Document BRzRzLqo6daDLKo4GNXGLaMvX

1 McCUTCHEN, DOYLE, BROWN & ENERSEN WILLIAM H. ARMSTRONG 2 WARREN E. GEORGE STUART C. WALKER 3 Three Embarcadero Center San Francisco, California 94111 4 Telephone: (415) 393-2000 5 Attorneys for Defendant GAP Corporation 6 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO 10 11 ESMAEL P. VELASQUEZ, 12 Plaintiff, No. 681-172 13 v. 14 FIBREBOARD PAPER PRODUCTS CORPORATION, et al., 15 Defendants. 16 _______________________________________ RESPONSES TO PLAINTIFF'S SECOND SET OF INTERROGATORIES TO DEFENDANTS 17 18 Defendant, GAF CORPORATION, ("GAF") responds to 19 plaintiff's second set of interrogatories as follows: 20 INTERROGATORY NO. 1: 21 Did you ever at any time give instructions to 22 workers who would use or apply the insulation products 23 manufactured or distributed by your company cf the correct 24 and safe method of applying your insulation? If so, describe 25 such instructions, to whom they were given, and the dates they 26 were given. t 1 ANSWER: 2 See GAF's Answer to Interrogatories B(3)(c) and (d) 3 of plaintiff's first set of interrogatories filed April 24, 4 1975 in Velasquez v. Fibreboard, et al., No. 681-172 (hereinafter 5 "plaintiff's first interrogatories - Velasquez"). 6 INTERROGATORY NO. 2: 7 What studies have you made to determine the effect 8 of your products containing asbestos on the lungs and physical 9 condition of persons employed as insulators and asbestos 10 workers who use your products? 11 ANSWER: 12 None. 13 INTERROGATORY NO. 3: 14 Please state who made such studies and when were they 15 made. Attach copies of the reports of such studies. In answer16 ing this question, fully describe any studies made beginning 17 with the year 1940 to the date of your answers. 18 ANSWER: 19 See Answer to Interrogatory No. 2. 20 INTERROGATORY NO. 4: 21 Did you package, sell or distribute any products con22 taining asbestos from the years 1940 to the present date? If so 23 how were the products sold, packaged and distributed. Were 24 these products universally used through the United States? 25 ANSWER: 26 See GAF's response to Interrogatories B(2) and 2. > 1 B(3)(a) of plaintiff's first interrogatories - Velasquez as 2 well as the letters of Stuart C. Walker to J. Kenneth Lynch 3 dated December 5, 1975 and February 4, 1976. GAF objects to 4 the final sentence of Interrogatory No. 4 on the ground that the 5 information requested is not relevant to the subject matter of 6 this action nor reasonably calculated to lead to the discovery 7 of admissible evidence. Further, GAF objects to the use of the 8 term "universally" as being so vague and ambiguous that GAF 9 cannot frame a meaningful response thereto. 10 INTERROGATORY NO. 5: 11 If these products were used primarily in any specific 12 location or area, please explain where such products were pri13 marily used. 14 ANSWER: 15 GAF objects to this interrogatory on thegrounds that 16 the information requested is not relevant to the subject mat17 ter of this action nor reasonably calculated to lead to the 18 discovery of admissible evidence. See/ however, answer to 19 Interrogatory No. 4, above, and letter of February 4, 1976, 20 from Stuart C. Walker to J. Kenneth Lynch supplementing GAF's 21 answers to plaintiff's first interrogatories - Velasquez. 22 INTERROGATORY NO. 6: 23 Do you recognize that prolongeduse of theinsulating 24 materials containing asbestos manufactured or distributed by 25 /// 26 /// i 3. 1 you can cause or contribute to cause various occupational 2 diseases, including asbestosis, silicosis, dermatitis and 3 mesothelioma? 4 ANSWER: 5 GAF objects to this interrogatory on the ground 6 that it is argumentative, improperly calls for expert opinion. 7 and that the terms "recognize" and "prolonged use" are so 8 vague and ambiguous that GAF cannot frame- a meaningful response 9 to the interrogatory. See, however, GAF's Answer to Inter10 rogatory B(3)(c) of plaintiff's first interrogatories - Velasquez 11 INTERROGATORY NO. 7: 12 Has your company done any studies or has your company 13 conducted any studies concerning the effects of inhalation of 14 asbestos dust or fibers by one using or being exposed to any of 15 the asbestos materials manufactured or distributed by your 16 company? In answer to this question, please give the date and 17 nature of your studies, if any; the name or names of the persons 18 conducting the studies and their address; what the purpose of 19 the studies were; and attach a copy of any report based upon 20 such studies, showing to whom such report was given and when. 21 ANSWER: 22 See Answers to Interrogatories 2 and 3, above. 23 INTERROGATORY NO. 8: 24 Have you or any of your employees ever conducted 25 studies designed to minimize or eliminate the inhalation 26 of asbestos dust and fibers by those exposed to your company's ftSi. - 4. 1 products during installation or tearing out thereof? If so, 2 give the name or names of such persons conducting such studies, 3 attach copies of such studies, by whom they were made, and to 4 whom they were given, and when, and state what action, if any, 5 was taken based upon such studies in an effort to minimize or 6 eliminate the effects of inhalation of asbestos dust or fibers 7 . upon those using or being exposed to the dust and fibers 8 contained in such products as manufactured or distributed by 9 your company. 10 ANSWER: 11 See Answers to Interrogatories 2 and 3, above. 12 INTERROGATORY NO. 9: 13 Do you or your company have any regular inspection of 14 areas where workers are applying or installing products manufac 15 tured by your company containing asbestos as to the dust count? 16 If you do not, then please explain why this is not done; and if 17 you do, please explain what action, if any, is taken by your 18 company following the taking of dust counts at any of the loca 19 tions referred to above. Please give the dates, if any, that 20 your company first started making dust counts. 21 ANSWER: 22 GAF does not presently manufacture thermal industrial 23 insulation products containing asbestos fibers. See answer 24 to interrogatory H of plaintiff's first interrogatories - Velasquez. 25 The letter of February 4, 1976 from Stuart C. Walker to J. Kenneth 26 Lynch, supplementing GAF's answers to plaintiff's first inter- 5. 1 rogatories - Velasquez indicates that GAF has not sold insulation 2 products containing asbestos to distributors or jobbers in 3 California during the period of time relevant to this action. 4 Accordingly, GAF had no access to job sites or job site 5 workers and no control over job site conditions known only to, 6 and capable of being affected only by, insulation contractors, 7 their employers, or unions. Any actions required properly to 8 prepare, use and apply insulation materials and to ensure a 9 proper working environment for individuals necessarily exposed 10 to asbestos containing products in the course of their 11 employment was thus within the sole control and responsibility 12 of such contractors, their employees or unions. 13 GAF objects to this interrogatory insofar as it-seeks 14 information regarding GAF's inspection procedures with respect 15 to GAF products other than thermal industrial insulation 16 materials containing asbestos on the ground that such information 17 is not relevant to the subject matter of this action nor 18 reasonably calculated to lead to the discovery of admissible evi- 19 dence. 20 INTERROGATORY NO. 10: 21 Do you agree that once asbestos fibers or dust are in22 haled into the lungs, there is no way to eliminate all such dust 23 or fibers from the lungs for the balance of such person's life? 24 ANSWER: 25 GAF objects to this interrogatory on the grounds that 26 it is argumentative, improperly calls for expert opinion, and 6. 1 that medical evidence on this point is equally available to 2 plaintiff. 3 INTERROGATORY NO. 11; 4 What technique, if any, does your company use to make 5 dust samplings. Please explain each technique and when it was 6 commenced; what the purpose was; and what action has been taken 7 in response to the findings as to the dust samples. 8 ANSWER; 9 Not applicable. See GAF's objection to Interrogatory 10 No. 9 regarding GAF products other than thermal industrial insu 11 lation materials containing asbestos. 12 INTERROGATORY NO. 12: 13 Does your, company recognize that asbestos causes 14 asbestos-induced lung cancer? If your answer is "yes," when 15 did you come to such realization and what action did you take 16 in response thereto? If your answer is "no," then please 17 explain why no studies were made by your company to ascertain 18 that this fact was indeed true and thereafter to take action 19 to advise those exposed to your products of their dangerous 20 nature. 