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IN RE: BALTIMORE CITY * IN THE ASBESTOS LITIGATION * CIRCUIT COURT * FOR BALTIMORE CITY * Consolidated No. 24X000003 81 Jfc sfic * * sj CHARLES CARGILE, et al. Plaintiffs * November 2001 Trial Group * Judge Richard T. Rombro V. Lead Case No. 24X00000258 ACandS. Inc., et al. Defendants * * ***#* * :{ CASE AFFECTED: & JOSE RONQUILLO Case No. 24X99001247 DEFENDANT MAREMONT CORPORATION'S RESPONSES TO PLAINTIFFS' INTERROGATORIES * * Defendant Maremont Corporation ("Maremont"), by its attorneys Church & Houff, P.A., hereby objects and responds as follows to Interrogatories of Plaintiffs Propounded To Defendants ("plaintiffs' interrogatories"). PRELIMINARY STATEMENT Maremont, One Noblitt Plaza, Columbus, Indiana 47201, incorporated in the State of Delaware, is primarily engaged in the manufacture and distribution of automotive exhaust systems, shock absorbers, MacPherson struts and related hardware and parts. On or about December 15, 1953. Maremont purchased the assets of a company in Paulding, Ohio known as Grizzly Manufacturing Company ("Grizzly"). Grizzly manufactured friction products, including brake linings, clutch facings and lined brake shoes. Maremont sold this division on or about June 30, 1977, to Nutum Corporation, a wholly-owned subsidiary of Turner and Newall, Ltd., except for a 20% interest, which was retained by Maremont. The remaining 20% interest was sold to Nutum on or about April 23, 1982. Soon after the purchase of Grizzly by Nutum, Nutum closed the Paulding facility and transferred the operation to a facility in Smithville, Tennessee. At this time, Maremont does not have in its employ any person or persons who previously worked at the Paulding facility. Furthermore, it appears that very few Maremont employees continued employment with Nutum. Very little documentation exists within Maremont concerning the Paulding, Ohio operation. Any documentation pertaining to the site that was not discarded by Nutum upon its move to Smithville would presumably be under the custody and control of Nutum Corporation, now known as Ferodo. GENERAL OBJECTIONS 1. Maremont objects to plaintiffs' interrogatories on the grounds that they are overbroad, vague, unduly burdensome, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Plaintiffs' interrogatories have been propounded indiscriminately to every defendant without any attempt to tailor them to any individual defendant. Without waiving this objection and subject to the objections that follow, Maremont is providing information in response to plaintiffs' interrogatories. 2. Maremont objects to plaintiffs' interrogatories on the grounds that they improperly attempt to shift the burden of establishing product identification and causation from plaintiffs to Maremont. 3. Maremont objects to plaintiffs' interrogatories to the extent they seek information relating to sales of asbestos-containing products by Maremont to any entity or entities other than entities specifically identified by plaintiffs as having been in the chain of distribution of an asbestos-containing product from Maremont to plaintiffs or plaintiffs' employers. 4. Maremont objects to plaintiffs' interrogatories to the extent they seek information protected from discovery by the attorney-client privilege or the work product doctrine. 5. Maremont objects to plaintiffs' interrogatories to the extent they seek disclosure of information generated by persons other than Maremont that has come into the possession of Maremont's counsel during the course of discovery and trial preparation in asbestos-related litigation. 6. Maremont objects to plaintiffs' interrogatories to the extent they seek information relating to products of other companies. 7. Maremont objects to plaintiffs' interrogatories to the extent they seek information subsequent to Maremont ceasing production of any asbestos-containing product. 8. Maremont objects to plaintiffs' interrogatories to the extent they seek information that is not under Maremont's custody or control or which is within the public domain or otherwise equally available to plaintiffs as to Maremont. 9. Many of the events about which plaintiffs' interrogatories inquire occurred forty or more years ago. Accordingly, each response that follows is qualified by the fact that through the passage of time, information and documents that once existed may no longer be available. 10. Maremont does not concede that any of its responses to plaintiffs' interrogatories are or will be admissible evidence at a trial of this action, and Maremont does not waive any objection, on any ground, whether or not asserted herein, to the use of any such answer at trial. 11. To the extent applicable, Maremont incorporates by reference each of its objections in each response that follows and reserves the right to amend or supplement its responses to plaintiffs' interrogatories to reflect information which may become available to it up until the time of trial. OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS 12. Maremont objects to the instructions and definitions supplied by plaintiffs with regard to these interrogatories on the grounds that the instructions and definitions are overly broad, vague, and often inconsistent with the normal usage and meaning of such words. These instructions and definitions constitute an unreasonable expansion of the interrogatories themselves. Maremont has therefore responded to the interrogatories in the manner consistent with a normal understanding of the language used in the response and to the extent necessary to fairly and fully respond to the interrogatories. 13. Maremont objects to plaintiffs' definitions on the grounds that the terms "asbestoscontaining" and "asbestos products" are so broad, vague, ambiguous, uncertain, and calls for speculation, that Maremont cannot determine the precise nature of the information sought, and therefore cannot respond without an unreasonable risk of inadvertently providing a misleading, confusing, inaccurate, or incomplete response. 14. Maremont objects to plaintiffs' instructions and definitions to the extent these instructions and definitions request Maremont to make any inquiry beyond that which is required by the Maryland Rules of Procedure or to the extent they seek to include documents not within Maremont's custody or control. INTERROGATORIES 1. State your correct corporate name, state of incorporation, date of incorporation, address ofprincipal place ofbusiness, the name ofall predecessor corporations under which you have carried on business and the years during which you carried on business under those names, and whether you carry on a regular business in the State of Maryland. RESPONSE TO INTERROGATORY NO. 1: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states: Maremont Corporation, and refers plaintiffs to the Preliminary Statement preceding these responses. Maremont further states that it has insufficient knowledge or belief to respond to this interrogatory. 2. If a report regarding the Occurrence was made in the ordinary course of business by you, by an employee of yours, or by someone who then gave it to you or told you about it, state the name and address ofthe person who made the report, the date thereof and in whose custody it is. RESPONSE TO INTERROGATORY NO. 2: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory. 3. Set forth all types of products you manufactured, sold, supplied and/or installed from 1935 through 1985 that contained any asbestos-containing materials or with which such materials were supplied or specified, stating as to each product what asbestos-containing materials were contained within the product, supplied with the product, or specified for the product; the trade or brand name of each asbestos-containing product; the dates of each such product; the fiber-type and percentage content of asbestos in the material incorporated, supplied or specified, all ingredients of each asbestos-containing product and a description of each product's packaging and intended uses; identify all persons with personal knowledge of the material facts responsive to this interrogatory, and identify all documents with material information responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 3: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont