Document JJQBXXnOY3r9Bn1a57VrdQj0K
NO. 92-02693
JOHN A. LOPER, SR. and PATSY LOPER; WILLIAM GEORGE WALLACE and SHELBY WALLACE; THOMAS COLTON BULLOCH, JR. and MARILYN BULLOCH; ROBERT EARL BUMPERS and FAYE BUMPERS; WILLIE F. MARLIN and IDA FAYE MARLIN; JAMES CLOIS HODGINS and DOROTHY HODGINS; and WOODROW WILSON SMITH and MELBA SMITH,
Plaintiffs,
versus
FIBREBOARD CORPORATION, et al.,
Defendants.
IN THE DISTRICT COURT TRAVIS COUNTY, TEXAS 53RD JUDICIAL DISTRICT
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO
DEFENDANT ON OR ABOUT APRIL 21. 1993
TO: Plaintiffs, by and through their counsel of record, Russell W. Budd, Baron & Budd, The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219.
Comes now Westinghouse Electric Corporation ("Westinghouse"), by and through its
attorneys of record, and files these Objections and Responses to Plaintiffs' Intenogatories Mailed
to Defendant on or about April 21, 1993.
Preliminary Statement and General Objections
Westinghouse has a history of cooperation with plaintiffs' counsel, Baton & Budd, and has produced substantial discovery consisting of documents, witnesses and answers to intenogatories. The current intenogatories request verification of the authenticity of certain documents which presumably were previously produced by Westinghouse to Plaintiffs along with literally thousands of other documents. However, many of these documents were not prepared
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 1
by Westinghouse and Westinghouse cannot attest to their authenticity. Specifically, Westinghouse lacks the first hand knowledge necessary to determine whether each of these documents is genuine and authentic. Likewise, the origin of many documents cannot be confirmed as Westinghouse documents because Plaintiffs have supplied copies which do not carry a readable bates number. Furthermore, many of the documents themselves are illegible. Finally, many documents on their face appear to be Westinghouse documents but contain other information either typed or hand written which would not have been found on the original document. Again, without knowing the source of the document or at least the source of this extraneous information, Westinghouse cannot attest to the documents authenticity. In essence, Plaintiffs have failed to provide sufficient information for Westinghouse to provide accurate and meaningful responses.
Westinghouse's responses to these Interrogatories are made without in any way waiving: (1) the right to object, on the grounds of competency, relevancy, materiality, hearsay or any other proper grounds, to the use of any such information for any purpose, in whole or in pan, in any subsequent stage or proceeding in this action or any other action; or (2) the right to object on any and all grounds, at any time, to any other discovery procedure relating to the subject matter of these Interrogatories.
Without waiving these objections and subject thereto Westinghouse further responds to the Interrogatories as follows:
INTERROGATORIES
INTERROGATORY NO. 1: For each document listed below, please answer whether
such document is a true and correct duplicate of a genuine and authentic document:
ANSWER: See general objection. Subject to these objections, these documents appear
to be copies of materials provided by Westinghouse to Plaintiffs in various cases.
INTERROGATORY NO. 2: For each document listed below, please answer whether
such document was kept and/or generated in the regular course of a regularly conducted business
activity of any Westinghouse Entity by an employee or representative of any Westinghouse
Entity with knowledge of the act, event, condition or opinion recorded.
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 2
ANSWER: See general objection and response to Interrogatory No. 1. The attached
documents appear to have been produced to Plaintiffs' counsel by Westinghouse. However,
because hundreds of thousands of pages of documents have been made available to Plaintiffs
from a large variety of sources within Westinghouse, Westinghouse is unable to determine
whether the materials were maintained in the regular course of regularly conducted business
activity. Therefore, Westinghouse cannot attest that these documents were "kept and/or
generated in the regular course of a regularly conducted business activity of any Westinghouse
entity by an employee or representative of any Westinghouse entity with knowledge of the act,
event, condition or opinion recorded." The foregoing is also true with respect to any document
produced by Westinghouse which was generated by some source outside the corporation.
Subject to the foregoing objections and without waiving same see individual responses below.
EXHIBIT NO.
DESCRIPTION
a) WH-396
Memorandum dated March 22, 1976 from John F. Adams to R&D Center 501-2Y34, E. S. Bober; re: Asbestos Air Sampling.