21 ANSWER; 22 GAF objects to this interrogatory on the ground 23 that the use of the word "causes," standing alone, is so 24 vague and ambiguous that it cannot frame a meaningful 25 response thereto. Moreover, the interrogatory is argumentative, 26 improperly calls for expert opinion, and medical evidence 7 1 regarding the point raised is equally available to plaintiff. 2 See, however, GAF's Answer to Interrogatory B(3)(c)(3) and (5) 3 of plaintiff's first interrogatories - Velasquez. 4 INTERROGATORY NO. 13: 5 Does your company recognize there is a direct connec 6 tion between the inhalation of asbestos dust and fibers and 7 the disease mesothelioma? If your answer is "yes," to this 8 question, then please advise what notices were given to those 9 exposed to your asbestos products of this fact. 10 ANSWER: 11 GAF objects to this interrogatory on the ground 12 that it is argumentative, improperly calls for expert opinion, 13 and that medical evidence regarding this point is equally 14 available to plaintiff. Moreover, the use of the term "direct 15 connection" is so vague and ambiguous that GAF cannot frame a 16 meaningful response to the interrogatory. See, however, GAF's 17 Answer to Interrogatory B(3)(c)(1) through (5) of plaintiff's 18 first set of interrogatories - Velasquez. 19 INTERROGATORY NO. 14; 20 Do you agree that asbestos has been directly 21 associated medically with the disease of cor pulmonale? 22 ANSWER: 23 GAF objects to this interrogatory for the reasons 24 set forth in Answer to Interrogatories 12 and 13 above. 25 The term "directly associated" is too vague and ambiguous 26 for GAF to be able to frame a meaningful response to the 8. 1 interrogatory. 2 INTERROGATORY NO. 15; 3 Has your company consulted with Dr. Irving J. 4 Selikoff, of New York, New York, concerning asbestosis, or 5 other asbestos-related diseases? If so", please state when 6 and under what circumstances and what information, if any, 7 was furnished by your company, giving dates, to him. 8 ANSWER: 9 GAF objects to this interrogatory on the grounds that 10 the word "consulted" is so vague and ambiguous that GAF cannot 11 frame a meaningful response thereto. 12 INTERROGATORY NO. 16: 13 Does your company recognize that Dr. Selikoff is one 14 of the world's foremost authorities on asbestosis and 15 mesothelioma? 16 ANSWER: 17 Defendant GAF objects to this .interrogatory on the >i 18 ground that it is argumentative, not relevant to the subject 19 matter of this action, nor reasonably calculated to lead to 20 the discovery of admissible evidence. 21 22 INTERROGATORY NO. 17: 23 Has your company previously, or does your company now, 24 contribute any funds to research concerning asbestos and its 25 relation to lung and other diseases of the body? If so, please 26 state the amount of money contributed, when and to whom, attaching 9. 1 any report or reports from such individual or organization to 2 whom your funds were contributed. 3 ANSWER: 4 GAF has made no direct contributions of funds to re5 search concerning asbestos and its purported relation to lung and 6 other diseases of the body. 7 INTERROGATORY NO. 18: 8 Do you have any labor inspectors or anyone from 9 your company whose job it is to go to areas where your products 10 are being used to make a dust level count? If so, please state 11 when your company started such procedure, the purpose of it. 12 and what action, if any, was taken in response to your findings. 13 ANSWER: 14 Not applicable. GAF does not presently manufacture 15 industrial insulation products containing asbestos fibers. 3.6 INTERROGATORY NO. 19: 17 Is your company familiar with the hearings conducted 18 in March 1967 before the House of Representatives of the United 19 States Congress Subcommittee on Labor? If so, did any repre20 sentative of your company participate in such hearings? If so, 21 state the name and address of your company representative. 22 ANSWER: 23 No. 24 INTERROGATORY NO. 20: 25 Do you have a copy of the transcript of such hearing? 26 If so, will you make a copy thereof available for plaintiff's 10. 1 inspection and copying without an order? 2 ANSWER; 3 No. 4 INTERROGATORY NO, 21: 5 Is it possible to distinguish your insulation products 6 containing asbestos from those manufactured or distributed by a 7 competitor when such product has been removed from its container? 8 if your answer is "yes," please describe how you contend your 9 products in all instances can be distinguished from that of a 10 competitor. If there are products which cannot be distinguished, 11 in your opinion, from products of a similar kind manufactured 12 by a competitor, please state the name of such product, who manu13 factures or distributes it, as well as the product manufactured 14 by your competitor. 15 ANSWER; Yes, by comparing, among other things, the form and/ 17 or substance and/or appearance of GAF products to those of 18 other products. 19 INTERROGATORY NO. 22: 20 Is it true that most of the products manufactured 21 or distributed by your company containing asbestos were intended 22 by you in most instances to be cut, sawed, scribed, shaped, or 23 mixed by the ultimate user and his employees, in the application 24 or installation of these products? 25 ANSWER; 26 No. 11. 1 INTERROGATORY NO. 23: 2 Please give the state of incorporation of your 3 company, the date it was organized, and the domicile of your 4 company at this time. State the name and address of the president 5 of your company. 6 ANSWER: 7 The Ruberoid Co. was incorporated in New York in 1886 8 under the name The Standard Paint Company. After several corpo 9 rate changes, The Standard Paint Company was incorporated in New 10 Jersey in 1905. The Standard Paint Company became The Ruberoid 11 Co. on March 10, 1921. After 1966 the executive offices of The 12 Ruberoid Co. were located at 733 Third Avenue, New York, New 13 York. 14 GAF was incorporated in Delaware in 1929 as the 15 American I.G. Chemical Corporation. Its name was changed in 16 1939 to General Aniline & Film Corporation and again in 1968 to 17 GAF Corporation. 18 GAF's principal place of business is 140 West 51st 19 Street, New York, New York 10020. Its president is Dr. Jesse 20 Werner. 21 INTERROGATORY NO. 24: 22 How many years has your company been engaged in the 23 manufacture of products containing asbestos? 24 ANSWER: 25 Pursuant to Agreement dated March 23, 1967, GAF merged 26 with The Ruberoid Co. The Ruberoid Co. began the manufacture of 12. 1 thermal industrial insulation products containing asbestos in 2 the 1930's. GAF ceased the manufacture of such products in 3 1972. 4 INTERROGATORY NO. 25; 5 If your company contends that any respirator or 6 other breathing device is currently on the market that will 7 prevent the inhalation of asbestos dust and fibers, give the 8 detailed description of such respirator or other breathing 9 device, together with how you know this will prevent the 10 inhalation of such dust and fibers, what tests were conducted, 11 by whom and where, with sufficient detail to enable us to 12 obtain the results of such tests. 13 ANSWER; 14 GAF ceased the manufacture of thermal industrial insu 15 lation products containing asbestos in 1972. GAF makes no con 16 tentions as described in this interrogatory, but GAF does know 17 that certain "breathing devices" are "currently on the market." 18 INTERROGATORY NO. 26: 19 If you have answered Interrogatory No. 25 that there 20 is a respirator or other breathing device currently on the market 21 that will prevent the inhalation of asbestos dust and fibers, 22 then state what date or approximately what date such device was 23 placed on the market. 24 ANSWER: 25 Unknown. 26 /// 1 INTERROGATORY NO. 27: 2 Prior to the date such device was placed on the 3 market, was there a respirator or other breathing device on 4 the market to prevent the inhalation of asbestos dust and fibers? 5 If so, give the description of such device, together with how 6 you know it prevented the inhalation of dust and fibers, what 7 tests were conducted, by whom and where, with sufficient detail 8 to enable plaintiffs to obtain the results of such tests. 9 ANSWER: 10 Unknown. 11 INTERROGATORY NO. 28: 12 Is it true that your company has manufactured or 13 distributed insulating materials containing asbestos for many 14 years, and that such products have been placed upon the open 15 market to be purchased and used by the public? 16 ANSWER: 17 See GAF's Answer to Interrogatories 4, 5, 18 and 24. GAF objects to so much of the interrogatory as 19 refers to "open market" and "the public" on the grounds 20 that said terms are vague and ambiguous and GAF cannot 21 frame a meaningful response thereto. 22 INTERROGATORY NO. 29: 23 Has your company ever recognized the fact that 24 after your products have been purchased from you that they 25 will ultimately be used and applied by a worker in the field 26 such as an insulator and asbestos worker? 14. 