Document 9JNZqZJe7oK31QNGb1axn5dy6
NO. 92-10123
CHARLES NORMAN WHITE and PAULINE WHITE; HARVEY LEWIS SHADDOX and MARY SHADDOX; ORVEL WOODROW FITTS and MAVIS FITTS; LEO L. DARDEN and RUTH DARDEN; and DANIEL ALLEN DALTON, SR. and MARITA DALTON,
Plaintiffs,
versus
KEENE CORPORATION, et al.,
Defendants.
IN THE DISTRICT COURT TRAVIS COUNTY, TEXAS 353RD JUDICIAL DISTRICT
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993
TO: Plaintiffs, by and through their counsel of record, Russell W. Budd, Baron & Budd, The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219.
Comes now Westinghouse Electric Corporation ("Westinghouse"), by and through its
attorneys of record, and files these First Amended Objections and Responses to Plaintiffs'
Interrogatories Mailed to Defendant on or about April 21, 1993.
Preliminary Statement and General Objections
Westinghouse has a history of cooperation with plaintiffs' counsel, Baron & Budd, and has produced substantial discovery consisting of documents, witnesses and answers to interrogatories. The current interrogatories request verification of the authenticity of certain documents which presumably were previously produced by Westinghouse to Plaintiffs along with literally thousands of other documents. However, many of these documents were not prepared by Westinghouse and Westinghouse cannot attest to their authenticity. Specifically,
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 1
Westinghouse lacks the first hand knowledge necessary to determine whether each of these documents is genuine and authentic. Likewise, the origin of many documents cannot be confirmed as Westinghouse documents because Plaintiffs have supplied copies which do not carry a readable bates number. Furthermore, many of the documents themselves are illegible. Finally, many documents on their face appear to be Westinghouse documents but contain other information either typed or hand written which would not have been found on the original document. Again, without knowing the source of the document or at least the source of this extraneous information, Westinghouse cannot attest to the documents authenticity. In essence, Plaintiffs have failed to provide sufficient information for Westinghouse to provide accurate and meaningful responses.
Westinghouse's responses to these Interrogatories are made without in any way waiving: (1) the right to object, on the grounds of competency, relevancy, materiality, hearsay or any other proper grounds, to the use of any such information for any purpose, in whole or in part, in any subsequent stage or proceeding in this action or any other action; or (2) the right to object on any and all grounds, at any time, to any other discovery procedure relating to the subject matter of these Interrogatories.
Without waiving these objections and subject thereto Westinghouse further responds to . the Interrogatories as follows:
INTERROGATORIES
INTERROGATORY NO. 1: For each document listed below, please answer whether
such document is a true and correct duplicate of a genuine and authentic document:
ANSWER: See general objection and objections and responses to Interrogatory Nos. 2
and 3 below. Subject to these objections, these documents appear to be copies of materials
provided by Westinghouse to Plaintiffs in various cases.
INTERROGATORY NO. 2: For each document listed below, please answer whether
such document was kept and/or generated in the regular course of a regularly conducted business
activity of any Westinghouse Entity by an employee or representative of any Westinghouse
Entity with knowledge of the act, event, condition or opinion recorded.
WESTINGHOIJSF. ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 2
ANSWER: See general objection and response to Interrogatory No. 1. The attached
documents appear to have been produced to Plaintiffs' counsel by Westinghouse. However,
because hundreds of thousands of pages of documents have been made available to Plaintiffs
from a large variety of sources within Westinghouse, Westinghouse is unable to determine
whether all the materials were maintained in the regular course of regularly conducted business
activity. Therefore, Westinghouse cannot attest that all these documents were "kept and/or
generated in the regular course of a regularly conducted business activity of any Westinghouse
entity by an employee or representative of any Westinghouse entity with knowledge of the act,
event, condition or opinion recorded." The foregoing is also true with respect to any document
produced by Westinghouse which was generated by some source outside the corporation.
Subject to the foregoing objections and without waiving same see individual responses below.
EXHIBIT NO.