ANSWER: Appears to be a document generated by Westinghouse.
b) WH-397
Memorandum dated April 5, 1976 from T. J. Sweeney to Building 401 Machining Services, W. Jackson, E. Kenyhercz, A. Butcher, C. Watson, J. Catterall.
ANSWER: Appears to be a document generated by Westinghouse.
c) WH-399
Memorandum dated May 14, 1976 from J. Adams regarding BEDFORD INCIDENT, with attachments.
ANSWER: Appears to be a document generated by Westinghouse.
d) WH-400
Memorandum dated May 17, 1976 from John F. Adams to R&D Center 501-2Y34, E. S. Bober; re: Asbestos Air Samples.
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 3
ANSWER: Appears to be a document generated by Westinghouse.
e) WH-401
Memorandum dated July 19, 1976 from J. F. Adams to Derry Plant, IMD, G. Shilling; re: Asbestos Air Samples.
ANSWER: Appears to be a document generated by Westinghouse.
f) WH-402
Westinghouse Electric Corporation Document titled "Large Rotating Apparatus Division, ID 76-31, Asbestos in LRA Progress Report" by C. R. Ruffing, August 24, 1976.
ANSWER: Appears to be a document generated by Westinghouse.
g) WH-403
Memorandum dated October 20, 1976 from G. T. Brady to William H. Ziefel, re: Industrial Hygiene - Legal Statement with attachment.
ANSWER: Appears to be a document generated by Westinghouse.
h) WH-406
Article titled "The Town Dilemma" by Don Jordan, reprinted from the March 1977 issue of Environment.
ANSWER: Not a Westinghouse generated document.
i) WH-414 Memorandum dated August 25, 1978 from Franklin H. Hawke to Edward F. Hanley, re: Subpoena of Records, Thomas F. Johnson with enclosed: Commonwealth of Pennsylvania, Department of Labor Workers' Compensation claim.
ANSWER:
The memo dated August 25, 1978 appears to be a document generated by Westinghouse. However, the remainder of the document was not generated by Westinghouse.
j) WH-4I6 Memorandum dated March 8, 1979 from C. G. Rausch to All PGSD Area and District Managers; re: Bearing Bracket Sealing (Tite Seal)
ANSWER: Appears to be a document generated by Westinghouse.
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 Paye 4
k) WH-418
Memorandum dated November 28, 1978 from H. D. Ruppel to Research & Development Center, John F. Gormley, re: Comments an Restrictions for Asbestos Uses.
ANSWER: Appears to be a document generated by Westinghouse.
1) WH-423
Memorandum dated July 25, 1980 from Paul Palmieri and Harry B. Burr to Personnel Relations Managers, Personnel Relations Representatives, Industrial Hygiene and Safety Coordinators, Medical Departments, re: OSHA Access to Employee Exposure and Medical Records Rule 1910.20 with attachment.
ANSWER: Appears to be a document generated by Westinghouse.
m) WH-424
Westinghouse Electric Corporation letter dated November 21, 1980 from James E. Ford to Executive Secretary, Occupational Safety & Health Review Commission; re: Secretary of Labor v. Westinghouse, OSHRC Docket No. 806779. with enclosure: Answer to Comolaint. Marshall v. Westinphouse. IJSA Occuoational Safetv and Health Review Commission. November 21, 1980.
ANSWER: Appears to be a document generated by Westinghouse.
n) WH-425
Citation and Notification of Penalty dated September 26, 1980, to M. P. Whittington, Westinghouse Electric Corporation, Lester, PA. and attached Westinghouse Corporation letter dated October 13, 1980 from James E. Ford to Walter E, Wilson, OSHA Area Director.
ANSWER:
The letter dated October 13,1980 appears to be a Westinghouse generated document. However, the remainder of the document was not generated by Westinghouse.
o) WH-433
Handwritten cover note from L. G. Rudolph to Wayne Bickerstaff transmitting Westinghouse letter dated May 25, 1984 from L. G. Rudolph to J. H. Askins, Att: Mary Doscci, re: Barbara Boysen v. Westinghouse.
ANSWER: Appears to be a document generated by Westinghouse.
p) WH-440
Document dated April 16, 1985, titled "Library, Industrial Hygiene Department".