1 ANSWER: 2 Yes. 3 INTERROGATORY NO. 30: 4 Does your company recognize that insulating materials 5 containing asbestos are dangerous and harmful to human beings 6 and to the health of man? If your answer to this question is 7 "yes," then please explain when you came to this conclusion and 8 what, if anything, you have done about it to notify the public. 9 If your answer is that your products are not harmful, then explain 10 what tests were made by you upon which you base such conclusion. 11 ANSWER: 12 GAF objects to this interrogatory on the grounds 13 set forth in Answer to Interrogatories 12 and 13 above. 14 See, however, GAF's answer to interrogatory B of plaintiff's 15 first interrogatories - Velasquez. 16 INTERROGATORY NO. 31: 17 Please state whether or not your company has knowledge f 18 of any deaths of lung disease among your employees which has been 19 attributed to asbestos dust or fibers. If so, please give the 20 number, the names of the employees, the address of such employees, 21 together with the name and address of the doctor who administered 22 treatment to such employee, if known. 23 ANSWER: 24 See GAF's answer to interrogatory F of plaintiff's 25 first interrogatories - Velascruez, as supplemented by the 26 letter of Stuart C. Walker to J. Kenneth Lynch, cated December i 15. 1 5, 1975. 2 INTERROGATORY NO. 32; 3 If your company previously manufactured or distributed 4 any insulation containing asbestos commonly used by insulators, 5 or does so now, please describe how the following products were, 6 or are, cut, shaped, mixed, and applied on the jobs: 7 (a) Asbestos cement 8 (b) Asbestos pipe covering 9 (c) Asbestos bricks or blocks 10 (d) Asbestos sheeting 11 (e) Asbestos rope or cloth 12 (f) Asbestos insulation in loose form which may be 13 blown into homes or buildings 14 (g) Asbestos in spray form. 15 In answering this question, give particular reference as to 16 whether or not the materials were to be sawed or cut on the 17 job, blown into confined areas, or mixed with water in a 18 cement or paste. State whether or not there is any way known 19 to you that the above products can be used and applied without 20 the worker inhaling any of the dust or fibers, giving the date 21 that you first: knew of such method you have described, and 22 how it is done. 23 ANSWER: 24 GAF's products were supplied in a ready-to-use form. 25 However, where on-site fitting was required, the following pro 26 cedures were necessary: 16. 1 1) Calsilite: required cutting only where dimensions 2 so dictated. 3 2) 7M Cement and 6D Cement: required mixing with 4 water. In addition, a small amount of ordinary 5 building cement was added at the user's option. 6 3) TN/A 100: required cutting only where^dimensions 7 so dictated. 8 4) Asbestos paper and millboard: required cutting 9 only where dimensions so dictated. 10 GAF has no direct knowledge regarding how its products were used 11 at job sites. See also, GAF's Answer to Interrogatory No. 9 above. 12 INTERROGATORY NO. 33: 13 Do you have any statistical figures available showing 14 the number of your employees who are exposed to asbestos dust and 15 fibers in their employment, and who have worked for your company 16 10 years or longer and who have lung disease? If so, please 17 give such figures. 18 ANSWER: 19 No. 20 INTERROGATORY NO. 34: 21 Do you have any medical information or information 22 of your own knowledge concerning the most common cause of death 23 of one having asbestosis? If so, describe what the most frequent 24 cause of death from one suffering from such disease is. 25 ANSWER: 26 GAF objects to this interrogatory on the grounds that 17. 1 it is so vague and ambiguous that GAF cannot frame a meaningful 2 response thereto. Moreover, the interrogatory is argumentative, 3 improperly calls for expert opinion, and information relating to 4 the point raised is equally available to plaintiff. 5 INTERROGATORY NO. 35; 6 State the net profits made by your company for each of 7 the years since and including the year 1960. 8 INTERROGATORY NO. 36: 9 State the net worth of your company as of the end of 10 your annual accounting period for each of the years since 1960. 11 INTERROGATORY NO. 37: 12 Give the total volume of sales of products manufactured 13 or distributed by your company and include, if possible, the total 14 amount of sales of products of your company containing asbestos 15 for each of the years since 1960. 16 ANSWERS TO INTERROGATORIES NOS. 35, 36 AND 37; 17 GAF will make available to plaintiff's attorneys for 18 their inspection and copying at plaintiff's expense copies of its 19 Financial Statements for the period 1967 to present as they appeared 20 in GAF's published Annual Reports. GAF will also produce for 21 plaintiff's inspection and copying at plaintiff's expense the 22 Financial Statements of The Ruberoid Co. as they appeared in its 23 published Annual Reports for the years 1960 through 1966. 24 INTERROGATORY NO. 38: 25 Has your company ever devised a high temperature 26 heat insulation which does not contain asbestos? If so, state 18. 1 the date that such insulation was first placed on the market 2 and whether or not you have eliminated your insulation products 3 containing asbestos. 4 ANSWER: 5 Yes. See letter of December 5, 1975 from Stuart C. 6 Walker to J. Kenneth Lynch, supplementing GAF's answer to 7 interrogatory H of plaintiff's first interrogatories - Velasquez. 8 See also GAF's answer to interrogatory H of plaintiff's first 9 interrogatories - Velasquez. 10 INTERROGATORY NO. 39: 11 State what prompted your company to devise such high 12 temperature heat insulation not containing asbestos. 13 ANSWER: 14 GAF followed its competition in improving and updating 15 its insulation products. 16 INTERROGATORY NO. 40: 17 Has such high temperature heat insulation not con18 taining asbestos performed satisfactorily, that is, is such 19 insulation suitable for the purpose for which it is used? 20 ANSWER: 21 Such product did perform satisfactorily. 22 INTERROGATORY NO. 41: 23 Does your company know of any other company which has 24 devised a high temperature heat insulation which does not con25 tain asbestos? If so, state the name of the company and the 26 trade name of such insulation. 19. 1 ANSWER: 2 GAF believes that most, if not all, major insulation 3 manufacturers have developed high temperature insulation, not 4 containing asbestos. GAF, however, has no first hand knowledge 5 regarding any manufacturer or its specific insulating products. 6 INTERROGATORY NO. 42: 1 7 Since devising a high temperature heat insulation 8 which does not contain asbestos, if you have done so, state 9 whether or not you have continued to manufacture or distribute 10 insulation containing asbestos. 11 ANSWER: 12 See GAF's Answer to Interrogatory No. 38. 13 INTERROGATORY NO. 43: 14 If you have devised a high temperature heat insula- 15 tion which does not contain asbestos, please list the trade 16 name or names of such insulation, and state fully what such 17 insulation contains. 18 ANSWER: 19 "Calsilite II". See also, GAF's Answer to Interrogatory 20 No. 38. GAF no longer manufactures asbestos-free Calsilite. 21 INTERROGATORY NO. 44: 22 If your company has devised a high temperature 23 heat insulation which does not contain asbestos, state whether 24 r not your sales of asbestos insulation have decreased. If 25 your sales have decreased, please state in dollars the amount 26 of such decrease for each year since you began manufacturing 20. 1 insulation which does not contain asbestos. 2 ANSWER: 3 GAF no longer manufactures thermal insulation products 4 containing asbestos. 5 INTERROGATORY NO. 45: 6 Have you ever been requested by contractor* to 7 devise a high temperature heat insulation not containing 8 asbestos? If so, please give the dates of such requests, and 9 by whom they were made. 10 ANSWER: 11 No, not to GAF's best recollection. 12 INTERROGATORY NO. 46: 13 Has your company ever been advised of threshold limit 14 values for exposure to asbestos dust recommended by the American 15 Conference of Governmental Industrial Hygienists? If so, state 16 the year that you were first advised or made aware of such 17 threshold limit values. Will you voluntarily make available t 18 copies thereof for plaintiff's inspection and copying? 19 ANSWER: 20 Yes. This defendant does not have a specific recoi- 21 lection concerning the date on which it first became aware of 22 threshold limit values recommended by the American Conference 23 of Governmental and Industrial Hygienists. This defendant 24 has always endeavored to operate within the special limits 25 thus recommended. The recommendations of the American Con26 ference of Governmental and Industrial Hygienists are a matter i 21. 1 of public record and equally available to plaintiff. 2 INTERROGATORY NO. 47: 3 What was the threshold limit values for exposure to 4 asbestos dust which was recommended by the American Conference 5 of Governmental Industrial Hygienists when you were first 6 advised of such threshold limit values? 