refers plaintiffs to the Preliminary Statement preceding these responses and Maremont's responses to plaintiffs' request for documents. Maremont states that the products were intended to be used as replacement parts for automotive vehicles. Maremont's former subsidiary, Grizzly, used trade names such as Grizzly, Ultra, Leland, Hyper, All-in-One, Over-the-Counter, Saftigrip and Silvertip, X-T Woven, Syncro, SS Metallic and Tru-Gard. Maremont does not know the percentage of asbestos put in each product. Based upon available information, components of at least a portion of such products were: Asbestos, 5R Asbestos, 6D Asbestos, 7D Asbestos, 7M Asbestos, 8T Barium ferrite Barytes, Bleached Barytes, Unbleached Carbon, Black Cashew Particles Cast Iron Dust Emergy Flour Hexamethylenetetramine Lime Linseed Oil Mineral Spirits Oxide, Brown Oxide, Red Resin, Bakelite 5095 Resin, Borden 774-113 Resin Monsanto 6823 Resin, Schenectady 868 Resin, Varcum 6019A Rubber Dust Seacoal Silica Sulfur Talc Boxes containing such products were either white or brown cardboard boxes. The boxes would either have the name Grizzly on the outside of the box or no name or the name of the customer, depending on the arrangement with the customer. It is believed that the product provided to Sears, prior to 1973, was in a plain white carton with a label. From 1973 to 1976 there was a running change to the Over-The-Counter carton with a man working on a car. All-InOne products were plain white with a label and a caution. From 1976 to 1977 there was a change to Over-The-Counter products with a stop sign and to the All-In-One products to a stop light on the carton and on brochures. The colors red and black were also contained on the product to connote the stoplight. Maremont states that much of the information sought by these interrogatories has been accumulated over time but not for purposes of responding to these interrogatories. It is not possible to now identify each person who, at some time, may have provided information that is now being used to answer this interrogatory. No single employee, officer, or agent of the company has direct knowledge of the documents and information necessary to supply each and every response. The person signing these interrogatories does so to satisfy whatever requirements may exist under the applicable Rules of Civil Procedure. The person does not, however, have direct knowledge regarding any specific answer, but is informed that the review of the documents and discussions referred to above support the answers based upon the information available as to the date of signature. Maremont has insufficient knowledge or belief to respond further to this interrogatory. 4. State whether you have within your possession or control photographs, schematic drawings, diagrams, formulas, and/or specifications of any product described in your Answer to Interrogatory No. 3. If so, identify each such photograph, schematic drawing, diagram, formula or specification. RESPONSE TO INTERROGATORY NO. 4: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 5. State whether, prior to 1985, you belonged to any of the organizations listed below, and, if so, as to each such organization to which you belonged, list the inclusive dates you were a member, the type of membership, and the date or dates on which you attended meetings, seminars or symposia involving that organization and having as a subject the potential health hazards ofexposure to asbestos; identify all persons with personal knowledge of the material facts responsive to this interrogatory, and identify all documents with material information responsive to this interrogatory. a. National Safety Council b. American Conference of Governmental Industrial Hygienists (ACGIH); c. Industrial Health Foundation or Industrial Hygiene Foundation (IHF); d. Air Hygiene Foundation; e. American Industrial Hygiene Association; f. American Ceramic Society; g. Asbestos Textile Institute; h. Refractories Institute; i. Fluid Sealing Association; j. Asbestos Information Association of North America; k. Friction Materials Standards Institute; l. International Association of Walls and Ceiling Contractors; m. Gypsum Association RESPONSE TO INTERROGATORY NO. 5: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad, unduly burdensome, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it knows it had associations with the Asbestos Information Association, Automobile Service Industry Association and the Friction Materials Standards Institute. Maremont does not possess sufficient information to respond further to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs request for documents. 6. State whether, prior to 1985, you belonged to any trade organization, industrial hygiene organization, medical organization, insurance organization, or safety organization not listed in die preceding Interrogatory, and, if so, as to each such organization to which you belonged, list the inclusive dates you were a member, the type of membership, and the date or dates on which you attended meetings, seminars or symposia involving that organization and having as a subject the potential health hazards of exposure to asbestos; identify all persons with personal knowledge ofthe material facts responsive to this interrogatory, and identify all documents with material information responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 6: See response to Interrogatory No. 5. 7. Identify all tests, experiments, research or studies performed prior to 1985 by you, on your behalf or with your knowledge in regard to the potential health hazards of exposure to asbestos; set forth all material facts in support of this answer, identify all persons with personal knowledge of the material facts responsive to this interrogatory, and identify all documents with material information responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 7: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs' to Maremont's responses to plaintiffs' request for documents. 8. State whether, prior to 1985, you maintained a medical department or industrial hygiene department; as to any such department you maintained, identify all persons with personal knowledge of the material facts responsive to this interrogatory, and identify: a. its location or locations; b. the inclusive dates from 1935 through 1985 when it was maintained; c. the number and identity of doctors in the medical department at each location, or the number and identity of industrial hygienists at each location; d. each file you maintained prior to 9185, further identified by the department and location where you maintained it, which contained documents regarding or referring to: i. exposure to asbestos; ii. potential health effects from exposure to asbestos; iii. your industrial hygiene practices or protocols regarding the prevention of exposure to asbestos; iv. any medical standards or protocols established by your medical department regarding the treatment of individuals for symptoms related to exposure to asbestos; e. each document maintained in a manner other than in a file, including any published medical, industrial hygiene or other scientific article, which you maintained prior to 1985, further identified by the department and location where you maintained it, regarding or referring to: l. exposure to asbestos; II. potential health effects from exposure to asbestos; iii. your industrial hygiene practices or protocols regarding the prevention of exposure to asbestos; iv. any medical standards or protocols established by your medical department regarding the treatment of individuals for symptoms related to exposure to asbestos. RESPONSE TO INTERROGATORY NO. 8: See general objections. Maremont also objects to this interrogatory on the grounds that it is vague and ambiguous, overbroad and unduly burdensome, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont answers as follows: it is believed that a physician (name unknown) was retained at the Paulding, Ohio facility for the purposes of general examinations and first-aid for two days per week as of an unknown time in 1969. Other physicians, the names of which are also not known by Maremont, are believed to have visited the Paulding, Ohio and Nashville, Tennessee facilities on or after 1969 to take x-rays and conduct other tests of plant personnel. Maremont also employed an industrial hygienist, Debbie Henderson, at the Paulding facility. Maremont states that it has insufficient icnowledge or belief to respond further to this interrogatory and refers plaintiffs' to Maremont's responses to plaintiffs' request for documents. 