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Pare 5
ANSWER: Appears to be a document generated by Westinghouse.
q) WH-458
Letter dated September 3, 1987 from Michael J. Hodgson to Joel Persky regarding Charles Krieger.
ANSWER: Not a Westinghouse generated document.
r) WH-462 Memorandum dated November 5, 1987 from C. W. Bickerstaff to E. P. Massaro regarding October Activities Report.
ANSWER: Appears to be a document generated by Westinghouse.
s) WH-463
Undated report signed by Jeffrey J. Bair and C. W. Bickerstaff.
ANSWER: Appears to be a document generated by Westinghouse.
t) WH-464 Memorandum dated November 19, 1987 from Jeffrey J. Bair to Wayne Bickerstaff regarding Review of Documents at Industrial Hygiene.
ANSWER: Appears to be a document generated by Westinghouse.
u) WH-465
Memorandum dated December 29, 1987 from C. W. Bickerstaff to S. R. Pitts regarding Proposed 1988 Objectives.
ANSWER: Appears to be a document generated by Westinghouse.
v) WH-466
Report entitled "Proposed 1988 I.X. Objectives," dated January 8, 1988.
ANSWER: Appears to be a document generated by Westinghouse.
w) WH-467
Memorandum dated January 29, 1988 from C. W. Bickerstaff to J. W. Fisch regarding document retention.
ANSWER: Appears to be a document generated by Westinghouse.
X) WH-478
Letter dated May 6, 1988 from Craig D. Lowry to Westinghouse Corporation regarding non-formal complaint #5-0055.
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 6
ANSWER: Not a Westinghouse generated document.
y) WH-485
Letter dated April 6, 1989 from Richard M. Dayoub to Mr. Smelstoys.
ANSWER: Not a Westinghouse generated document.
z) WH-489
Memorandum dated August 10, 1989 from Mark Perriello to Ron Lawrence regarding asbestos records stored at STC.
ANSWER: Appears to be a document generated by Westinghouse.
aa) WH-490
Memorandum dated October 12, 1989 from C. Wayne Bickerstaff to industrial hygiene & safety officers, et al regarding EPA Bans Asbestos products.
ANSWER:
The memo dated October 12, 1989 appears to be a Westinghouse generated document. However, the remainder of the document was not generated by Westinghouse.
bb) WH-491
Citation dated November 16, 1989 from Peter M. Clark to Lloyd West with attached report.
ANSWER: Not a Westinghouse generated document.
cc) WH-493
Letter dated October 11, 1991 from Roger E. Wills to the Honorable Edwin G. Salvers regarding Martin v. Westinghouse Electric Cornoration Docket No. 91-1874 with attachment.
ANSWER: Appears to be a document generated by Westinghouse.
dd) WH-494
Letter dated December 13, 1991 from Newmyer Associates to Westinghouse Electric Corporation regarding job safety enforcement report of interest group with attached survey.
ANSWER: Not a Westinghouse generated document.
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Pare 7
ee) WH-495
Facsimile cover sheet from Jerry Brady to Roger Wills regarding enclosed letter dated July 28, 1992 from Cois M. Brown to Westinghouse.
ANSWER:
The facsimile cover sheet appears to be a Westinghouse generated document. However, the remainder of the document was not generated by Westinghouse.
ff) WH-499
Bulletin entitled "Standards of Conduct - n. Health and Safety in the Workplace."
ANSWER: Appears to be a document generated by Westinghouse.
gg) WH-500
George D. Clayton & Association, Inc., letter (DRAFT) from George D. Clayton to Paul Tuttle.
ANSWER: Not a Westinghouse generated document.
hh) WH-501
Safe Practice Data Sheet A-20 entitled "Asbestos" dated 1/2/53.
ANSWER: Appears to be a document generated by Westinghouse.
ii) WH-504
Letter dated September 4, 1963 from A. C. Richardson, Marketing Manager, to H. W. Speicher regarding Sprayed "Limpet" Asbestos, with enclosure.
ANSWER: Not a Westinghouse generated document.
jj) WH-507
Memorandum dated March 6, 1970 from Zella R. Rees to J. Welshones.
ANSWER: Appears to be a document generated by Westinghouse.
kk) WH-574
Westinghouse memorandum dated February 7, 1973 from E. J. Hlavaty, to W. G. Craig; re: Use of Asbestos Cloth, Paper and Tape in Soldering Operations.