DESCRIPTION
a) WH-55
Westinghouse Electric & Manufacturing Company, Purchasing Department specification No. 7305-A. Blanket Insulation over 850 F., Approved December 20, 1934, Revised, February 5, 1934. Bates Nos. 000874-000875.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
b) WH-57
Materials File Card No. 8407. Re: Cement, Heat Insulating (Plastic Insulations). June 5, 1946. Westinghouse Standards Department. Bates No. 000672.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MATTED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 3
c) WH-93 _ Materials File Card (2 pages).
No. 46601AA thru AC. Re: Heat
Insulating Block, High Temperature. April 5, 1969. Westinghouse
Standards Department. Bates No. 000908.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
d) WH-326
Document titled "Sample Sheets 1951" with attachment.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
e) WH-327
Document titled "Sample Sheets 1952"
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
f) WH-333
Document titled "Legal Guidelines for Business Writing" with attached "Terms & Definitions Commonly Used"
ANSWER: Appears to be a document generated by Westinghouse.
g) WH-337
Document titled "Table I, Evaluation of Asbestos Exposure Results of Air Samples"
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
h) WH-338
Memo dated March 27, from Wesley E. Piros, to IN Transportation & Generator, Harry Mower, Safety Engineer.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
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i) WH-339
Photocopy of products used on turbine: Insulation, Flange Cover Insulation, Crossover Pipe Moulded Insulation and Block Insulation.
ANSWER: Source of this document is currently unknown.
j) WH-340
The Saranac Laboratory for the Study of Tuberculosis of the Edward L. Trudeau Foundation letter dated January 31, 1936 from Leroy U. Gardner, M.D., Director to E. C. Barnes, Westinghouse Electric Company.
ANSWER: This is not a Westinghouse generated document.
k) WH-341
Letter dated December 23, 1936 from Susy Schu... to Mr. Barnes, Westinghouse Company.
ANSWER: This is not a Westinghouse generated document.
1) WH-342
Report titled "Intraperitoneal Reactions caused by Dusts, G20, G21 and G22. Preliminary Report" submitted by Susy Schu... (injection September 23, 1936)
ANSWER: This is not a Westinghouse generated document.
m) WH-345
Statement of Claim, Home v. Westinghouse Electric and Manufacturing Company. Court of Common Pleas of Allegheny County, Pennsylvania, August 1937.
ANSWER: This is not a Westinghouse generated document.
n) WH-346
Pittsburgh Plate Glass Company letter dated September 16,1938 from F. R. Holden, Ph.D. Industrial Hygienist to E. Barnes, Westinghouse Electric and Manufacturing Co.
ANSWER: This is not a Westinghouse generated document.
o) WH-347
Memorandum dated January 11, 1946 from E. C. Barnes, Headquarters Medical Department to South Philadelphia Works.
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 5
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
p) WH-348
Memorandum dated April 20, 1948 from E. C. Barnes to 3-B-42 Trans. & Generator Div., Mr. Paul Edelman.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
q) WH-349
Memorandum dated May 14, 1948 from E. C. Barnes to Sharon Works, R. L. Miller.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
r) WH-350
Memorandum dated June 11, 1954 from N. Wilbur Speicher, to South Philadelphia Works, W. E. McKeldin.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
s) WH-351
Memo dated July 24, 1957 from H. Wilbur Speicher to James McClimans; re: Report of Plant Visit.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
t) WH-353
Westinghouse memo dated April 16, 1958 from C. F. Ehalt to Office Methods Representatives, Manager of East Pittsburgh Accounting; subject: Revision of Procedure for Preservation and Destruction of Records - East Pittsburgh Departments.
ANSWER: Appears to be a document generated by Westinghouse.
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 6
u) WH-357_ Letter dated October 15, 1971 from Pete Rotelli to Hon. George Guenther, OSHA.
ANSWER: This is not a Westinghouse generated document.
v) WH-358
Owens-Coming Fiberglas letter dated March 1, 1972 from Gerald E. Devitt to H. W. Speicher.
ANSWER: This is not a Westinghouse generated document.
w) WH-360
Handwritten note concerning Asbestos Cloth with date 8/7/72 and name of Bill Lane.
