and engineering and/or research? If so, state:
(a) The date each such library was established;
(b) The location of each library;
(c) The name(s) of the librarian(s) since 1930;
(d) List all journals subscribed to by you concerning asbestos, industrial hygiene, medicine, safety, and/or engineering;
(e) List all books and articles dealing with asbestos and asbestos-related diseases and the date acquired.
ANSWER: See previous answer. Defendant has no such
library. Robert M. Tami recalls that he has obtained copies of
the following around the time indicated:
(a) Peters, G., et al., Sourcebook on Asbestos Diseases (Garland Publishing, NY 1980). Date of purchase or acquisition unknown.
(b) Rajhans, G., Bragg, G., Engineering Aspects of Asbestos Dust Control (Ann Arbor Science Publishers, 1978). Date of purchase or acquisition unknown.
Dated: April 24, 1995
, r /!
-Roger Pascal Jayant W. Tambe SCHIFF HARDIN & WAITE 7200 Sears Tower Chicago, Illinois 60606 (312) 876-1000 Attorneys for Defendant
Carlisle Corporation
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