7 ANSWER; 8 The first value GAF is able to recall was 5,000,000 9 particles per cubic foot (5MPPCF). 10 INTERROGATORY NO. 48; 11 Have you been made aware of any changes in the 12 threshold limit values for exposure to asbestos dust recommen 13 ded by the American Conference of Governmental Industrial 14 Hygienists in the last five years? If so, please state what 15 changes, if any, have been made in such threshold limit values, 16 and when you were first advised of such changes. 17 ANSWER; 18 Yes. In 1968 the American Conference of Governmental 19 Industrial Hygienists proposed that the threshold limit value be 20 changed to 12 fibers greater than 5 microns in length per milli 21 liter or 2,000,000 particles per cubic foot (2MPPCF), and in 1970 22 proposed that the threshold limit value be changed to 5 fibers 23 greater than 5 micrometers in length per milliliter. 24 INTERROGATORY NO. 49; 25 Has your company, either directly, or indirectly, 26 through any trade associations, ever advised any contractor 22. 1 to whom you sell, or have sold, your products containing as2 bestos of threshold limit values for exposure to asbestos 3 dust recommend by the American Conference of Governmental 4 Industrial Hygienists? If so, state the date or dates that 5 you so advised such contractors and the manner in which you 6 advised such contractors. 7 ANSWER: 8 GAF belongs to the Asbestos Information Association/ 9 North America, Inc. ("AIA"). As it is believed that the main 10 function of the AIA is to publish material and literature which 11 is then forwarded or otherwise transmitted to contractors, GAF 12 has indirectly advised contractors of such threshold limit values. 13 See also GAF's Answer to Interrogatories Nos. 1 and 9 above. 14 INTERROGATORY NO. 50: 15 Do you agree that various states of the United States 16 have enacted Workers' Compensation Laws covering employees who 17 contract an occupational disease in their employment? 18 ANSWER: 19 GAF objects to this interrogatory on the grounds 20 that it is argumentative, calls for information that is a 21 matter of public record, is not relevant to the subject matter 22 of this action nor reasonably calculated to lead to discovery 23 of admissible evidence, and is so vague and ambiguous that 24 GAF cannot frame a meangingful response thereto. 25 INTERROGATORY NO. 51: 26 Do you agree that one,or more states of the United j 23. 1 States have enacted such Workers' Compensation Laws covering 2 employees who contract an occupational disease as early as 3 the year 1913? 4 ANSWER: 5 GAF objects to this interrogatory for the reasons 6 set forth in its Answer to Interrogatory No. 50. 7 INTERROGATORY NO. 52: 8 Do you agree that one or more states of the United 9 States have enacted such Workers' Compensation Laws covering 10 employees who contract an occupational disease as early as 11 the year 1917? 12 ANSWER: 13 GAF objects to this interrogatory for the reasons 14 set forth in its Answer to Interrogatory No. 50. 15 INTERROGATORY NO. 53: 16 Do you agree that one or more states of the United 17 States have enacted such Workers' Compensation Laws covering 18 employees who contract an occupational disease as early as 19 the year 1920? 20 ANSWER: 21 GAF objects to this interrogatory for the reasons 22 set forth in its Answer to Interrogatory No. 50. 23 INTERROGATORY NO. 54: 24 Do you agree that one or more states of the United 25 States have enacted such Workers' Compensation Laws covering 26 employees who contract an occupational disease as early as 24. 1 the year 1930? 2 ANSWER: * 3 GAF objects to this interrogatory for the reasons 4 set forth in its Answer to Interrogatory No. 50. 5 INTERROGATORY NO. 55: 6 Do you agree that asbestosis is an occupational 7 disease? 8 ANSWER: 9 GAF objects to this interrogatory on the grounds 10 that it is argumentative, improperly calls for expert opinion, 11 and that the information sought is not relevant to the subject 12 matter of this action nor reasonably calculated to lead to 13 discovery of admissible evidence. Moreover, the interrogatory 14 is so vague and ambiguous that GAF cannot frame a meaningful 15 response thereto. 16 INTERROGATORY NO. 56: 17 Do you have copies of your current sales literature 18 for your insulation products available? If so, will you 19 furnish plaintiff copies of such sales literature for inspec 20 tion and copying? 21 ANSWER: 22 No. GAF does not presently manufacture insulation 23 products containing asbestos. 24 INTERROGATORY NO. 57: 25 Do you have copies of your sales literature for your 26 insulation products containing asbestos for the years 1950, 25. 1 1955, 1960, 1965, 1970 available? If so, will you furnish 2 plaintiff copies of such sales literature for inspection and 3 copying? 4 ANSWER: 5 GAF will make available to plaintiff's counsel for 6 inspection and copying whatever sales literature for its 7 insulation products containing asbestos that it can locate in 8 its files for the years indicated. 9 INTERROGATORY NO. 58; 10 Does your company have, or has it ever had, a Research 11 Department? If so, give the name and address of each head of 12 such department, give the year that such Research Department 13 was established and whether or not such Research Department has 14 operated continuously since being established. 15 ANSWER: 16 During the period from 1967 through the present, the 17 following persons at GAF have held the position Vice-President 18 Research: 19 20 GAF 21 Name 22 Dr. Leon Katz 23 Dr. Frederick Grosser 24 Dr. Robert Meyers 25 Dr. Simon Kantor 26 /// Date of Service -1967 1967-1969 1969-1972 1972-Present Present Employer American Can GAF Regal Paper GAF 26. 1 The directors of the research" department at The 2 Ruberoid Co. were as follows: 3 Name 4 5 Edward Duke Date of Service 7-1947 Present Employer Retired; address unknown 6 Clarence Eckert 1947-1958 Deceased 7 Philip S. Bettoli 1958-1967 GAF 8 GAF does not recall the date when it initially es 9 tablished a Research Department. 10 INTERROGATORY NO. 59: 11 Please state in detail the duties and responsibilities 12 of such Research Department. 13 ANSWER: 14 Principally, new product research and development. 15 INTERROGATORY NO. 60: 16 Does your company have, or has it ever had, a Medical 17 Department? If so, give the name and address of each head of 18 such department, give the year that suc!h Medical Department was 19 established and whether or not such Medical Department has 20 operated continuously since being established. 21 ANSWER: 22 No. 23 INTERROGATORY NO. 61: 24 State in detail the duties and responsibilities of 25 such Medical Department. 26 /// 4 27. ANSWER: Not applicable. INTERROGATORY NO. 62: Does your company employ any person or persons as a "librarian" or keeper of articles, books, transcripts, reports, medical literature, past or current, advertising materials, or other documents relating to health hazards of various insula tion products? If so, please state: (a) the name and resi dence address of each person so employed; (b) the date such "library" or collection of documents was commenced; (c) the location of each such "library" or collection; (d) a general description of contents of the "library" or collection. ANSWER: No. INTERROGATORY NO. 63: Does your company have copies of the books, articles, reports, transcripts, or literature described in Exhibit "A" attached hereto? If so, will you voluntarily make copies there of available to plaintiff for inspection and copying? ANSWER: GAF believes that it has some but not all of the items listed in Exhibit "A". A detailed inventory is not possible because this literature, if in GAF's possession, custody or con trol, would be located in diverse geographic locations, and then, in several, if not more, offices in each such location. In any event, GAF does receive whatever information is disseminated by 1 the AIA and will, if so requested, make inquiry to determine what 2 items were sent to it by the AIA during the period of GAF's 3 membership. 4 INTERROGATORY NO. 64; 5 To what trade associations concerning insulation 6 and building products has your company belonged to?~ Please 7 state the full name and address of each such association, and 8 the period or periods of your company's belonging? 9 ANSWER: 10 GAF has belonged to the following trade associations re 11 lated to insulation materials containing asbestos: 12 Asbestos Information Association/North American Suite 914 13 1660 L Street N.W. Washington, D.C. 20036 14 National Insulation Manufacturers Association, Inc. 15 441 Lexington Avenue New York, N.Y. 10017 16 Asbestos Cement Product Association 17 (believed defunct) 18 American Society of Testing Materials Race Street, Philadelphia, Pennsylvania 19 20 INTERROGATORY NO. 65: 21 Has your company or its employees participated in 22 the writing or publication by such association written or filmed 23 information concerning insulation products? If so, please state: 24 (a) the names and residence addresses of your employees so in 25 volved; and (b) the titles and dates of such writings or films. 