9. Name the manufacturers, distributors, sellers and suppliers of any asbestoscontaining materials that were incorporated in or supplied with any of your products from 1935 through 1985, and set forth as to each such manufacturer, distributor, seller and supplier, the products for which such material was intended; the material it provided to you, the trade or brand name of the material it provided to you, when it provided the material to you, and the fiber-type and percentage content of asbestos in the material it provided to you; identify all persons with personal knowledge of the material facts responsive to this interrogatory, and identify all documents with material information responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 9: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds as follows: Maremont marketed and distributed primarily products of its own manufacture. However, for low-volume items, Maremont occasionally bought disc pads from other brake lining manufacturers and other products and relabeled them. The major source of supply of disc pads was Lear Siegler, Inc. and Fras-le. Maremont sold these products under its own trade names. Maremont states that it has insufficient knowledge or belief to respond further to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 10. State whether you gave any warnings, notices, instructions, or other information to any person or entity concerning asbestos, potential health risks from exposure to asbestos, or ways to prevent exposure to asbestos, at any time from 1935 through 1985, and, as to each such warning, notice, instruction or item of information, set forth its substance, who gave it, and how. when, where, and to whom you gave it; identify all persons with personal knowledge of the material facts responsive to this interrogatory, and identify all documents with material information responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 10; See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds as follows: based upon available information, the appropriate prescribed OSHA warning accompanied brake products. The exact wording of each warning read: Caution Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos May Cause Serious Bodily Harm Such warning appeared on the box containing the product or inside of the box. Maremont refers plaintiffs to Maremont's responses to plaintiffs' request for documents and states that it has insufficient knowledge or belief to respond further to this interrogatory. 11. State whether, on any premises owned or possessed by you from 1935 through 1985, you instructed, directed or trained your employees or employees of independent contractors in the safe handling and use of asbestos-containing products and/or the avoidance of exposure to asbestos dust or fibers. If so, state when you did so, how you did so and to whom, at which premises you did so, and your employees responsible for doing so; identify all persons with personal knowledge of the material facts responsive to this interrogatory, and identify all documents with material information responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 11: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont refers plaintiffs to its response to Interrogatory No. 8. Maremont has insufficient knowledge or belief to respond further to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 12. State whether, on any premises owned or possessed by you from 1935 through 1985, you monitored or screened your employees or employees ofindependent contractors for the presence or absence of asbestosis or other lung disease, or for cancer. If so, state when you did so, how you did so and to whom, at which premises you did so, and your employees responsible for doing so; identify all persons with personal knowledge ofthe material facts responsive to this interrogatory, and identify all documents with material information responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 12: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 13. State whether, in the course of your business, you have performed or have had performed for you, or there have been performed, any air monitoring or other sampling studies of asbestos dust or fibers generated either on your premises or from any asbestos-containing product you manufactured, sold, supplied and/or installed and, if so, as to each study, set forth who did the study, when it was done, where it was done and the results thereof; identify all persons with personal knowledge of the material facts responsive to this interrogatory, and identify all documents with material information responsive to this interrogatory, including the air monitoring and/or bulk sampling studies. RESPONSE TO INTERROGATORY NO. 13: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 14. Set forth all information received at any time prior to 1985 by any of your officers, any doctors in your medical department, any of your chemists or industrial hygienists, or any of your employees or agents, including but not limited to those who were a liaison with, served on, or attended meetings of any trade organization, medical organization, industrial hygiene organization, safety organization, chemical organization, or refinery organization, concerning the capability of exposure to asbestos to cause or contribute to the development of asbestosis, cancer, or other diseases or illnesses; state all sources and dates of such information, identify all persons with personal knowledge of the material facts responsive to this interrogatory, and identify all documents with material information, including any written sources of information requested above, that are responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 14: See general objections. Maremont also objects to this interrogatory on the grounds that it is vague and ambiguous, overbroad and unduly burdensome, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont refers plaintiffs to Maremont's responses to plaintiffs' document request and states that it has insufficient knowledge or belief to respond to this interrogatory. 15. State whether any person or entity gave you any warnings, notices, instructions, or other information concerning asbestos, potential health risks from exposure to asbestos, or ways to prevent exposure to asbestos, at any time from 1935 through 1985, and, as to each such warning, notice, instruction or item of information, set forth its substance, who received it, and how, when, where, and from whom you received it; identify all persons with personal knowledge of the material facts responsive to this interrogatory, and identify all documents with material information responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 15: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 16. State whether, prior to 1985, anyone filed a workers' compensation claim or other claim against you based upon the development of asbestosis, cancer, mesothelioma or any other medical condition alleged to be caused by exposure to asbestos, and, if so, as to each such claim, state who filed the claim, the asbestos-related condition upon which the claim was based, when it was filed, where it was filed, the claim number, and the claim's disposition; identify all documents in your possession with material information responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 16: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states to the best of its knowledge and belief based on investigative efforts that are ongoing, no. 17. State whether, prior to 1985, anyone filed a civil action against you based upon the development of asbestosis, cancer, mesothelioma or any other medical condition alleged to be caused by exposure to asbestos, and, if so, as to each such civil action, state who filed the civil action, the asbestos-related condition upon which the civil action was based, when it was filed, where it was filed, the civil action number, and the civil action's disposition; identify all documents in your possession with material information responsive to this interrogatory. RESPONSE TO INTERROGATORY NO. 17: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: yes, and will provide a list of first ten such actions upon receipt of an appropriate request. Maremont has insufficient knowledge or belief to respond further to this interrogatory. 