Document GKjeNZY21XaD6BNDaNqobDQdV

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA LAURA A. NIZINSKI, Executor of the Estate of LEONARD R NIZINSKI, Deceased, and LAURA A. NIZINSKI, in her own right, Plaintiff, vs. PNEUMO ABEX CORPORATION, et al., Defendants. ANSWERS TO PLAINTIFFS' FIRST SET OF INTERROGATORIES DIRECTED TO DEFENDANT BONDO CORPORATION AND NOW, conies the Defendant, Bondo Corporation, by and through its counsel, Peter D. Giglione, Esquire and Marshall, Dennehey, Warner, Coleman & Goggin, and Files the within Answers to Plaintiffs' First Set of Interrogatories as follows: 1. Identify all of Bondo Corporation's suppliers of talc from 1960 to 1990. ANSWER: Objection. This Interrogatory is overly broad, unduly burdensome, and not likely to lead to the discovery of relevant evidence. Without waiver of said objections, Bondo Corporation purchased talc from the following companies: Engelbart Corporation; Eastern Magnesium Talc; Vertal Corporation, also known as Vermont Talc, Inc.; Cyprus Minerals; Specialty Minerals; Luzenac America; and Whittaker, Clark and Daniels. Bondo Corporation never purchased talc from any other companies. Respectfully Submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN PLAINTIFFS EXHIBIT WCD-365 Peter D. Giglione, Esquire Attorneys for the Defendant Bondo Corporation