26 Will you make such writings or films available to plaintiff for 1 inspection and copying? 2 ANSWER: 3 No. 4 INTERROGATORY NO. 66: 5 Will youstipulate that this set of Interrogatories 6 and your answers thereto may be utilized in the following 7 civil actions as though fully asked and answered in said 8 actions without the necessity of submitting the same set of 9 Interrogatories to you in said actions and without the neces- 10 sity of your reanswering said Interrogatories in each of 11 said actions? 12 (a) Judson G. Fleming v. Fibreboard, et al.. Action No. 710-899 13 (b) Maurice Kendall v. Fibreboard, et al.. 14 Action No. 697-762 15 16 17 18 19 20 21 22 23 24 25 /// (c) Opal Morrison, Ad administrator of the Estate of Elwyn J. Morrison, deceased v. Fibreboard, et al., Action No. 701-446 (d) Joe P. Sandoval v. Fibreboard, et al.. Action No. 689-959 (e) Neal Speer v. Fibreboard, et al.. Action No. 695-157 (f) Sherman S. Stewart v. Fibreboard, et al.. Action No. 695-921 (g) Mary J. Thompson, As administrator of the Estate of Clarence Ewing Thompson, deceased v. Fibreboard, et al., Action 698-870 (h) Robert Wadley v. Fibreboard, et al., Action No. 697-762. 26 /// 30. 1 ANSWER: 2 Yes. 3 DATED: January 1977. 4 McCUTCHEN, DOYLE, BROWN & ENERSEN 5 6 By STUART C. WALKER Attorneys for Defendant 7 GAF Corporation 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 31. K! 1 STATE OF NEW YORK ) ) SS: 2 COUNTY OF NEW YORK ) 3 JONATHAN BERGER, being duly sworn according to law, 4 deposes and says that he is Assistant Secretary of defendant 5 GAF Corporation; that he is duly authorized to make this affi 6 davit on behalf of said corporation; and that all of the state 7 ments set forth in the foregoing Responses to Plaintiff's Second 8 Set of Interrogatories are true and correct to the best of his 9 knowledge, information and belief. 10 11 12 13 14 Sworn to and subscribed before me this / 7 - day 15 of January, 1977. 16 17 'otary Public 18 19 20 21 22 23 24 25 26 1. Jack Woodward and Ed Koch of Johns-Manville visited them. D. Johns-Manville supplied them with fiber off and on. 1. Difficulty with infiltration problems. E. Bought from: V. jGAF 1. Cassiar 2. Lake Asbestos Company 1 2 3. Asbestos Corporation A. Acquired Rubberoid in 1963 - fiber product manufacturer. B. 1958-1962 Ken McDonald was vice president of purchasing - Hendry did not discuss housekeeping with him. 1. Hendry would give McDonald technical information. C. President during 1960's was Tim O'Leary. 1. He discussed health hazards with Clint Burnett, Johns-Manville president, D. Joe Hall was in charge of asbestos mine in Vermont in 1950's. 1. In 1960's was vice president. 2. Asked Hendry many questions regarding asbestos, environment, and equipment. 3. Knew more than others in Rubberoid organization regarding asbestos hazards. 't E. From 1968 to the present, Don' Partridge of Johns-Manville called on GAF plants in St. Louis and Kansas City. 1. He passed on information regarding health hazards with asbestos. 2. Hendry also visited GAF plants. VI. H. K. Porter A. Owned and operated prior to 1975 by Pacific Asbestos in Calaveras County, California. B. In 1975, H. K. Porter sold to U.S./German interests. C. Charlotte, North Carolina textile plant was very clean. -12- ) ASBESTOSIS CASES IN WHICH GAF WAS A DEFENDANT AS OF JANUARY 11, 1977 Ahern vs. Keene Industrial Insulation, et al County of Philadelphia, Court of Common Pleas Case No. 3463 Albert vs. Keene Industrial Insulation, et al County of Philadelphia, Court of Common Pleas case No. 680 Allore vs. Combustion Engineering, Inc., et al United States District Court for the Northern District of Ohio Eastern Division Case No. C-76-447 Anthol2 vs. Fibreboard Paper Products, et al United States District Court for District of Minnesota - Fifth Division Case No. 5-70 Civ. 105 Status: dismissed Armstrong vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 1057 Ballinger vs. Combustion Engineering, Inc., et al Circuit Court, Division I, Knox Co., Knoxville, Tennessee Case No. 1-684-75 Barrett vs. Johns-Manville Products Corporation, et al Circuit Court of Missouri, Sixteenth Judicial Circuit Case No. 784937 Status: dismissed Baumann vs. Fibreboard Paper Products Corporation, et al Superior Court of the State of California in and for the City and County of San Francisco Case No. 688-553 Baumgartner vs. Combustion Engineering, Inc.; et al United States District Court for the Northern District of Ohio Eastern Division Case No. C-75-1057 Bednarczyk vs. Armstrong Cork Company, et al Circuit Court of Cook County, Illinois Case No. 76 L-5285 Bell vs. Fibreboard Paaer Products Coro., et al United States District Court for Eastern District of Texas Case No. B-74-CA-50 Status: settled Bellot vs. Fibreboard Coro., et al United States District Court for the Eastern District of Texas Beaumont Division Case No. B-74-253-CA Status: settled Bender vs. Armstrong Cork Company, et al United States District Court for the Southern District cf Florida, Miami Division Case No. 75-2578 Bilotta vs. Keene Industrial Insulation, et al Court of common Pleas of Philadelphia County Case No. 412, 413 Birkner vs. GAF Corporation, et al Circuit Court of the City of St. Louis, State of Missouri Case No. 57711 F Borel vs. Fibreboard Paper Products Corporation, et al United States District Court for the Eastern District of Beaumont Division Case No. 6449 Status: Judgment affirmed on appeal Texas - Breedlove vs. Combustion Engineering, Inc., et al United States District Court - Northern District of Eastern Division Case No. C-74-1130 Ohio - Broussard vs. Fibreboard Paper Products Corporation, et al United States District Court for the Eastern District of Texas Beaumont Division Case No. B-73-CA-300 Status: settled - Brown vs. Combustion Engineering, Inc., et al United States District Court, District of South Caroline, Charleston Division Case No. 76-1162 Bugyis vs. Johns-Manville Products Corp. et al Circuit Court of Cook County, Illinois Case No. 76 L 2164 Bunn vs. Keene Industrial Insulation, et al County oi Philadelphia, Court of Common Fleas Case No. 3455 Bura vs. Keene Industrial Insulation, et al Court of Common Pleas of Pnilaaeiphia County Case No. 684 Burke vs. Combustion Engineering, Inc., et al United States District Court for the Northern District of Ohio - Eastern Division Case No. C73-239 Burke vs. Standard Asbestos Manufacturing and Insulating Company, et al United States District Court for tne Southern District of Texas'- Houston Division Case No. 75-H-870 Buscaino vs. Fibreboard Paper Products Corporation, et al Superior Court of the State of California in and for the City and County of San Francisco Case Ho. 694-631 Status: settled 2 Byerly vs. Standard Asbestos Manufacturing and Insulating Company, et al United States District Court cr the Southern District of Texas - Houston Division Case No. 75-H-866 Canino vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 924 Carr vs. Combustion Engineering, Inc., et al U.S. District Court, East. Dist. of Michigan, South Division Case No. 572332 Carter vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 413 Cathcart vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 923 Chaddock vs. Combustion Engineering, Inc., et al United states District Court for the Northern District of Ohio - Eastern Division Case No. C-75-102 Ciseck vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 4022 Coleman vs. Keene Industrial Insulation, et al County of Philadelphia, Court of Common Pleas Case No. 3459 Condray vs. Fibreboard Corporation, et al United States District Court, Eastern District of Texas, Beaumont Division Case No. B-76-108-CA Conte vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 686 Corea vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 1056 Corkran vs. Fibreboard Paper Products Corporation, et al United States District Court, Eastern District of Texas, Beaumont Division Case No. B-76-128-CA Crawford vs. Fibreboard Corporation, et al Court of Common Fleas of Philadelphia County Case No. 4016 Crawford vs. Fibreboard Paper Products Corporation, et al United States District Court for cne Eastern District of Texas Beaumont Division Case Ho. 6492 Status: settled Cunningham vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case Ho. 412, 413 3 Curtin vs. Johns-Manville Products Corporation, et al Circuit Court of the Third Judicial circuit, MadisonCounty Case No. 75-L-146 Status: dismissed Daniels vs. Combustion Engineering, Inc., et al State of Tennesse, Circuit Court of Knox County, Division Z Case No. 1-492-75 DeChristopher vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 1749 Pellamo