18. Identify each person whom you expect to call as an expert witness at trial, state the subject matter on which the expert is expected to testify, state the substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion, and product any written report made by the expert concerning those findings and opinions. RESPONSE TO INTERROGATORY NO. 18: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities. Subject to the general and specific objections, and without waiving same, Maremont has not determined yet what expert witnesses it may call at trial. Maremont will supplement this response at such time, or in accordance with the Court's scheduling order or agreement between the parties. 19. If any person carrying on an insurance business might be liable to satisfy part or all of a judgment that might be entered in this action or to indemnify or reimburse for payments made to satisfy the judgment, identify that person, state the applicable policy limits of any insurance agreement under which the person might be liable, and describe any question or challenged raised by the person relating to coverage for this action. RESPONSE TO INTERROGATORY NO. 19: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing general and specific objections, and without waiving same, Maremont refers plaintiffs to Maremont's responses to plaintiffs request for discovery. Maremont has insufficient knowledge or belief to respond further to this interrogatory. 20. Identify each person, other than a person intended to be called as an expert witness at trial, having discoverable information that tends to support a position that you have taken or intend to take in this action, and state the subject matter of the information possessed by that person. RESPONSE TO INTERROGATORY NO. 20: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities. Subject to the general and specific objections, and without waiving same, Maremont has not determined yet what witnesses it may call at trial. Maremont will supplement this response at such time, or in accordance with the Court's scheduling order or agreement between the parties. 21. If you intend to rely upon any documents or other tangible things to support a position that you have taken or intend to take in the action, provide a brief description, by category and location, of all such documents and other tangible things, and identify all persons having possession, custody or control of them. RESPONSE TO INTERROGATORY NO. 21: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: discovery is continuing. Maremont reserves the right to supplement this response upon completion of discovery. 22. For each brochure, pamphlet, specification, instruction, manual, bulletin, advertisement or other written material describing or relating to each asbestos-containing product identified in these Answers to Interrogatories and/or the use thereof; a. Describe its contents; b. State when, where, how, and to whom it was distributed; c. State the manner in which it was placed in the product container or where it was separate from the product container; d. State whether any written, printed or graphic matter was present to warn of any potential harmful ingredient it might contain. If so, state: i. whether a signal word, e.g. "danger", "warning" or "caution" was present; ii. whether the signal word was printed in boldface, capital letters or different colored inks; iii. the wording of the statements describing any hazard; iv. the wording of all directions and/or instructions pertaining to any method of use to avoid any hazard. e. Identify each individual who participated in the writing of the brochure or other written materials and describe in detail the extent of his participation; f. Identify and produce each document which reflects, refers or relates to the information contained on the brochures, or other written materials and/or the decision to include such information; g. As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance ofthe information supplied. h. The custodian, location and identity of all documents related thereto. RESPONSE TO INTERROGATORY NO. 22: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont refers plaintiffs to Maremont's responses to plaintiffs' request for documents and refers plaintiffs to its response to Interrogatory No. 3 and 10. 23. As to your asbestos product manufacturing facilities, please state: a. Their coiporate history, including but not limited to, when they began production and your purchase thereof; b. The identity ofall plant managers and each person responsible for safety, dust monitoring and employee health; c. The dates of each of their jobs referenced above; d. The products and materials manufactured, produced and/or distributed and the dates associated therewith; e. The amount of asbestos-containing products manufactured, produced and/or distributed for every year from 1935 to 1982; f. The identity of any co-Defendants in these cases to which you sold, supplied and/or installed any of your asbestos-containing products, and if so, the purpose, uses and/or dates thereof; g. Whether you recommended and/or required that employees use respiratory protection for asbestos exposure. If so, please state: i. when you made such recommendation and/or requirement; ii. to which employees you made such recommendation and/or requirement; iii. whether any changes or modification were made to such recommendations and/or requirements and the dates associated therewith; and iv. the type of respiratory protection recommended and/or required. RESPONSE TO INTERROGATORY NO. 23; See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont refers plaintiffs to the Preliminary Statement preceding these responses and states the Paulding, Ohio facility is believed to have begun production in or around 1934, and was purchased by Maremont in December 1953. There were safety precautions, procedures, informational meetings and bulletin board postings instituted at its facilities for its employees. The following Maremont employees were plant managers and persons responsible for safety, dust monitoring and employee health: Wayne Knight, Carl Liggett, Cindy Hayes, among others. Maremont believes that the use of respirators was made mandatory in the Paulding, Ohio facility after OSHA inspections in 1975. Maremont has insufficient knowledge or belief to respond further to this interrogatory. 24. Identify all corporate fact witnesses who have testified for you at trial or in deposition in either asbestos-related litigation or asbestos-related workmen's compensation claims, and provide for each witness the dates of all prior deposition or trial testimony given by them, case(s) in which such testimony was given and the court reporting service which transcribed the testimony. RESPONSE TO INTERROGATORY NO. 24: See general objections. Maremont also objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds that to the best of its belief, no one has ever testified at trial on its behalf. The following persons are known to have been deposed: Byron Pond Kenneth Cornelius Charles Burkhead Mr. Pond's deposition took place on January 13, 1984 in Chicago, Illinois. Mr. Cornelius's deposition took place on November 10, 1983 in Chicago, Illinois. Mr. Burkhead's deposition took place on May 3, 1988 in Newark, New Jersey. Maremont has insufficient knowledge or belief to respond further to this interrogatory. 25. If you contend that the claim of any Plaintiff is barred by the statute of limitations, state for each Plaintiffall facts which support your contention and identify in detail and produce any and all documents or other evidence which support your contention. RESPONSE TO INTERROGATORY NO. 25: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by the applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery ofadmissible evidence, and calls for a legal conclusion. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: contentions can only be formulated when discovery is completed. At the present time, Maremont has not conducted discovery or made a review of discovery conducted by other parties. Maremont reserves the right to supplement this response upon completion of this review and of further discovery. 26. If you contend that the claim of any Plaintiff is barred by contributory negligence or assumption of the risk, state for each Plaintiff all facts which support your contention and identify in detail and produce any and all documents or other evidence which support your contention. RESPONSE TO INTERROGATORY NO. 26: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by the applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence, and calls for a legal conclusion. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: contentions can only be formulated when discovery is completed. At the present time, Maremont has not conducted discovery or made a review of discovery conducted by other parties. Maremont reserves the right to supplement this response upon completion of this review and of further discovery. 27. If you contend that the disease alleged by any Plaintiff was not caused by exposure to asbestos or asbestos-containing products, state for each Plaintiff all facts which support your contention and identify in detail and produce copies ofall documents or other evidence which support your contention. RESPONSE TO INTERROGATORY NO. 27: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by the applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence, and calls for a legal conclusion. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: contentions can only be formulated when discovery is completed. At the present time, Maremont has not conducted discovery or made a review of discovery conducted by other parties. Maremont reserves the right to supplement this response upon completion of this review and of further discovery. 28. If you contend that the condition complained of by any Plaintiff was not caused by exposure to asbestos or asbestos-containing products, state for each Plaintiff all facts which support your contention and identify in detail and produce copies of all documents or other evidence which support your contention. RESPONSE TO INTERROGATORY NO. 28: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by the applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence, and calls for a legal conclusion. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: contentions can only be formulated when discovery is completed. At the present time, Maremont has not conducted discovery or made a review of discovery conducted by other parties. Maremont reserves the right to supplement this response upon completion of this review and of further discovery. 29. If you contend that any Plaintiff was not exposed to asbestos-containing products you manufactured, sold, supplied and/or installed, state for each Plaintiff all facts which support your contention and identify in detail and produce copies of all documents or other evidence which support your contention. RESPONSE TO INTERROGATORY NO. 29: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by the applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence, and calls for a legal conclusion. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: contentions can only be formulated when discovery is completed. At the present time, Maremont has not conducted discovery or made a review of discovery conducted by other parties. Maremont reserves the right to supplement this response upon completion of this review and of further discovery. 30. Ifyou contend that the asbestos-containing products you manufactured, sold, supplied and/or installed were not a substantial contributing factor to the disease alleged by any Plaintiff, state for each Plaintiff all facts which support your contention and identify in detail and attach all documents or other evidence which support your contention. RESPONSE TO INTERROGATORY NO. 30: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by the applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence, and calls for a legal conclusion. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: contentions can only be formulated when discovery is completed. At the present time, Maremont has not conducted discovery or made a review of discovery conducted by other parties. Maremont reserves the right to supplement this response upon completion of this review and of further discovery. 31. If you contend that asbestos-containing products other than yours were a substantial contributing factor to the disease alleged by any Plaintiff, state for each Plaintiff all facts which support your contention and identify in detail and produce copies of all documents or other evidence which support your contention. RESPONSE TO INTERROGATORY NO. 31: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by the applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence, and calls for a legal conclusion. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: contentions can only be formulated when discovery is completed. At the present time, Maremont has not conducted discovery or made a review of discovery conducted by other parties. Maremont reserves the right to supplement this response upon completion of this review and of further discovery. 32. Ifyou are in possession ofany written statements or transcribed oral statements given by any Plaintiff, their personal representatives or any other witness on their behalf, identify in detail and produce copies of any and all such statements. RESPONSE TO INTERROGATORY NO. 32: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs to its responses to plaintiffs' request for documents. 33. If you contend that any Plaintiff was exposed to any asbestos or asbestos-containing products other than through an occupational exposure, state for each Plaintiff all facts which support your contention and identify in detail and produce copies of all documents or other evidence which support your contention. RESPONSE TO INTERROGATORY NO. 33: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by the applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence, and calls for a legal conclusion. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: contentions can only be formulated when discovery is completed. At the present time, Maremont has not conducted discovery or made a review of discovery conducted by other parties. Maremont reserves the right to supplement this response upon completion of this review and of further discovery. 34. Identify by name, current address and title or position each person who assisted in preparing the answers to these interrogatories or who provided any information used in preparing the answers. RESPONSE TO INTERROGATORY NO. 34: In-house counsel, outside counsel and persons acting at their direction. 35. Please identify and/or produce copies of any documents or other evidence to be marked for identification, moved into evidence or used by you to cross-examine any witness at the trial of these cases. RESPONSE TO INTERROGATORY NO. 35: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same. Maremont responds: that it has not decided yet what documents or evidence it will use to crossexamine any witness at trial. Maremont reserves the right to supplement this response upon completion of discovery. 36. Please identify and/or produce or make available for inspection any charts, slides or other demonstrative aids to be used by you or any of your witnesses at the trial of these cases. RESPONSE TO INTERROGATORY NO. 36: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: that it has not decided yet what charts, slides or other demonstrative aids it will use at trial. Maremont reserves the right to supplement this response upon completion of discovery. 