Document JNDzxnr63oBnNMZ4x7DR098YZ

FILE NAME Reichhold REI DATE 2014 DOC REI042 DOCUMENT DESCRIPTION Legal - Answers to Plaintiff's Interrogatories IN THE CIRCUIT COURT FOR THE CITY OF ST LOUIS STATE OF MISSOURI TWENTY SECOND JUDICIAL CIRCUIT JEFF KOVAR ) Plaintiff ) ) VS. ) Case No CC01123 ) UNION CARBIDE CORPORATION ) et al ) JURY TRIAL DEMANDED Defendants ) DEFENDANT REICHHOLD INC.'S OBJECTIONS AND ANSWERS TO PLAINTIFF'S FIRST INTERROGATORIES TO Plaintiffs by and through their attorney of record Gerald J. FitzGerald O'Brien Law Firm P.C. 815 Geyer Avenue St. Louis Missouri 63104 Defendant Reichhold Inc. makes the following Objections and Answers to Plaintiff's FirstFirst Interrogatories PRELIMINARY STATEMENT AND GENERAL OBJECTION As a threshold matter Reichhold states that these responses are based upon facts known or believed by Reichhold at the time ofanswering these discovery requests These discovery responses are made pursuant to a reasonable and diligent investigation and search for the information requested Reichhold reserves the right to amend these responses if new or additional information becomes available to it Thousands of employees have worked at Reichhold over the years In conducting business Reichhold has created many documents kept in numerous geographic locations that have been moved as required Accordingly Reichhold does not represent that the answers contained herein provide all information requested rather these answers reflect information obtained before this date by Reichhold pursuant to a reasonable and diligent search and investigation in those areas where this information was expected to be found To the extent that the interrogatory purports to require more Reichhold objects on the grounds that compliance with the interrogatory is not feasible and would impose an undue burden or expense Plaintiffs may have some pertinent documents perhaps even some Reichhold documents not in Reichhold's possession Reichhold objects to these discovery requests on the grounds that it would be less burdensome more convenient and less expensive for Plaintiffs to identify what documents Plaintiffs already have that may fall within the scope of these discovery requests This would accomplish several purposes ) it would obviate Reichhold having to search for and copy documents already in Plaintiffs possession 2 it would enable Reichhold to use the documents Page 1 14 Page of Case No. CC01123 provided as guides in looking for related material and 3 it would if the purpose is to obtain authentication enable Reichhold to authenticate the copies provided by you without having to conduct an uninformed search for the documents Reichhold also objects to Plaintiffs discovery requests to the extent they seek information regarding any Reichhold facility or operation located outside ofthe United States Reichhold states that its discovery responses herein are limited to Reichhold's operations located within the United States II The objections set forth herein are hereby incorporated into all ofthe subsequent responses as if fully set forth in each particular answer and response where appropriate III Subject to the foregoing objections and without waiving same Reichhold answers as follows ANSWERS TO INTERROGATORIES 1. Identify the person verifying these Answers on behalf of Defendant including their full name address length of employment with this Defendant and current job title Answer Reichhold objects that this Interrogatory seeks information protected from disclosure by the right to privacy Reichhold also objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections see verification attached hereto 2 Identify by full name address and job title your Custodian of Business records Answer Reichhold objects that this Interrogatory seeks information protected from disclosure by the right to privacy Reichhold also objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections Reichhold reserves its right to supplement this Interrogatory as needed 3 Has Defendant ever had a document retention policy your Answer is yes identify the date of each such policy and specify its document retention requirements Page 2 14 Pag 2 e 14 Case No. CC01123 Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections Reichhold states that it has a current document retention policy However and responding further Reichhold's former Carteret New Jersey facility commercially manufactured molding compounds that may have contained short chrysotile in a bonded matrix Reichhold states that it sold its molding compound business to BTL Specialty Resins in June 1986. The terms of the sales agreement between Reichhold and BTL required Reichhold to transfer all documents pertaining to its molding compound operations to BTL 4 With respect to Defendant please identify a The full and correct name b All names by which Defendant has been known or has conducted business and the dates during which it has been known by or conducted business under each such name ^d The principal place of business ^d Each state in which Defendant maintains an office for the usual and customary transaction of business 04i The present state of incorporation 04i Whether Defendant is authorized to transact business in the State ofMissouri and if so the date such authority was first issued and last renewed and g The location of each agent representative and place of business in Missouri Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections Reichhold states that it was originally incorporated in or about 1930 as Beck Koller & Company Inc. Its name was changed to Reichhold Chemicals Inc. in 1938. Reichhold Chemicals Inc. became Reichhold Inc. on or about February 10 1998. Reichhold is a Delaware corporation with its principal place ofbusiness at 1035 Swabia Court Durham NC 27703 Reichhold is authorized to conduct business in the State of