vs. Keene Corporation, et al Court of Common Pleas of Philadelphia County Case No. 100 Dickey vs. Standard Asbestos United States District Court Houston Division Case No. 75-H-864 Manufacturing and Insulating Company, for the Southern District of Texas, et al Dolce vs. Fibreboard Paper Products Corporation, et al United States District Court for the Eastern District of Beaumont Division Case No. B-75-191-CA Texas - Dunbar vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 412, 413 Duncan vs. Combustion Engineering, Inc., et al United States District Court for the District of South Carolina, Charleston Division Case No. 76-1249 Dunn vs. Keene Industrial Insulation, et al County of Philadelphia, Court of Common Fleas Case No. 3452 Dunn vs. Johns-Manville International Corporation, et al United States District Court for the Southern District of Houston Division Case No. 73-H-1072 Texas - Estepp vs. Combustion Engineering, et al State"of Tennessee, Circuit Court of Knox County Case No. 2-474-75 Farrar vs. Standard Asbestos Manufacturing & Insulating Co., et al United States District Court for the Southern Drstrictof Texas, Houston Division Case No. 75-H-862 Featherstone vs. Johns-Mar.ville Sales United States District Court, Eastern Division Case No. B-76-167-CA Status: settled Coreoration, et al District of Texas - Beaumont Ferris vs. Keene Corporation, et al Court of Common Pleas of Philadelphia County Case Mo. Jones, Wilson W. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Long, James T. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Overman, Percy C. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Patrick, 0. W. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Reynolds, Hugh V. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Roland, John Lee vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Sawyer, Thomas R. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Stacey, Milton L. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Van Dyke, Robert L. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Watson, Homer E. vs. Johns-Manville Corporation, et al United States District Court for the Eastern Districtof Virginia, Newport News Division Case No. 76-178-NN White. John W. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN White, Walter J. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Turlev vs. Combustion Engineering, Inc., et al United States District Court for the Northern District of Georgia, Gainesville Division Case No. C76-108 G Bailey, Esther vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-155-NN Grimes vs. Owens-Coming Fiberalas Corporation, et al United States District Court, Southern District of Texas, Houston Division Case No. 76-H-1936 Small vs. Johns-Manville International Corp., et al United States District Court, Southern District ofTexas, Houston Division Case No. 76-H-1907 Walker vs. Johns-Manville Corporation, et al Circuit Court of the City of Newport News Case No. 2959-G Mosher vs. Johns-Manville Products Corporation, et al Circuit Court for the County of Wayne Case No. 76-614243 Shout vs. Johns-Manville Products Corporation, et al Circuit Court for the County of Wayne" Case No. 76-606-823 Caines, Dorothy (Executrix) vs. Combustion Engineering, Inc., et al Court of Common Pleas, County of Barnwell, South Carolina Case No. Drinkard, Harriet vs. Combustion Engineering, Inc., et al United States District Court, Northern District of Ohio, Eastern Division Case No. C76-1318 Cash, Ronald M. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Ellis, Donahue vs. Johns-Manville Corooratzion, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Gibbons, Willie A. vs. Johns-Manville Corporation, et al United States District Court for tne Eastern District of Virginia, Newport News Division Case No. 76-178-NN Hoooe, Thomas J. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Holloway, Maurice W. vs. Johns-Manville Corporation, et al United States District Court for the Eastern District of Virginia, Newport News Division Case No. 76-178-NN Foster vs. Fibreboard Paper Products United States District Court for the Beaumont Division Case No. B-74-204-CA Status: settled Corporation, et al Eastern District of Texas - Freeman vs. Standard Asbestos Manufacturing and Insulating Company, United States District Court for the Southern District of Texas Houston Division Case No. 75-H-B69 Frith vs. Johns-Manville Products Corporation, et al United States District Court for the western District of Louisiana - Shreveport Division Case No. 73-H-1072 Gaspard vs. Standard Asbestos Manufacturing and Insulating Company, United States District Court for the Southern District of Texas - Houston Division Case No. 75-H-868 et al Gaus vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 4020 Gerace vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 3930 Gibson vs. Johns-Manville Products Corporation, et al District Court in and for the County of Boulder, Colorado Case No. 74-12-6-2 Status: settled Grecco vs. Keene Industrial Insulation, et al Court of Common Pleas ox Philadelphia County Case No. 4017 Greene vs. Keene Industrial Insulation, et al County of Philadelphia, Court of Common Pleas Case No. 3458 Gustafson vs. Fibreboard Paper Products Corporation, et al United States District Court for the Fifth Division - District of Minnesota Case No. 5-71-40 Status: dismissed Hainsworth vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 4024 Hallinan vs. Combustion Engineering, Inc., et al United States District Court for the Southern District of Indiana - Evansville Division Case No. 75-25-C Status: settled Hamilton vs. Johns-Manville Products Corporation, et al In the Circuit Court of Jac.<son County, Missouri at Kansas Case No. 784,986 Status: dismissed City Hammond vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 922 Hanna vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 4023 Harter vs. Combustion Engineering, Inc., et al United States District Court for the Northern District of Ohio, Eastern Division Case No. C-75-452 Hartwell vs. Johns-Manville Products Corporation, et al United States District Court for the Eastern District of Texas - Beaumont Division Case No. 7513 Status: settled Heinsdorf vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 1755 Holton vs. Standard Asbestos Manufacturing & Insulating Co., et al United States District Court for the Southern District of Texas - Houston Division Case No. 75-H-1635 Howard vs. Owens-Corning Fiberglass Corporation, et al United States District Court for the Eastern District of Sherman Division Case No. S-7S-58-CA Status: dismissed Texas - Hughes vs. Keene Industrial Insulation, et al County of Philadelphia, Court of Common Pleas Case No. 3451 Huthmacher vs. Keene Industrial Insulation, et al County of Philadelphia, Court of Common Please Case-No. 3457 Hutson vs. Armstrong Cork Company, et al United States District Court for the Southern District of Florida, Miami Division Case No. 76-53-Civ-CA Jacomino vs. Johns-Manville Corporation, et al Court of Common Pleas, Philadelphia County Case No. 1507 Jeane vs. Fibreboard Corporation, et al Unitea States District Court for the Eastern District of Texas - Beaumont Division Case No. B-74-337-CA Johnson vs. Fibreboard Paper Products Corporation, et al United States District Court for the Eastern District of Texas - Beaumont Division Case No. B-74-124-CA Status: settled Joyce vs. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 4019 Joyner vs. Armstrong Cork Company, et al United States District Court for the Southern District of Florida, Miami Division Case No. 75-2581 Karjala vs. Fibreboard Paper Products Corporation, et al United States District Court for the District of Minnesota - Fifth Division Case No. 5-71-18 Status: dismissed Kearns vs. Combustion Engineering, Inc., et al United States District Court for the Northern District of Ohio - Eastern Division Case No. C73-70 Kendall vs. Fibreboard Paper Products Corporation, et al Superior Court of the State of California in and for the County of San Francisco Case No. 704-023 City and Kirchner vs. Standard Asbestos Manufacturing & Insulating Co., et al Case No. '75-H-863 Kyburz vs. Standard Asbestos Manufacturing and Insulating Company, et al United States District Court for the Southern District of Texas - Houston Division Case No. 75-H-863 LaGrappe vs. Fibreboard Corporation, et al Unitec States District Court for the Eastern District of Texas - Beaumont Division Case No. B-74-66-CA Status: settled Landre vs. Johns-Manville Sales Corporation, et al Superior Court of California, County of Alameda Case No. 449876-8 Laurie ys. Keene Industrial Insulation, et al Court of Common Pleas of Philadelphia County Case No. 681 Leava ys. Johns-Manville Products Corp. , et al The Circuit Court of Jackson County, Missouri a; Kansas City Case No. CB75-4160 Lewis vs. GAF