37. Identify the distributors or approved applicators of the asbestos products identified in these Answers to Interrogatories at any time during the period from 1935 to the present and identify and attach copies ofall documents relating to said distributors and applicators. For each such entity, indicate: a. The terms ofall assignments, agreements, licenses and other arrangements by and between you and said distributor or applicator; b. Whether the distribution or application relationship was exclusive; c. The year or years in which the distribution or application relationship was in effect; d. The identity of the asbestos products listed in these Answers to Interrogatories which the distributor or applicator was authorized to and did distribute or apply; and e. The quantity of the asbestos products listed in these Answers to Interrogatories distributed by the distributor or sold to the applicator on a year-by-year and product-by-product basis. RESPONSE TO INTERROGATORY NO. 37: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds as follows: Grizzly products were sold to Sears Roebuck & Company ("Sears"), who rebranded the products and sold them under the Sears brand name. Maremont states that it has insufficient information or belief to respond further to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' requests for documents. 38. Do you have custody, possession, or control of any asbestos-containing products and/or packages that presently or formerly packaged asbestos-containing products? If so, a. Identify each such product and/or package; b. Identify the custodian of each such product and/or package; c. Identify the date on which each such product and/or package was manufactured, sold, supplied and/or installed by you and the date when each such product and/or package was retrieved from your facilities and/or from the stream of commerce; d. State whether or not each such product and/or package was retrieved from the stream of commerce or was retrieved from your warehouses or storage facilities; e. If it was retrieved from the stream of commerce, identify the person or company from whom it was retrieved and when; f. If it was retrieved from in-house sources, e.g., warehouses, storage facilities, or sales representatives, identify where, when and from whom it was retrieved. RESPONSE TO INTERROGATORY NO. 38: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds: no. 39. State whether you or anyone on your behalf ever conducted, engaged in or participated in any tests, experiments, studies and/or research concerning the human health consequences of persons coming in contact with and/or inhaling asbestos fibers or asbestos dust during the manufacture and/or use of asbestos products. If so, identify: a. What tests, studies and/or research were done; b. When said tests, studies and/or research were done; c. The individuals who ordered and supervised the tests, studies and/or research; d. The individuals or groups engaged in or participating in the tests, studies and/or research; e. The substance ofany conclusions, recommendations and/or suggestions given as a result of the tests, studies or research. State when, by whom and to whom said recommendations were made, including the addresses of these individuals. f. All written documents including, but not limited to, reports, memoranda, specifications and correspondence which refer, relate or pertain to said tests, studies and/or research; and g. The present custodian of the written documents identified in your Answer to Part (f) of this Interrogatory. RESPONSE TO INTERROGATORY NO. 39: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 40. State whether you ever conducted, sponsored, or directed any tests, experiments, research or studies on any asbestos-containing product you manufactured, sold, supplied and/or installed to determine potential health hazards involved in the use ofthe materials contained therein. If so, indicate the date of each test, the individual or group conducting each such test, the result or conclusion of each such test, all documents which refer, relate or pertain to each such test, and the present custodian of all documents identified in this Answer. RESPONSE TO INTERROGATORY NO. 40: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it has insufficient knowledge or beliefto respond to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 41. State whether you ever conducted, sponsored, tests, experiments, research or studies designed to learn how to prevent, minimize or eliminate the inhalation and ingestion of asbestos dust and fibers by those who used asbestos products or are exposed to asbestos dust or fibers therefrom. If so, indicate the date ofeach study, the individual or group conducting each such study, the result or conclusion of each such study, all documents which refer, relate or pertain to each such study, and the present custodian of all documents identified in this Answer. RESPONSE TO INTERROGATORY NO. 41: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 42. Identify all persons who have testified on your behalfbefore the Occupational Safety and Health Administration, the National Institute of Occupational Safety and Health, any United States congressional or state legislative committee, sub-committee, administrative hearing or investigative proceeding on the subjects of the human health consequences of exposure to asbestos dusts, fibers and/or asbestos-containing products and/or the setting, modification, feasibility or acceptance of allegedly safe or proper levels of exposure to said asbestos and asbestos products. RESPONSE TO INTERROGATORY NO. 42: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory. 43. Identify all documents presented to, utilized or relied upon in the preparation of testimony before the organizations, agencies or committees referred to in the preceding Interrogatory, specifying which documents were presented or utilized for each such body and the present custodian and location of each document. RESPONSE TO INTERROGATORY NO. 43: See response to Interrogatory No. 42. 44. For all testimony or presentations identified in your Answer to Interrogatory No. 42, identify: a. The dates and descriptions of the hearings and proceedings b. The relationship between the person who testified or responded and you; and c. All studies, test results, scientific and/or medical documents relied upon by each person as the basis for any recommendation made or testimony given. RESPONSE TO INTERROGATORY NO. 44: See response to Interrogatory No. 42. 45. State your knowledge relating to the meaning of "maximum allowable concentration", "permissible exposure level" and/or "threshold limit value" as it pertains to asbestos exposure and disease. RESPONSE TO INTERROGATORY NO. 45: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. 46. With reference to "maximum allowable concentration", "permissible exposure level" and/or "threshold limit value", state: a. When and by what means you first obtained information related to a threshold limit value, permissible exposure level and/or maximum allowable concentration; b. The substance of any information imparted to you regarding the same; c. Whether and by what means you advised or warned anyone of details relating thereto; and d. The custodian, location and identity of all documents related thereto. RESPONSE TO INTERROGATORY NO. 46: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds as follows: Maremont does not know when it first became aware of "maximum allowable concentration and threshold limit value." However, it was a matter of general knowledge from the 1960s onward that prolonged exposure to airborne asbestos could possibly be harmful. The initial knowledge in this area pertained to asbestos mining operations. Maremont states that it has insufficient knowledge or belief to respond fiirther to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' requests for documents. 47. State whether you ever knew that any governmental, private agency, and/or other entity issued guidelines suggesting a "maximum allowable concentration", "permissible exposure level", and/or "threshold limit value" for exposure to asbestos dust and/or fibers. If so, state: a. The identity of the agency or other entity which issued said guidelines; b. The verbatim content of said guidelines; c. The date said guidelines were issued; d. The date you were first aware of the purpose of said guidelines; and e. The custodian, location and identity of all documents related thereto. RESPONSE TO INTERROGATORY NO. 47: See response to Interrogatory No. 46. 