ANSWER: Appears to be a document generated by Westinghouse.
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOTTT APRIL 21. 1993 - Paw 8
INTERROGATORY NO. 3: For each document listed below, please answer whether
such document was found in your files in such a condition as to create no suspicion concerning
its authenticity.
ANSWER: See general objections and response to Interrogatory Nos. 1 and 2 above.
Except as noted below, each of these documents appears in the condition as found in
Westinghouse files.
EXHIBIT NO.
DESCRIPTION
b) WH-397
Memorandum dated April 5, 1976 from T. J. Sweeney to Building 401 Machining Services, W. Jackson, E. Kenyhercz, A. Butcher, C. Watson, J. Catterail.
ANSWER: This document contains unidentified extraneous information.
f) WH-402
Westinghouse Electric Corporation Document titled "Large Rotating Apparatus Division, ID 76-31, Asbestos in LRA Progress Report" by C. R. Ruffing, August 24, 1976.
ANSWER: This document contains unidentified extraneous information.
g) WH-403
Memorandum dated October 20, 1976 from G. T. Brady to William H. Ziefel, re: Industrial Hygiene - Legal Statement with attachment.
ANSWER:
This document contains unidentified extraneous information. Furthermore, it is unknown whether this document is complete or whether additional portions should be attached hereto.
h) WH-406
Article titled "The Town Dilemma" by Don Jordan, reprinted from the March 1977 issue of Environment.
ANSWER:
Not only was this document not generated by Westinghouse but also it is illegible and incomprehensible. Accordingly, Westinghouse can provide no information regarding its authenticity.
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 Page 9
i) WH-414
Memorandum dated August 25, 1978 from Franklin H. Hawke to Edward F. Hanley, re: Subpoena of Records, Thomas F. Johnson with enclosed: Commonwealth of Pennsylvania, Department of Labor Workers' Compensation claim.
ANSWER:
The memo dated August 25, 1978 contains unidentified extraneous information. Furthermore, the remaining documents are illegible and it is unknown whether these remaining documents regarding this unsubstantiated claim are a complete set of those documents filed. Finally, this document was not generated by Westinghouse and therefore Westinghouse can provide no information regarding its authenticity.
j) WH-416
Memorandum dated March 8, 1979 from C. G. Rausch to All PGSD Area and District Managers; re: Bearing Bracket Sealing (Tite Seal).
ANSWER: This document contains unidentified extraneous information.
k) WH-418
Memorandum dated November 28, 1978 from H. D. Ruppel to Research & Development Center, John F. Gormley, re: Comments on Restrictions for Asbestos Uses.
ANSWER: This document contains unidentified extraneous information.
n) WH-425
Citation and Notification of Penalty dated September 26, 1980, to M. P. Whittington, Westinghouse Electric Corporation, Lester, PA. and attached Westinghouse Corporation letter dated October 13, 1980 from James E. Ford to Walter E. Wilson, OSHA Area Director.
ANSWER:
Because this citation and unsubstantiated claim is not a Westinghouse generated document, Westinghouse is unsure as to whether this document has been provided in its entirety. Furthermore, as a non-Westinghouse generated document Westinghouse can provide no information regarding its authenticity. However, the letter dated October 13, 1980 appears to be a copy of a Westinghouse generated document.
0) WH-433
Handwritten cover note from L. G. Rudolph to Wayne Bickerstaff transmitting Westinghouse letter dated May 25,1984 from L. G. Rudolph to J. H. Askins, Att: Mary Doscci, re: Barbara Boysen v. Westinghouse.
ANSWER: This document contains unidentified extraneous information.
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Paw 10
q) WH-458
Letter dated September 3, 1987 from Michael J. Hodgson to Joel Persky regarding Charles Krieger.
ANSWER:
Not only does this document contain unidentified extraneous information, but also the document was not prepared by Westinghouse and Westinghouse can provide no information regarding its authenticity.
s) WH-463
Undated report signed by Jeffrey J. Bair and C. W. Bickerstaff.
ANSWER: This document contains unidentified extraneous information.
x) WH-478
Letter dated May 6, 1988 from Craig D. Lowry to Westinghouse Corporation regarding non-formal complaint #5-0055.
