Document GmXQ05bJnQnjRJYgek6BRoJbY

James J. Marehiano George A. Markell CROSBY, HEAFEY, ROACH i MAY Professional Corporation 1999 Harrison Street Oakland, CA 94612 (415) 763-2000 Attorneys for Defendant Chrysler Corporation, a corporation SUPERIOR COURT OF CALIFORNIA - CITY AND COUNTY OF SAN FRANCISC IN RE: COMPLEX ASBESTOS LITIGATION __________________________________________ / No. 828-684 SUPPLEMENTARY RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO DEFENDANT Propounding Party Responding Party: Set Number: Plaintiffs Defendant Chrysler Corporation, a corporation Plaintiffs' Standard Set (Exhibit "I" to General Order 29) Defendant Chrysler Corporation makes the folloving supplemental responses to plaintiffs' Standard Interrogatories 1 BRSPOMSg TO INTERROGATORY HO. 2: 2 e. Chrysler is without information adequate t: 3 respond to this interrogatory. 4 / 5 RESPONSE TO INTERROGATORY HO. 3; Chrysler Corporate 6 underwent a corporate reorganization in 1986 and is now doing 7 business as Chrysler Motors Corporation. The names Plymouth, 8 Dodge and De Soto identify products that have been made by 9 Chrysler Corporation and also have identified divisions of 10 Chrysler Corporation, but Chrysler Corporation has not done 11 business under those names. 12 /> 13 RESPONSE TO INTERROGATORY NO. 9: Chrysler Corporatioi 14 reasserts all objections previously stated, but states that it 15 manufactured asbestos-containing brake products and clutch parts 16 for automobiles only since 1959. 17 18 RESPONSE TO INTERROGATORY NO. 10: Chrysler 19 Corporation objects to this interrogatory on the ground that it 20 is unduly burdensome and that the burden it imposes is grossly 21 incommensurate with the results obtainable; in addition, the 22 information sought is equally available to both parties. To 23 list every authorized Chrysler dealer in 46 counties over 55 24 years would require hundreds of manhours and serve no other 25 purpose than to establish that which all parties already know, 26 i.e., that any automobile agency selling new Chrysler, Dodge, 3 1 RESPONSE TO XNTERROGATORY MO. 17; The following 2 entities supplied passenger car brake linings to Chrysler in : 3 years indicated: 1981, Bendix Corp. Friction Material Divisic 4 1980, same as 1981; 1979, same as 1981; 1978; Abex Corp. and 5 Bendix Corp.; 1977, same as 1981; 1976, same as 1981; 1975, sa 6 as 1981; 1974, Bendix Corp. and Raybestos-Manliattan; 1970-1973 7 same as 1981; 1969, same as 1978; 19^8, Abex Corp. and Johns- j 8 Manville Corp.; 1965-1967, same as 1968; 1963-1964, same as 9 1981; 1962; Bendix Corp., Johns-ManviHe Corp.; 1960^1961, sam< ^ 10 as 1968; 1959, Abex Corp. and Johns-Manville Corp. (All dates 11 are model years.) 12 / ' V. / .. 13 RESPONSE TO INTERROGATORY MO. 19: Chrysler continues 14 to object to this interrogatory as it pertains to clutch 15 products on the ground that warnings are irrelevant to any issu 16 pertaining to clutch products. Chrysler has given no such 17 warnings in relation to brake shoes, brake blocks, brake pads 18 and brake bands. 19 20 RESPONSE TO INTERROGATORY NO. 20: The original 21 response was complete, notwithstanding objections asserted, on 22 the basis of current information; discovery is continuing and 23 Chrysler will supplement this answer if and when it learns of 24 other depositions responsive to this interrogatory. 25 26 5 RESPONSE TO INTERROGATORY HO. 22: Chrysler reasse its previous objection to these interrogatories, and in addit-.o; objects on the further ground that these questions call for a legal conclusion. These interrogatories can only be answered b) litigation of questions of coverage, not by speculation. Nonetheless, and in spite of any past events in Chrysler's fiscal history, Chrysler is able to respond to your claim for damages. RESPONSE TO INTERROGATORY MO. 23: Interrogatory No. 22. See response to DATED: August 10, 1986 CROSBY, HZAFEY, ROACH i MAY Professional Corporation By a corporation