Corporation, et al Court of Common Pleas, Philadelphia County Case No. 12969 Lombardo vs. Keene Industrial Insulation, ct al. County of Philadelphia, Court of Common Pleas Case No. 3448 Lope2 vs. Armstrong Cork Company, et al. United States District Court for the Southern District of Florida Miami Division Case No. 75-1365 CIV-JLK Lucera vs. Keene Industrial Insulation, et al. Court of Common Pleas of Philadelphia County Case No 683 Luker vs. Johns-flanville International Corporation, et al. United States District Court for the Southern District oTexas - Houston Division Case No. 75-H-342 Lyons vs. G. & W. Corson Inc. , et al. Court of Common Pie.is of Delaware County, Pennsylvania Case No. 75-6065 McAndrew vs. Keene Industrial Insulation, et al. Court of Common Pleas of Philadelphia County Case No. 2192 McClain vs. G. & W. H. Corson Inc., et al. Court ox Common Pleas oi Delaware County,Pennsylvania Case No. 75-6065 McCoy vs. Fibreboard Paper Products, et al. Circuit Court of Jackson County, Missouri at Kansas City Case No. CV76-1377 Civil E McDaniel vs. Johns-Hanville Products Corporation, et al. United States District Court for the Eastern District of Texas - . Beaumont Division Case No. 6967 Status: settled McGinnis vs. Combustion Engineering, Inc., et al. United States District Court for the Northern District of Ohio - Eastern Division Case No. C-74-1077 McGlinn vs. G. & W. H. Corson Inc., et al. Court of Common Pleas of Delaware County,Pennsylvania Case No. 75-6065 McGovern vs. Keene Industrial Insulation, et al. Court of Common Pleas of Philadelphia County Case No. 1752 McGurk vs. Keene Industrial Insulation, et al. Court of Common Pleas of Philadelphia County Case No. 1748 McKee vs. Johns-Mar.ville Corporation, et al. State of New York Supreme Court, County of Erie Case No. McKimraie vs. Cor.bustlon Engineering, et al. United States District Court for the Northern District of Ohio - Eastern Division Case No. C-76-130 McLaughlin vs. Combustion Engineering, Inc., et al. United States District Court for the Northern District of Ohio - Eastern Division Case No. C-75-377 McLaughlin vs. Combustion Engineering, Inc., et al. United States District Court for the Northern District of Ohio - Eastern Division Case No. C-74-923 HcWeeley vs. Combustion Engineering, Inc., et al. United States District Court for the Northern District of Ohio - Eastern Division McPoyle vs. Keene Industrial Insulation, et al. Court of common Pleas of Philadelphia County Case No. 4021 Macaluso vs. Keene Industrial Insulation, et al. County of Philadelphia, Court of Common Pleas Case No. 3462 Mackinson vs. Keene Industrial Insulation, et al. Court of Common Pleas of Philadelphia County Case No. 1747 Matthews vs. Fibreboard Paper Products Corporation, et al. United States District Court for the Eastern District of Texas Beaumont Division Case NO. B-73-CA-309 Status: settled - Measor vs. Combustion Engineering, Inc., et al. United States District Court for"the Northern District of Ohio - Eastern Division Case Nol C73-238 Mellot vs. Johns-Manville Products Corporation, et al. United States District Court for the Northern District of Ohio - Eastern Division Case Mo. C-75-1058 Missanelli vs. Keene Industrial Insulation, et al. Court of Common Pleas of Philadelphia County Case No. 1751 Mitchell vs. United Asbestos Corporation, et al. State of Illinois - Circuit Court of the Third Judicial Circuit - Madison County Case No. 74-L-676 Moran vs. G. & V?. Corson Inc., et al. Court of Common Pleas of Delaware County, Pennsylvania Case No. 1699 Morris vs, Johns-Manville Products Corporation, et al. District Court m and for the County of 3oulder, State of Colorado Case No. 76-1504-1 Status: settled Morrison vs. Fibreboard Paper Products Corporation, et al. Superior Court of the State of California in ar.d for the City County of San Francisco Case No. 701 44$ and Muntean vs. Combustion Engineering, Inc., et al. United States District Court for the Northern District of Ohio - Eastern Division ". . Case No. C73-199 Murphy vs. Combustion Engineering, Inc., et al. United States District Court forthe Northern District of Ohio - Eastern Division Case No. C-75-453 Nave vs. Combustion Engineering, Inc., et al. State of Tennessee, Circuit Court of Knox County, Division III Case No. 3-491-75 Navo vs. Keene Industrial Insulation, et al. County of Philadelphia, Court of Common Pleas Case NO. 3461 Nolan vs. Johns-Manville Asbestos & Magnesia Materials Company, et al. Circuit Court of Cook County, Illinois Case No. 75 L 8672 Overstreet vs. Keene Industrial Insulation, et al. Court of Common Pleas of Philadelphia County Case No. 412,413 Palermo vs. Fibreboard United States District Beaumont Division Case No. B-75-192-CA Paper Court Products Corporation, et for the Eastern District al. ofTexas - Pappalardo vs. Keene Industrial Insulation, et al. Coivity of Philadelphia, Court of Common Pleas Case No. 3454 Phelps vs. Combustion Engineering, et al. United States District Court for the Eastern District of Illinois Case No. 76-4-012 Plitt vs. Standard Asbestos Manufacturing and Insulating Company, et al. United States District Court for the Southern District of Texas Houston Division Case No. 75-H-906 Poore vs. G. & W. H. Corson Inc., et al. Court of Common Pleas of Delaware County, Case No. 75-6065 f 1 Pennsylvania Potter vs. Fibreboard Paper Products United States District Court for the Beaumont Division Case No. 6329 Status: settled Corporation, et al. Eastern District of Texas - Pyles vs. Keene Industrial Insulation, et al. Court of Common Pleas of Philadelphia County Case No. 1058 Quattelbaum vs. Combustion Engineering, Inc., et al. Unitac States District Court for the District of South Carolina, Charleston Division Case No. 76-1239 Rabincwitz vs. Keene Industrial Insulation, et al Court of Camcn Pleas of Philadelphia County Case No. 677 Reinhardt vs. Johns-Manville Products Corporation, et al Circuit Court, Wayne County, Michigan Case No. 76-614893 Rendall vs. Keene Industrial Insulation, et al County of Philadelphia, Court of Cannon Pleas Case No. 3450 Riccivs. Canbustion Engineering, Inc., et al United States District Court for the Northern District of Ohio - Eastern Division Case No. C72-507 Richards vs. Keene Industrial Insulation, et al Court of Ccnrcn Pleas of Philadelphia Canty Case No. 1753 Rpderman vs. Combustion Engineering, Inc., et al United States District Court for the Northern District of Ohio - Eastern Division Case No. C72-390 Rcrano vs. Keene Industrial Insulation, et al Court of Ccnmon Pleas of Philariephia County Case No. 921 Rosenouest vs. GBF, et al United States District Court, Southern District of Texas - Houston Division Case No. 76-H-115 Roswunn vs. Philip Carev Manufacturing Corporation, et al Circuit Court of Jackson County, Missouri Case No. CV76-2631 Ririio vs. Keene Industrial Insulation, et al Canty of Philadelphia, Court of Cannon Pleas Case No. 3456 Russo vs. Keene Industrial Insulation, et al Court, of rnrmon Pleas nr Phi 1 ariplpnia County Case No. 4026 Samohod vs. G. & W. H. Corson Inc., et al Court of Coition Pleas of Delaware County, Pennsylvania Case No. 76-6065 Sandoval vs. Fibreboard Paper Products Corooration, et al Superior Court of California, County of San Francisco Case No. 689-959 Sedlock vs. Ccrctoustion Engineering, Inc., et al United States District Court for the Northern District of Ohio - Eastern Divisim Case No. C72-395 Saavicchio vs. G. & W. H. Corson Inc., et al Court of Carren Pleas of Delaware County, Pennsylvania Case No. 75-6065 Shaw vs. Keene Industrial Insulation, et al County of Philadelphia, Court of Camcn Pleas Case No. 3453 Siimiler vs. Keene Industrial Insulation, et al Court of Canon Pleas of Philadelphia County Case No. 685 Snell vs: Keene Industrial Insulation, et al County of Philadelphia, Court of Canton Pleas Case No. 3460 Speer vs. Fibreboard Paper Products Corporation, et al Superior Court of the State of California in and for the City and County of San Francisco Case No. 695-157 Spell vs. Fibreboard Paper Products Corporation, et al United States District Court for the Eastern District of Texas - Beaumont Division Case No. E-71-81-CA Status: Settled Starnes vs. GAF, et al United States District Court for the Northern District of Ohio - Eastern Division Case No. C-76-46 Starnes vs. Carbusticn Encinesrinq, Inc., et al United States District Court for the Eastern District of Tennessee Case No. CIV-2-75-122 Steele vs. Car-bustlon Engineering, Inc., et al United States District Court for "the Northern District of Ohio - Eastern Division Case No. C-75-359 Stewart vs. Fibreboard Paper Products Corporation, et al Superior Court cf the State of California m and for the City and County of San Francisco Case No. 695-921 Strickland vs. Johns-Manville International Corooration, et al United States District Court for the Southern Division of Texas - Houston