ANSWER:
Not only does this document contain unidentified extraneous information, but also this document was not prepared by Westinghouse and Westinghouse can provide no information regarding its authenticity. Furthermore, Westinghouse is uncertain as to whether the document and the attachments thereto is complete or whether there is any basis for this unsubstantiated claim.
y) WH-485
Letter dated April 6, 1989 from Richard M. Dayoub to Mr. Smelstoys.
ANSWER:
Not only does this document contain unidentified extraneous information, but also this document was not prepared by Westinghouse and Westinghouse can provide no information regarding its authenticity. Furthermore, Westinghouse has no information to verify the basis of this unsubstantiated claim or whether this document is complete.
aa) WH-490
Memorandum dated October 12, 1989 from C. Wayne Bickerstaff to industrial hygiene & safety officers, et al regarding EPA Bans Asbestos Products.
ANSWER:
Because the information from the EPA is not a Westinghouse document, Westinghouse can provide no information regarding its authenticity. However, the memo dated October 12, 1989 appears to be a Westinghouse document.
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORTF.S MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Paw 11
bb) WH-491
Citation dated November 16, 1989 from Peter M. Clark to Lloyd West with attached report.
ANSWER:
Because this unsubstantiated claim is not a Westinghouse generated document, Westinghouse is uncertain as to whether this document is complete or if additional attachments exist. Furthermore, since Westinghouse did not generate this document it can provide no information regarding its authenticity.
dd) WH-494
Letter dated December 13, 1991 from Newmyer Associates to Westinghouse Electric Corporation regarding job safety enforcement report of interest group with attached survey.
ANSWER:
Not only does this document contain unidentified extraneous information, but also this document was not prepared by Westinghouse and Westinghouse can provide no information regarding its authenticity.
ee) WH-495
Facsimile cover sheet from Jerry Brady to Roger Wills regarding enclosed letter dated July 28, 1992 from Cois M. Brown to Westinghouse.
ANSWER:
Not only does this document contain extraneous information, but also the letter dated July 28, 1992 was not prepared by Westinghouse as Westinghouse can provide no information regarding its authenticity.
ff) WH-499
Bulletin entitled MStandards of Conduct - n. Health and Safety in the Workplace."
ANSWER: This document contains unidentified extraneous information.
gg) WH-500
George D. Clayton & Association, Inc., letter (DRAFT) from George D. Clayton to Paul Tuttle.
ANSWER:
Not only does this document contain unidentified extraneous information, but also this document was not prepared by Westinghouse and Westinghouse can provide no information regarding its authenticity.
ii) WH-504
Letter dated September 4, 1963 from A. C. Richardson, Marketing Manager, to H. W. Speicher regarding Sprayed "Limpet" Asbestos, with enclosure.
WESTINGHOUSE ELECTRIC CORPORATION'S OB.TECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Paw 12
ANSWER:
Not only does this document contain unidentified extraneous information, but also this document was not prepared by Westinghouse and Westinghouse and Westinghouse can provide no information regarding its authenticity.
kk) WH-574
Westinghouse memorandum dated February 7, 1973 from E. J. Hlavaty, to W. G. Craig; re: Use of Asbestos Cloth, Paper and Tape in Soldering Operations.
ANSWER: This document contains unidentified extraneous information.
INTERROGATORY NO. 4: Has Westinghouse stipulated or agreed to the authenticity of any of the documents referenced in Interrogatory No. 1 with any person prior to the date of these Interrogatories?
ANSWER: Westinghouse is not aware of any stipulation to the authenticity of any of the documents referred to in Interrogatory No. 1 except to the extent Westinghouse may have stated that the documents were provided by Westinghouse via document production in various cases.