48. State in detail what tests, research or studies, if any, prior to 1985 you ever conducted, sponsored or directed with regard to the quantity, quality, maximum exposure levels, threshold limit values or permissible exposure levels of asbestos dust, fibers or particles to which users of the asbestos products identified in these Answers to Interrogatories and/or others working in the same vicinity were exposed. RESPONSE TO INTERROGATORY NO. 48: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory. 49. State whether you ever learned that there is or may be a causal connection between exposure to asbestos dust and: a. Asbestosis; b. Pneumoconiosis; ' c. Lung cancer; d. Mesothelioma; and e. Other cancers. RESPONSE TO INTERROGATORY NO. 49: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it was a matter of general knowledge from the 1960s onward that prolonged exposure to airborne asbestos could possibly be harmful. The initial knowledge in this area pertained to asbestos mining operations. Maremont states that it has insufficient knowledge or belief to respond further to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' requests for documents. 50. If your Answer to the preceding Interrogatory is in the affirmative, identify the following as to each such disease listed therein: a. When and by what means you first became aware of such causal connection; b. If your awareness of such causal connection was obtained at any conference, lecture, convention, symposium, or other such meeting, identify the event, its date, the person(s) who attended on your behalf and/or any documents obtained from such event; and c. If your awareness of such causal connection was obtained from a medical or scientific study, or from any other published works, identify the same and the date of your receipt thereof. RESPONSE TO INTERROGATORY NO. 50: See response to Interrogatory No. 49. 51. State whether you ever received any documents, reports or communications from your worker's compensation insurance carrier or products liability insurance carrier with regard to potential health hazards incident to the use of asbestos products and/or exposure to asbestos fibers or dust. RESPONSE TO INTERROGATORY NO. 51: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory. 52. If your Answer to the preceding Interrogatory is in the affirmative, state: a. The substance ofthe contents of such documents, reports or communications; b. The identity ofthe insurance carrier from which you received each document, report or communication; c. The dates of each such document, report or communication; and d. The custodian, identity and location of all documents which relate or pertain to such reports or communications. RESPONSE TO INTERROGATORY NO. 52: See response to Interrogatory No. 51. 53. Identify all locations including but not limited to those at which Plaintiffs worked, to which you sold, supplied, distributed and/or installed asbestos products from 1935 to 1985 and include as to each such location: a. The identity of employees, including foremen and helpers; b. Dates; c. Location; d. Identity and quantity of asbestos products; e. Contracts; f. Bids; g. Specifications; h. Work orders; i. Estimates; j. Reports; and k. Job books. RESPONSE TO INTERROGATORY NO. 53: See genera] objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 54. Have you or anyone on your behalf conducted, sponsored, or had conducted any investigation ofthe statistical and/or epidemiological relationship between your employees exposed to asbestos or any persons using the asbestos-containing products identified in these Answers to Interrogatories and the contraction by humans or animals of asbestosis, lung cancer, colon cancer. other cancers and/or mesothelioma. If so: a. Identify each person participating in such investigation and describe in detail the extent of this participation; b. State when the investigation was conducted and its conclusions and/or recommendations; c. Identify the person or persons who authorized the investigation; d. Identify each document which refers or relates to any information set forth in answer to this Interrogatory; e. As to any information received orally in answer to this Interrogatory, identify each person who supplied such information and state the full substance ofthe information supplied; f. Identify the person or persons to whom the results of the investigation were reported or communicated; and g. Where the results of said investigation were memorialized. RESPONSE TO INTERROGATORY NO. 54: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 55. Have you ever communicated with an agency or department of the United States, or state or local government, concerning the specifications and/or standards for any asbestos-containing product? If so, state separately for each product or set of specifications: a. Identify each such product; b. The number, if any, assigned to the military or federal specification or standard; c. The intended purpose or use for the product so specified; d. The date, time and place of each communication; i. The name of each of your agents or employees who participated in each communication; ii. The name, title, and agencies of each individual with whom such communication was had; iii. The subject of the communication; iv. Whether any notes, minutes or memoranda in any form were recorded of such communication or of any meetings between you and the agency; v. Whether any documents were submitted to the agency; vi. If iv or v above is answered in the affirmative state the name and location of the custodian of such records. RESPONSE TO INTERROGATORY NO. 55: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory and refers plaintiffs to Maremont's responses to plaintiffs' request for documents. 56. When was the first time that you became aware of the contents and existence of Public Health Bulletin No. 241 entitled "A Study of Asbestosis in the Asbestos Textile Industry" by Dressen, Dallavale, Edwards, Miller and Sayers? RESPONSE TO INTERROGATORY NO. 56: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory. 57. With respect to the article referred to in the preceding Interrogatory, please state: a. How you became aware of the existence of such article; b. How you first became aware of the content of such article; c. Which individuals, representatives, employees or agents ofyours were the first to become aware of the content and existence of such article; d. The job title or position held by such individuals) of yours who first became aware of the contents and existence of such article. RESPONSE TO INTERROGATORY NO. 57: See response to Interrogatory No. 56. 58. When was the first time that you became aware of the contents and existence of the article entitle "A Health Survey of Pipecovering Operations in Constructing Naval Vessels" by Fleischer. Viles, Gade, and Drinker. RESPONSE TO INTERROGATORY NO. 58: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory. 59. With respect to the article referred to in the preceding interrogatory, please state: a. How you became aware of the existence of such article; b. How you first became aware of the content of such article; c. Which individuals, representatives, employees or agents ofyours were the first to become aware of the content and existence of such article; d. The job title or position held by such individual(s) ofyours who first became aware of the contents and existence of such article. RESPONSE TO INTERROGATORY NO. 59: See response to Interrogatory No. 58. 