Document J3yp4en3on12xyvKgMoEBbjYO

FILE NAME: Mannington Mills (MM) DATE: 1988 Sept 22 DOC#: MM005 DOCUMENT DESCRIPTION: Legal - Defendant Tarkett, Inc.'s Responses to Plaintiffs Standard Interrogatories to All Defendants 1 i Lisa L. Oberg (State Bar No. 120139) , Felicia Y. Feng (State Bar No. 184346) 2 HAIGHT, BROWN & BONESTEEL L.L.P. 100 Bush Street, 27th Floor 3 1 San Francisco, CA 94104 : Telephone: (415) 986-7700 4 , Attorneys For Defendant 5 , TARKETT, INC. 6 7 f<EC-S: SEP 2 2 1998 VAR FklCp. LN H "lh*( SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 10 11 IN RE ) 12 : COMPLEX ASBESTOS LITIGATION ) ) ) 13 ) 14 Case No. 828684 DEFENDANT TARKETT, INC.'S RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO ALL DEFENDANTS PURSUANT TO GENERAL ORDER 129 15 PROPOUNDING PARTY: PLAINTIFFS 16 RESPONDING PARTY: DEFENDANT TARKETT, INC. 17 SET NO.: ONE 18 Defendant sued herein as TARKETT, INC. ("Tarkett") responds to Plaintiff s 19 \ Interrogatories as follows: 20 3 RESPONSES TO INTERROGATORIES 21 i INTERROGATORY NO. 1: 22 jl '! IDENTIFY the person verifying these answers on YOUR behalf. 23 RESPONSE TO INTERROGATORY NO. 1: 24 Alan J. Husak. 25 3 INTERROGATORY NO. 2: 26 jj State the date o f first employment with YOU, and the dates and titles of each job position 27 person verifying these interrogatories has held while employed by YOU. 28 CC25-10000/# 51130 1 1 site in the GEOGRAPHIC AREA and whether any of THIS DEFENDANT'S RAW ASBESTOS I 2 1has at any time, been sold to any manufacturer, or manufacturing facility, of ASBESTOS- 3 CONTAINING PRODUCTS. If so, state: 4 ;j 1. The names of each such COMPANY, governmental agency or 5 j entity, shipyard, distributor, supplier, manufacturer or refinery'; 6 I 2. The inclusive dates of each such sale, and the amount (quantity) 7 !and the trade brand name of such RAW ASBESTOS sold; 8 3. The manner of shipment (e.g. boat, rail, etc.) 9 1 4. Whether you have any records indicating any such sale or shipment 10 . and, if so, the name, address and job classification of each person who currently has possession 11 of such records. 12 j 5. Either (1) attach all DOCUMENTS evidencing the information 13 , sought in this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach 14 ' disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that 15 | they may be made the subject of a request for production of documents. 16 RESPONSE TO INTERROGATORY NO. 29: 17 Not applicable. 18 INTERROGATORY NO. 30: 19 Between 1930 and 1985, did YOU ever engage in any o f the activities listed below with 20 j regard to ASBESTOS-CONTAINING PRODUCTS? If so, state the inclusive dates of such 1 21 activity: 22 j: 23 j 24 ; ! 25 i 26 ! 1 27 ! A. Supply; B. Importing; C. Distribution; D. Marketing; E. Sale; F. Labeling; 28 1 G. Manufacturing; CC2S-I0000/#5II30 15 11 H. Brokering. 2 I! RESPONSE TO INTERROGATORY NO. 30: ;i ; 3i On September 28, 1981, Tarkett puj-chased the worldwide assets o f the GAF Corporation i' : , i 4 | Flooring Division. Tarkett sold vinyl floor tiles, sheet vinyls and felt-based materials from 5 1approximately 9/28/81 - 12/31/81 some of which, upon information and belief, may have 6 1contained asbestos to distributors of GAF who were in existence during the four month period. 7 ! That time period is an estimate based uponiinventory turn calculation - inventories turned 5.2 8 times or approximately every 69 days. Under that calculation, any asbestos containing floor tile, 9 sheet vinyl and/or felt-based material would have been sold by 12/31/81. Tarkett did not 10 ,1 , j manufacture any asbestos-containing products. 11 i INTERROGATORY NO. 31: 12 .! If your answer to any subpart of Interrogatory No. 31 [sic] regarding "ASBESTOS - 13 : CONTAINING PRODUCTS" is in the affirmative, state: 14 ij A. The trade, brand nathe, and/or generic name of each such ASBESTOS- 15 ! CONTAINING PRODUCT MARKETED,in any form or quantity between 1930 and 1985; 16 '! B. The datc(s) each sudh ASBESTOS-CONTAINING PRODUCT was first i 17 placed on the market, including the date(s) each such ASBESTOS-CONTAINING PRODUCT 18 !' was first MARKETED; 19 1. 20 2. :; On an experimental basis; On a test basis; or 21 3. For sale. 22 C. The date(s) each such ASBESTOS-CONTAINING PRODUCT: 23 1. Ceased to be produced; or 24 2. Was recalled from the market, if ever. 25 D. A detailed description of the chemical composition of each such 26 {ASBESTOS-CONTAINING PRODUCT, including the type and/or grade of asbestos and/or 27 \ asbestos fiber contained in each such product and the quantitative percentage of asbestos or 28 asbestos fiber such product, and all non-asbestos components of the ASBESTOS-CONTAINING CC25-10000/# 5 i !30 16 I VERIFICATION STATE OF CALIFORNIA ) ss. COUNTY OF SAN FRANCISCO ) ' I have read the foregoing DEFENDANT TARKETT, INC.'S RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES! TO ALL DEFENDANTS PURSUANT TO GENERAL ORDER 129 and know its contents. I am an authorized agent of Tarkett, Inc., a prty to this action, and am authorized to make this verification for and on its behalf, and I make this verification for that reason. I am informed and believe and on that ground allege that the matters1stated in the foregoing document are true. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. [ Executed on // 199^, at Whitehall, Pennsylvania. Type or Print Name /# 51730