ANSWER: Appears to be a document generated by Westinghouse.
x) WH-363
Memorandum dated August 28, 1972 from Zella R. Rees to South Philadelphia Works, W. C. Lane.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
y) WH-366
Memorandum dated January 29, 1973 from H. Wilbur Speicher to East Pittsburgh, W. G. Craig.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
z) WH-367
Memorandum dated February 7, 1973 from R. L. Bergquist to East Pittsburgh Works, W. G. Craig, re: Use of Asbestos Material in Soldering Operations.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 7
aa) WH-369-
Memorandum dated February 16, 1973 from H. Wilbur Speicher to East Pittsburgh, W. G. Craig.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
bb) WH-370
Memorandum dated March 19, 1973 from E. J. Hlavaty to D. L. Collier; re: E-4 & 5 Operations involving Asbestos Materials.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
cc) WH-372
Memorandum dated April 16, 1973 from R. L. Bergquist to East Pittsburgh Works 4N5, W. G. Craig; re: Use of Asbestos Material in Soldering Operations P. G. & E. Diablo Canyon #1.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
dd) WH-373
Memorandum dated April 24, 1973 from John F. Adams to East Pittsburgh Works, E. J. Hlavaty; re: Results of Air Samples Taken for Airborne Asbestos Fibers in Section E-5, LRA, East Pittsburgh Works, with attachment.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
ee) WH-374
Memorandum dated May IS, 1973 from John F. Adams to East PGH., F General Office, B. J. Pleunik.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MATT,ED TO
DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 8
ff) WH-379_ Memorandum dated April 18, 1974 from R. A. Gerbrands to East Pittsburgh - Room 2G46, H. W. Speicher; re: Asbestos Blanket, with handwritten notation.
ANSWER: Appears to be a document generated by Westinghouse.
gg) WH-382
Document entitled Excerpt from "Technological Feasibility and Economic Impact of OSHA Proposed Revision to the Asbestos Standard" prepared by WESTON Environmental Consultants", re: regulation proposed on October 9, 1975.
ANSWER: This is not a Westinghouse generated document.
hh) WH-383
Article titled "The Asbestos Exposure of Insulation Workmen", Insulation Hygiene Progress Reports, by Irving J. Selikoff, M.D., Vol. 6, No. 1, Spring 1975.
ANSWER: This is not a Westinghouse generated document.
ii) WH-384
Memorandum dated January 8, 1975 from Zella R. Heasley to R&D Center - 401-3X9, A. Zervins.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
jj) WH-385
Memorandum dated June 10, 1975 from Dick Wolf to R. C. Boyd, PCB Division.
ANSWER:
Appears to be a document generated by Westinghouse. Also, this document appears to be kept or generated in the regular course of Westinghouse's regularly conducted business activity.
kk) WH-393
South Carolina Department of Labor Citation and Notification of Proposed Penalty dated January 12, 1976; re: Westinghouse Electric Corporation Micarta Division.
ANSWER: This is not a Westinghouse generated document.
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 9
INTERROGATORY NO. 3: For each document listed below, please answer whether such document was found in your files in such a condition as to create no suspicion concerning its authenticity.
ANSWER: See general objections and response to Interrogatory Nos. 1 and 2 above. Except as noted below, each of these documents appears in the condition as found in Westinghouse files and in a condition as to create no suspicion.
EXHIBIT NO.
DESCRIPTION
b) WH-57
Materials File Card No. 8407. Re: Cement, Heat Insulating (Plastic Insulations). June 5, 1946. Westinghouse standards Department. Bates No. 000672.
ANSWER:
This document contains unidentified extraneous information. However, except for this extraneous information, the document appears in a condition as to create no suspicion concerning its authenticity.
d) WH-326
Document titled "Sample Sheets 1951" with attachment.
ANSWER:
This document contains unidentified extraneous information. However, except for this extraneous information, the document appears in a condition as to create no suspicion concerning its authenticity.
f) WH-333
Document titled "Legal Guidelines for Business Writing" with attached "Terms & Definitions Commonly Used"
ANSWER: This document contains unidentified extraneous information.
i) WH-339
Photocopy of products used on turbine: Insulation, Flange Cover Insulation, Crossover Pipe Moulded Insulation and Block Insulation.