60. State when, if at all, you received knowledge ofthe following publications or matters discussed therein, who received such knowledge and identify all documents relating to such knowledge: (a) Selikoff, et al., "Asbestosis and Neoplasia," 42 Am. J. Med. 1967; (b) Selikoff, Churg and Hammond, "The Occurrence of Asbestosis Among Industrial Insulation Workers," 132 Ann. New York Acad. Sc. 139 (1965); (c) 1957 Industrial Hygiene Foundation ofAmerica - "An Epidemiological Study of Lung Cancer in Asbestos Miners" by Braun; (d) 1964 "Asbestos Exposure and Neoplasia" by Selikoff, Churg and Hammond; (e) Annals New York Academy of Sciences, "The Occurrence of Asbestosis Among Insulation Workers in the United States" by Selikoff, Churg and Hammond; (f) 1965 - "Relation Between Exposure to Asbestos and Mesothelioma" by Selikoff, Churg and Hammond; (g) 1968 - "Asbestos Exposure, Smoking, and Neoplasia" by Selikoff, Hammond and Churg; (h) "Documentation of the Threshold Limit Values for Substances in Workroom Air," A.C.G.I.H. (3rd 1971); (i) "Threshold Limit Values for 1961," A.C.G.I.H. (1961); (j) 1906 report by Dr. H. Montague Murray; (k) 1930 - "The Occurrence of Pulmonary Fibrosis and Other Pulmonary Afflictions in Asbestos Workers" by E.R.A. Merewether, M.D.; (l) 1930 - "Report on Effects of Asbestos Dust on the Lungs and Dust Suppression in the Asbestos Industry" by Merewether and Price; (m) Lanza, A.J., W.J. McConnell, and J.W. Fehnel. "Effects of the Inhalation of Asbestos dust on the Lungs of Asbestos Workers," Publ. Health Rep. 50:1 12 (1935); (n) Fulton, W.B., et al., Asbsetosis. Harrisburg, Pennsylvania: Department of Labor and Industry, Commonwealth of Pennsylvania, 1935; (o) Doll, R., "Mortality from Lung Cancer in Asbestos Workers", British Journal of Industrial Medicine, v. 12, 1955; (p) Wagner, J.C., et ah, "Diffuse Pleural Mesothelioma and Asbestos Exposure in the North Western Cape Province", British Journal of Industrial Medicine, v. 17, 1960; (q) Hueper, W.C., "Carcinogens in the Human Environment," Arch. Path. 71:237-267 (1961); (r) Enterline, P.E. and M.F. McKiever. "Differential Mortality from Lung Cancer by Occupation," J. Occup. Med. 5:283-290 (1963); (s) Newhouse, M. and H. Thompson. "Mesothelioma of Pleura and Peritoneum following Exposure to Asbestos in the London Area," Brit. J. Indust. Med. 22:261-269(1965); (t) Hueper, W.C. "Occupational and Nonoccupational Exposures to Asbestos," Ann. N.Y. Acad. Sci. 132:184-195 (965); (u) Brodeur, P., "The Magic Mineral," The New Yorker Magazine, 10/12/68. RESPONSE TO INTERROGATORY NO. 60: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory. 61. Have you ever sent any advisory letter, memorandum or other document to any of your customers or to any of the Plaintiffs' employers, which attempted to advise them of any health hazard that may be associated with the use of asbestos-containing products? If so, a. Identify the author of each such advisory letter or memorandum; b. State the content of each such advisory letter or memorandum; c. Identify the person(s) to whom each such letter or memorandum was sent; d. State the date on which each such letter was sent; and e. Identify the custodian of all such advisory letters or memoranda. RESPONSE TO INTERROGATORY NO. 61: See general objections. Maremont also objects to this interrogatory on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont responds as follows: Maremont did at one time prepare a report for one of its largest customers. Sears Roebuck & Company, regarding the proper installation of brakes, including recommending the use of ventilation and personal protective equipment under appropriate circumstances. ("Asbestos Exposure vs. Back Shop Brake Shoe Grinding," prepared by W.M. Bockay for J.H. Batogowski.). Also, Maremont produced a written Service and Installation Manual in 1971. Maremont has no knowledge or belief as whether it was distributed, and if so to whom. Maremont has insufficient knowledge or belief to respond further to this interrogatory. 62. If you had a sales office or manufacturing or storage facility located in Maryland, Pennsylvania, Delaware, Washington, D.C. and/or Virginia between 1935 and 1985, state the following: a. The address and type (whether sales office, manufacturing, packaging, warehouse, shipping or other) of each office or facility; b. Dates each office or facility was open and in operation; c. The area or territory of responsibility for each such office or area or territory covered by the operations of each facility d. The identity of any asbestos-containing products that were manufactured, packaged or stored in such facility and the dates applicable thereto; e. The identity of any asbestos-containing products that were sold, distributed or supplied from each such office or facility and the dates applicable thereto. RESPONSE TO INTERROGATORY NO. 62: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states, to the best of its knowledge and belief based on investigative efforts that are ongoing, Maremont had no such office or facility. 63. As to any asbestos threshold limit values ever published by the American Conference of Governmental Industrial Hygienists, state when, if ever, you brought such information to the attention of purchasers, users, sellers, suppliers and/or installers of the asbestos products identified in these Answers to Interrogatories. If you did not do so, state the reasons why not. RESPONSE TO INTERROGATORY NO. 63: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory. 64. Please state whether you removed and/or replaced asbestos-containing materials from any of your own facilities after learning of the potential health hazards of asbestos exposure. If so, please state: a. The purpose for each such action; b. The location where each such action occurred; c. The dates for each such action; d. The persons responsible for deciding to undertake such action; e. How each such action was accomplished by the workers who were removing the asbestos-containing materials; f. What respiratory protection was recommended and/or required for the workers who were using or removing the asbestos-containing materials, and if so, the dates thereof; g. The identity of any employees who alleged asbestos lung disease or filed a Workers' Compensation claim alleging asbestos lung disease as a result of such work, and if so, all dates thereof; and h. The custodian, location and identity of all documents related thereto. RESPONSE TO INTERROGATORY NO. 64: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discoveiy of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same. Maremont states that it has no knowledge of abatement activities conducted at any operating facility owned by Maremont which was involved with asbestos containing products. Maremont authorized, as part of overall environmental remediation measures, asbestos removal and related activities at the former Paulding, Ohio facility long after Maremont had sold its friction products business and after the subsequent owner had vacated the premises. The removal was conducted by James L. Grant & Associates between September and November 1988. The removal was conducted preparatory to demolishing the building and was conducted in accordance with all applicable laws, regulations and good management practices. 65. State whether you ever produced, funded or in any way participated in the creation of any film, video, movie or tape (hereinafter "film") whose subjects included asbestos, asbestoscontaining products, asbestos and health, methods of asbestos product application or removal, recommended practices for asbestos product use and/or warnings concerning asbestos inhalation. If so, state: a. The identity, contents and description of each film; b. The author or producer of each film; c. The date of each film; d. The identity of all products discussed therein; e. To whom each film was shown and when; and f. The present location and custodian of each film. RESPONSE TO INTERROGATORY NO. 65: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont states that it has insufficient knowledge or belief to respond to this interrogatory. 66. State if you knew ofthe laws, including but not limited to occupational disease laws, of the states in which you operated and, identify by name, current address and title or position which of your officers), director(s), employee(s) or agent(s) had the primary responsibility ofensuring your compliance with all applicable occupational disease statutes and regulations in each state in which you operated. RESPONSE TO INTERROGATORY NO. 66: See general objections. Maremont also objects to this interrogatory to the extent it seeks disclosure of information protected by applicable privileges and immunities, and on the grounds that it is overbroad and unduly burdensome, vague and ambiguous, not relevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to the foregoing Preliminary Statement and to the general and specific objections, and without waiving same, Maremont has insufficient knowledge or belief to respond to this interrogatory. Is/ Scott M. Richmond Scott M. Richmond Church & Houff, P.A. 2 N. Charles Street, Suite 600 Baltimore, Maryland 21201 (410) 539-3900 Attorneys for Maremont Corporation