Division Case No. 75-H-492 Strickland vs. Fibreboard Parer Products Corporation, et al Superior Cnurr of rip of rjhfnrua m'ann for me City and County of San Francisco Case No. 677-527 Sutcliffe vs. Keene Industrial Insulation, et al Court of Corrcn Pleas of Philsdeipma County Case No. 4015 Talarioo vs. Keene Industrial Insulation, et al Court of Center. Pleas of Pniladephia County Case No. 1055 Talbot vs. Fibreboard Paper Products Corporation, et al United States District Court, Eastern District o Texas - Beamont Division Case No. B-75-391-CA Tannenbaum vs. Keene Industrial Insulation, et al Pranft of rrnrm-m Plgag of Philadelphia O-nm-fy Case No. 678 Taylor vs. Combustion Engineering, Inc., et al United States District Court for the District of South Carolina - Charleston Division Case No. 76-1208 Taylor vs. Carbustion Engineering, Inc., et al United States District Court far the District of South Carolina - Charleston Division Case No. 76-1241 Thanpson vs. Fibreboard Paper Products Corporation, et al Superior Court of tne State of California in and for the City and County of San Francisco Case No. 698-870 Tillman vs, G. & W. H. Corson Inc., et al Court of Cauiui Pleas of Delaware County, Pennsylvania Case No. 75-6065 Trahan vs. Standard Asbestos Manufacturing and Insulating Company, et al United States District Court for the Southern District of Texas - Houston Division Case NO. 75-H-905 Treadway vs. Carbustion Engineering, Inc., et al Circuit Court, Division 1,'kdck County, Knoxville, Tennessee Case NO. 1-528-75 Tricoski vs. Keene Industrial Insulation, et al County of Philadelphia, Court of Cannon Pleas Case No. 3449 Turci vs. Keene Industrial Insulation, et al Court- of Q-rrm-m ?1ms nr Phi larielpnia County Case No. 2191 Tyler vs. Keene Industrial Insulation, et al Court- of Crrmnn PI Pag of Phi ladelphia County Case No. 2193 Valiska vs. Johns-Manville Products Corporation, et al Circuit Court of Cock County, Illinois Case No. 76 L 2913 Velasquez vs. Fibreboard Paper Products Corporation, et al Superior Court- of ralirnraia, County of San' Francisco Case No. 681-172 Viator vs. Standard Asbestos Manufacturing and Insulating Ccroanv, et al United States District Court for the Southern District of Texas - Houston Division Case No. 75-H-867 Vice vs. Fibreboard Corporation, et al United States District Court for the Eastern District of Texas - Eeaumont Division Case NO. B-76-115-CA Wadlev vs, Fibreboard Paper Products Corporation, et al Superior Court cf the State of California in ana for the City and County of San Francisco Case No. 697-762 Walters vs. Keene Industrial Insulation, et al Court of Ccrrrcn Pleas cf Philadepnia County Case No. 4018 Warrington vs. Keene Industrial Insulation, et al Court of Cannon Pleas of Philadelphia County Case No. 679 Watts vs. Keene Industrial Insulation, et al Court of Comm Pleas of Philadelphia County Case No. 4025 Welker vs. Keene Industrial Insulation, et al <Vmr-t- nf rnnnon Plaag of Philadelphia Pruinty Case No. 1750 Wesberry vs. Standard Asbestos Manufacturing and Insulating Catpany, et al United States District Court for the Southern District of Texas - Houston Division Case No. 75-H-865 White vs. Combustion Engineering, Inc., et al Circuit Court for Knox County, Tennessee Case No. 3-672-75 . Wiater vs. Keene Industrial Insulation, et al Court of Carman Pleas of Philadelphia County Case No. 1754 Wimberly vs. Fibreboard Corporation, et al United States District Court for the Eastern District of Texas - Beaumont Division Case No. B-74-224-CA Status: settled Woods vs. Keene Industrial Insulation, et al Court of Caanon Pleas of Philadelphia County Case No. 682 Zeldin vs. Keene Industrial Insulation, et al Court of Cannon Pleas of Philadelphia County Case No. 920 Gause vs. Combustion Engineering, Inc., et al Greenville County Court or Carman Pleas, Greenville, South Carolina Case No. Thornton vs. Johns-Manville Corporation, et al Circuit Court of the City of Portsnouth, Virginia Case No. L-76-590 Dgnarest vs. Johns-Manville Sales Corporation, et al Circuit Court, Wayne County, Michigan Case No. 76-626429-NP Queerer vs. Combustion Engineering, Inc., et al Circuit Court for Knox County, Tennessee Case No. 3-442-76 Nave, Bruce Alfred vs. Combustion Engineering, Inc., et al Circuit Court for Knox County, Tennessee Case No. 2-443-76 Adams vs. Carbustion Engineering, Inc., et al Court of Gxmcn Pleas for Greenville County, S. C. Case No. Adams, Pauline vs. Carhustion Sncineerina. Inc , et al Court of Cannon Pleas for Greenville County, South Carolina Case No. Hatfield vs. Canbustion Engineering, Inc., et al Circuit Court, Knox County, Knoxville, Tennessee Case No. 2-453-76 Rogers vs. Canbustion Engineering, Inc., et al Circuit Court, Knox County, Knoxville, Tennessee Case No. 1-456-76 Snith vs. Johns-Manville Corporation, et al Circuit Court of the City orPortsncuth, Virginia Case No. L-76-658 Starnes, Billy Joe vs. Combustion Engineering, Inc., et al United States District Court for the Northern District of Ohio, Eastern Division Case No. C-76-882 Fleming vs. Fihrehoard Paper Products Corporation, et al Superior Court of California, City anri County nf San Prarv-iann Case No. 710-899 Grice vs. Canbustion Engineering, Inc., et al United States District Court for the Northern District of Ohio, Eastern Division Case No. C-76-883 Sijpson vs. Omens Coming Fiberclas Corporation, et al U. S. District Court, Southern District of Texas, Houston Division Case No. 76-H-1499 Bartholomew vs. Canbustion Engineering, Inc., et al Court of Ccnmon Pleas, County oz Greenville, South Carolina Case No. Bolten vs. Philip Carev Manufacturing, et al Circuit Court of Jackson County, Missouri Case No. CV76-3764 Bumgardner vs. Canbustion Engineering, Inc., et al Court of Carman Pleas, County of Greenville, South Carolina Case No. Heath vs. Combustion Engineering, Inc., et al Court of Cannon Pleas, County of Greenville, S. C. Case No. Kidd vs. Combustion Engineering, Inc., et al Court of Carman Pleas, County of Greenville, S. C. Case No. Koar.tz vs. Combustion Engineering, Inc., et al Court of Cannon Pleas, County of Greenville, S. C. Case No. Glover vs. Johns-Manville Corporation, et al Circuit Court of the City of Portsooth, Virginia Case No. L-76-747 Lauderback vs. Johns-Manville Sales Corporation, et al United States District Court for the Pastern District of Texas, Marshall Division Case No. M-76-69-CA Barnett vs. Combustion Engineering, Inc., et al Court of Ccnmcn Pleas for Greenville County, S. C. Case No. Davis vs. Caifeustion Engineering, Inc., et al Court of Caiman Pleas for Greenville, S. C. Case No. Murray vs. Ccntoustion Engineering, Inc., et al Court of Cannon Pleas far Charleston County, S. C. Case No. Smith vs. Ccntoustion Engineering, Inc., et al Court of Camcn Pleas for AilcenCounty, S. C. Case No. Turner vs. Ccntoustion Engineering, Inc., et al Court of Cannon Pleas for Greenville County, S. C. Case No. Evelyn White vs. Canbustion Engineering, Inc., et al Court of Canaan Pleas for Greenville, S. C. Case No. John E. White vs. Combustion Engineering, Inc., et al Court of Common Pleas for Greenville County, S.C. Case No. Ward vs. Johns-Manville Products Corporation, et al U.S. District Court for the Eastern District of Texas, Marshall Division Case No. M-76-73-CA Sterken vs. Owens-Corning Fiberqlas Corporation, et al United States District Court, Southern District of Texas, Galveston Division Case No. 76-G-lll Bouchelle vs. Combustion Engineering, Inc., et al Court of Common Pleas for Aiken County, S. C. Case No. Norris vs. Combustion Engineering, Inc., et al United States District Court for the District of South Carolina, Charleston Division Case No. 76-1901 Bazemore vs. Johns-Manville Corporation, et al Circuit Court of the City of Portsmouth, Virginia Case No. L-76-883 Bouchelle vs. Combustion Engineering, Inc., et al Court of Common Pleas for Aiken County, S. C. Case No. Call vs. Combustion Engineering, Inc., et al Court o Common Pleas for the County of Charleston, S. C. Case No. Fearn vs. Forty-Eight Insulation, Inc., et al Court of Common Pleas of Allegheny County, Pennsylvania Case No. GD76-23408 Hershman vs. Johns-Manville Corporation, et al Circuit Court of the City of Norfolk, Virginia Case No. L76-1706 Johnson, Marv E. vs. GAF Corporation Superior Court of New Jersey', Law Division, Hudson Coupty Case No. Marzolf vs. Johns-Manville Corporation, et al State of New York Supreme Court, County of Erie Case No. Oman vs. Johns-Manville Corporation, et al Circuit Court of the City of Newoort News Case No. 2930-S Sedlock, Joseph E. vs. Combustion Engineering, Inc., et al United States" District Court for the Northern District of Ohio, Eastern Division Case No. C-76-1098 Stewart, Evelyn vs. Fibreboard Paper Products Corporation, et al Superior Court of the State of California for the City and County of San Francisco Case No. 713-284