ANSWER:
This document contains unidentified extraneous information. However, except for this extraneous information, the document appears in a condition as to create no suspicion concerning its authenticity.
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 10
j) WH-340
The Saranac Laboratory for the Study of Tuberculosis of the Edward L. Tmdeau Foundation letter dated January 31, 1936 from Leroy U. Gardner, M.D., Director to E. C. Barnes, Westinghouse Electric Company.
ANSWER:
Because this document was not generated by Westinghouse, Westinghouse can provide little information regarding its authenticity. However, the document as provided appears in a condition as to create no suspicion concerning its authenticity.
k) WH-341
Letter dated December 23, 1936 from Susy Schu... to Mr. Barnes, Westinghouse Company.
ANSWER:
Because this document was not generated by Westinghouse, Westinghouse can provide little information regarding its authenticity. However, the document as provided appears in a condition as to create no suspicion concerning its authenticity.
1) WH-342 Report titled "Intraperitoneal Reactions caused by Dusts, G20, G21 and G22. Preliminary Report submitted by Susy Schu...
ANSWER:
Because this document is not a Westinghouse generated document, Westinghouse is uncertain as to whether this is a complete document and can provide little information regarding its authenticity. However the document as provided appears in a condition as to create no suspicion concerning its authenticity.
m) WH-345
Statement of Claim, Homa v. Westinghouse Electric and Manufacturing Company. Court of Common Pleas of Allegheny County, Pennsylvania, August 1937.
ANSWER:
Not only does this document contain unidentified extraneous information but also it was not generated by Westinghouse and Westinghouse can provide little information regarding its authenticity. Westinghouse is unaware of the basis of this unsubstantiated claim and whether the documents contained herein are a complete copy of the claim. However, the document as provided appears in a condition as to create no suspicion concerning its authenticity.
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 11
n) WH-346, Pittsburgh Plate Glass Company letter dated September 16, 1938 from F. R. Holden, Ph.D. Industrial Hygienist to E. Barnes, Westinghouse Electric and Manufacturing Co.
ANSWER:
Not only does this document contain unidentified extraneous information but also this document was not generated by Westinghouse and Westinghouse can provide little information regarding its authenticity.
t) WH-353
Westinghouse memo dated April 16, 1958 from C. F. Ehalt to Office Methods Representatives, Manager of East Pittsburgh Accounting; subject: Revision of Procedure for Preservation and Destruction of Records - East Pittsburgh Departments.
ANSWER: This document contains unidentified extraneous information.
u) WH-357
Letter dated October 15, 1971 from Pete Rotelli to Hon. George Guenther, OSHA.
ANSWER:
Not only does this document contain unidentified extraneous information but also is a non-Westinghouse generated document and Westinghouse can provide little information regarding its authenticity. However, the document as provided appears in a condition as to create no suspicion concerning its authenticity.
v) WH-358
Owens-Coming Fiberglas letter dated March I, 1972 from Gerald E. Devitt to H. W. Speicher.
ANSWER:
Not only does this document contain unidentified extraneous information but also is a non-Westinghouse generated document and Westinghouse can provide little information regarding its authenticity. However, except for this extraneous information, the document appears in a condition as to create no suspicion concerning its authenticity.
w) WH-360
Handwritten note concerning Asbestos Cloth with date 8/7/72 and name of Bill Lane.
ANSWER: This document contains unidentified extraneous information.
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 12
x) WH-363_ Memorandum dated August 28, 1972 from Zella R. Rees to South Philadelphia Works, W. C. Lane.
ANSWER:
This document contains unidentified extraneous information. However, except for this extraneous information, the document appears in a condition as to create no suspicion concerning its authenticity.
z) WH-367
Memorandum dated February 7, 1973 from R. L. Bergquist to East Pittsburgh Works, W. G. Craig, re: Use of Asbestos Material in Soldering Operations.
ANSWER:
This document contains unidentified extraneous information. However, except for this extraneous information, the document appears in a condition as to create no suspicion concerning its authenticity.
bb) WH-370
Memorandum dated March 19, 1973 from E. J. Hlavaty to D. L. Collier; re: E-4 & 5 Operations involving Asbestos Materials.
