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.
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7
f<EC-S:
SEP 2 2 1998
VAR FklCp. LN H "lh*(
SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN FRANCISCO
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11 IN RE
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: COMPLEX ASBESTOS LITIGATION
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Case No. 828684
DEFENDANT TARKETT, INC.'S RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO ALL DEFENDANTS PURSUANT TO GENERAL ORDER 129
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PROPOUNDING PARTY: PLAINTIFFS
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RESPONDING PARTY: DEFENDANT TARKETT, INC.
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SET NO.:
ONE
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Defendant sued herein as TARKETT, INC. ("Tarkett") responds to Plaintiff s
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\ Interrogatories as follows:
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RESPONSES TO INTERROGATORIES
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i INTERROGATORY NO. 1:
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IDENTIFY the person verifying these answers on YOUR behalf.
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RESPONSE TO INTERROGATORY NO. 1:
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Alan J. Husak.
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3 INTERROGATORY NO. 2:
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State the date o f first employment with YOU, and the dates and titles of each job position
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person verifying these interrogatories has held while employed by YOU. 28
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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:
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1. The names of each such COMPANY, governmental agency or
5 j entity, shipyard, distributor, supplier, manufacturer or refinery';
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2. The inclusive dates of each such sale, and the amount (quantity)
7 !and the trade brand name of such RAW ASBESTOS sold;
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3. The manner of shipment (e.g. boat, rail, etc.)
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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:
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Not applicable.
18 INTERROGATORY NO. 30:
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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:
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A. Supply; B. Importing; C. Distribution; D. Marketing; E. Sale; F. Labeling;
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G. Manufacturing;
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H. Brokering.
2 I! RESPONSE TO INTERROGATORY NO. 30:
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On September 28, 1981, Tarkett puj-chased the worldwide assets o f the GAF Corporation
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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
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,1
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j manufacture any asbestos-containing products.
11 i INTERROGATORY NO. 31:
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If your answer to any subpart of Interrogatory No. 31 [sic] regarding "ASBESTOS -
13 : CONTAINING PRODUCTS" is in the affirmative, state:
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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;
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B. The datc(s) each sudh ASBESTOS-CONTAINING PRODUCT was first
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17 placed on the market, including the date(s) each such ASBESTOS-CONTAINING PRODUCT
18 !' was first MARKETED;
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1.
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2.
:; On an experimental basis;
On a test basis; or
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3. For sale.
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C. The date(s) each such ASBESTOS-CONTAINING PRODUCT:
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1. Ceased to be produced; or
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2. Was recalled from the market, if ever.
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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
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VERIFICATION
STATE OF CALIFORNIA
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COUNTY OF SAN FRANCISCO )
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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.
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Executed on
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199^, at Whitehall, Pennsylvania.
Type or Print Name
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