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 13
Respectfully submitted, VIAL, HAMILTON, KOCH & KNOX 1717 Main Street Suite 4400 Dallas, Texas 75201-4605 (214) 712-4400 FAX (214) 712-4402
State Bar No. 09460500 ROBERT E. THACKSTON State Bar No. 00785487 B. SCOTT TILLEY State Bar No. 20032700 McGUIRE, WOODS, BATTLE &
BOOTHE One James Center Richmond, Virginia 23219 (804) 775-1000 ATTORNEYS FOR WESHNGHOUSE ELECTRIC CORPORATION
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS ANDRESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 14
STATE OF _ COUNTY OF
BEFORE ME, the undersigned authority, on this day personally appeared DANIEL VICKOVIC, Assistant Secretary of Westinghouse Electric Corporation, who being by me duly sworn, upon his oath deposes and says that he is duly authorized as an agent by and on behalf of Westinghouse Electric Corporation to make this Verification, that he has read Defendant's Answers to Plaintiffs' Master Interrogatories and Requests for Production, and that the facts stated therein are within his personal knowledge and are true and correct.
DANIEL VICKOVIC, Affiant
SUBSCRIBED AND SWORN TO BEFORE ME on this the day of _____________, 1993.
Notary Public in and for the State of_____________
My Commission Expires:
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 15
CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Westinghouse Electric Corporation's Objections and Responses to Plaintiffs' Interrogatories mailed to Defendant on or about April 21, 1993 have been forwarded to counsel for Plaintiffs via certified mail, return receipt requested, and to all other known counsel of record via U.S. Mail, regular delivery, on this the?l\4 day of May, 1993.
M______________ ATTORNEYS FOR DEFENDANT
WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 16
CATHY HENDRICKSON
(214)712-410
Vial, Hamilton, Koch & Knox
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
ATTORNEYS AND COUNSELORS
BftB0N & bu J'
1717 MAIN STREET SUITE 4400
DALLAS, TEXAS 75201 TELEPHONE: (214)712-4400
May 28, 1993
D/FW METRO TEL.: 988-7375 FAX: (214) 712-4402
Mr. John Dickson District Clerk Courthouse 1000 Guadalupe Street P.O. Box 1748 Austin, Texas 78767
Ovvt'W-CAA-- *
RE: John A. Loper, Sr., etal. v. Fibreboard Corporation, et al,; Cause No. 92-02693 in the 53rd Judicial District Court of Travis County, Texas
Charles Norman White, et al. v. Fibreboard Corporation, et al.; Cause No. 92-10123 in the 353rd Judicial District Court of Travis County, Texas
Dear Mr. Dickson:
Please find enclosed verifications to be attached to Westinghouse Electric Corporation's Responses to Plaintiffs Interrogatories Mailed to Defendant On Or About April 21, 1993, which were previously filed with the Court on or about May 24, 1993. After you have placed your file mark on the enclosed copies of the verifications, please return same to me via die enclosed self-addressed, stamped envelope.
I appreciate your courtesy and cooperation and remain
Very truly yours,
Cathy Hendrickson CH/lft Enclosures cc: All counsel of record via certified mail/nr
I:\INS\CJH\LTRS\149987.1
RCV 6Y*WSTINQH0U5 LAW DEPT. ; 5-24-83 ; 5107PM I
CCITT G5'
41254246811* 4
COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY
) ) )
SS:
Before me, the undersigned authority, a Notary Public in and for said Commonwealth
and County, personally appeared Daniel D. Vkkovie, who, being duly sworn, deposes and says
that lie is ASSISTANT SECRETARY OF WESTINGHOUSE ELECTRIC CORPORATION,
and that he signs the foregoing DEFENDANT WESTINGHOUSE ELECTRIC
CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFF'S
INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21, 1993, on
behalf of that defendant amt is duly authorized so to do; that the matters stated in the foregoing
document are not necessarily within the personal knowledge of deponent and that deponent is
informed that there is no officer of WESTINGHOUSE ELECTRIC CORPORATION who has
personal knowledge of all such mailers; and that the facts stated in the foregoing document have
been assembled by authorized employees and counsel of defendant and deponent is informed by
those authorized employees that the facts stated in the foregoing document are true and correct.
SWORN TO and subscribed
before me on this 5^^ day
of S/?/ty
. 1993.
Daniel D. Vickovic Assistant Secretary
Notaiy Public
Notarial Ssal NsyofeA-Antal, Notary Pubic
1 '-'ffnnsyi.ranta Association of Notaries
WESTINGgQUSE ELECTRIC CORPORATION'S ORTECTFONS AMP RESPONSES TO PLAINTIFFS' INTERROGATORIES MAWBJ> TO DEFENDANT ON OR ABOUT APRIL 21.1993 - Rase IS