ANSWER:
This document contains unidentified extraneous information. However, except for this extraneous information, the document appears in a condition as to create no suspicion concerning its authenticity.
cc) WH-372
Memorandum dated April 16, 1973 from R. L. Bergquist to East Pittsburgh Works 4N5, W. G. Craig; re: Use of Asbestos Material in Soldering Operations P. G. & E. Diablo Canyon #1.
ANSWER:
This document contains unidentified extraneous information. However, except for this extraneous information, the document appears in a condition as to create no suspicion concerning its authenticity.
ff) WH-379
Memorandum dated April 18, 1974 from R. A. Gerbrands to East Pittsburgh - Room 2G46, H. W. Speicher; re: Asbestos Blanket, with handwritten notation.
ANSWER: This document contains unidentified extraneous information.
gg) WH-382
Document entitled Excerpt from "Technological Feasibility and Economic Impact of OSHA Proposed Revision to the Asbestos Standard" prepared
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORTFS MAILED TO
DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 13
by WESTON Environmental Consultants", re: regulation proposed on October 9, 1975.
ANSWER:
Because this document was not generated by Westinghouse, Westinghouse can provide little information regarding its authenticity. However, the document as provided appears in a condition as to create no suspicion concerning its authenticity.
hh) WH-383
Article titled "The Asbestos Exposure of Insulation Workmen", Insulation Hygiene Progress Reports, by Irving J. Selikoff, M.D., Vol. 6, No. 1, Spring 1975.
ANSWER:
Because this document was not generated by Westinghouse, Westinghouse can provide little information regarding its authenticity. However, the document as provided appears in a condition as to create no suspicion concerning its authenticity.
ii) WH-384
Memorandum dated January 8, 1975 from Zella R. Heasley to R&D Center - 401-3X9, A. Zervins.
ANSWER:
This document contains unidentified extraneous information. However, except for this extraneous information, the document appears in a condition as to create no suspicion concerning its authenticity.
kk) WH-393
South Carolina Department of Labor Citation and Notification of Proposed Penalty dated January 12, 1976; re: Westinghouse Electric Corporation Micarta Division.
ANSWER:
Not only does this document contain extraneous information but also this is not a Westinghouse generated document and Westinghouse can provide little information regarding its authenticity. Furthermore, Westinghouse does not know the basis for the complaint herein or whether this document is complete. However, the document as provided appears in a condition as to create no suspicion concerning its authenticity.
Ds i EkROGATORY NO. 4: Has Westinghouse stipulated or agreed to the authenticity
of any of the documents referenced in Interrogatory No. 1 with any person prior to the date of
these Interrogatories?
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 14
ANSWER: Westinghouse is not aware of any stipulation to the authenticity of any of the documents referred to in Interrogatory No. 1 except to the extent Westinghouse may have stated that the documents were provided by Westinghouse via document production in various cases.
Respectfully submitted, VIAL, HAMILTON, KOCH & KNOX 1717 Main Street Suite 4400 Dallas, Texas 75201-4605 (214) 712-4400 FAX (214) 712-4402
MARK A. HENDRIX State Bar No. 09460500 ROBERT E. THACKSTON State Bar No. 00785487 B. SCOTT TILLEY State Bar No. 20032700 McGUIRE, WOODS, BATTLE &
BOOTHE One James Center Richmond, Virginia 23219 (804) 775-1000 ATTORNEYS FOR WESTINGHOUSE ELECTRIC CORPORATION
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page IS
CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Westinghouse Electric Corporation's First Amended Objections and Responses to Plaintiffs' Interrogatories mailed to Defendant on or about April 21, 1993 have been forwarded to counsel for Plaintiffs via hand delivery, and to all other known counsel of record via U.S. Mail, regular delivery, on this the 4th day of October, 1993.
I:\INS\CJH\DISC\149630.1
Mark A. Hendrix ATTORNEYS FOR DEFENDANT
WESTINGHOUSE ELECTRIC CORPORATION'S FIRST AMENDED OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 18