Missouri Reichhold currently owns and operates one manufacturing facility in Missouri The address is 249 St. Louis Avenue Valley Park Missouri 63088. To the best of its knowledge Reichhold has never manufactured any containing products at this facility and neither the facility itself nor any products Page 3 of 14 Page of 14 Case No. CC01123 manufactured by this facility are at issue in this case Reichhold's current registered agent for service of process in Missouri is CSC Lawyers Incorporating Service Company 221 Bolivar Street Jefferson City Missouri 65101 5. Identify by full and complete trade name all thermoset plastics thermo plastic plastic resin and plastic compound materials which you or any predecessor entity has at any time a Designed or contracted to design b Manufactured or contracted to manufacture C. Processed or prepared or contracted to process or prepare d Sold or contracted to sell e Distributed or contracted to distribute f acquire sic Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections Reichhold commercially manufactured molding compounds at its former Carteret New Jersey facility starting in approximately 1964. Some of those molding compounds contained short chrysotile in a bonded matrix This chrysotile asbestos added strength and heat resistance to molded plastic products From the time Reichhold began commercially manufacturing molding compounds in 1964 it always manufactured some compounds that did not contain chrysotile asbestos Reichhold began phasing out the use of chrysotile in 1974 and believes the phase was influenced by thenanticipated changes in government regulations on permissible levels of exposure during the manufacturing of such compounds The ability to phase out asbestos in all molding compounds was impacted by the lack of adequate asbestos substitute materials for all types of compounds and customer resistance to molding compounds for certain applications that did not contain asbestos Reichhold believes it completed the phase out of asbestos in molding compounds by the end of 1980 or early 1981. Reichhold discontinued asbestos usage because of increased difficulty and cost of complying with OSHA regulations regarding the use of asbestos as a raw material at its Carteret New Jersey manufacturing facility Reichhold no longer manufactures molding compounds because Reichhold sold the molding compounds business in June 1986 Reichhold believes that its molding compounds were sold packaged in bags drums or Gaylords bearing the name Reichhold Chemicals Inc. or RCI Reichhold's molding compounds were granular in texture They were made with an exclusive extrusion process that historical Page 4 14 Page 4 of 14 Case No. CC01123 documents described as dust free Reichhold affixed labels to packages that said in pertinent part Avoid breathing dust or vapors Avoid contact with skin and eyes Use only with adequate ventilation Use protective equipment and clothing for continued handling and to avoid breathing dust or vapors . READ MATERIAL SAFETY DATA SHEET BEFORE USING Reichhold has a copy of a Material Safety Data Sheet dated January 1980 for approximately seven containing molding compounds that said in pertinent part While it would not be expected that under normal handling and use of this compound free asbestos fiber would be released subsequent processing such as drilling sanding milling and filing may release asbestos fibers Refer to Section Asbestos 1910.1001 of the Occupational Safety and Health Regulation Reichhold also believes that in or by 1972 packages of containing molding compounds came with a warning that said Caution Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Seriously Bodily Harm Reichhold does not possess any documents that enable it to determine the precise date of initial issuance of warning labels and Material Safety Data Sheets MSDS The MSDS for the Phenolic Molding Compounds contained the following statements among others Section IV Fire and Explosion Hazard Data Wear contained breathing apparatus if fighting fire in a confined area such as a warehouse Dust mixtures are explosive Section V Health Hazard Data For asbestos - 2 fibers per cc air Fine dust may occur when handling Use a respirator at all times when handling to avoid breathing dust Wear gloves when handling Wash before smoking or eating In contact with skin wash with soap and water at first opportunity Flush eyes with plenty ofwater for at least 15 minutes Section VII Spill or Leak Procedures Vacuum or sweep up Use sweeping compound to avoid creating dust Ventilate area well Wear respirator if dust is generated Waste disposal method 1 incinerate 2 land fill in accordance with State and Federal regulations Section VIII Special Protection Information Respirator for nuisance dust and if asbestos fibers released Chemical resistant plastic or rubber gloves recommended Wear chemical goggles at all times Dust collection should be included as part of mechanical ventilation Section IX Special Precautions Avoid exposure to temperature extremes and moisture Both affect product performance Do not breathe heated vapors from molding process Asbestos fibers in molding compounds are encapsulated in a bonded matrix and thus would not be released under normal handling and use ofmolding compounds While initial OSHA asbestos regulations did not require warnings on such products Reichhold still included the standard OSHA warnings on packages of molding compound in an abundance of caution 6 For each asbestos thermoset plastics thermo plastic plastic resin and plastic compound materials referred to in Answer 5 above identify whether asbestos was ever an ingredient Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and Page 5 14 Page of 14 Case No. CC01123 C without waiving these objections see Reichhold's answer to Interrogatory No. 5 above 7 For each asbestos thermoset plastics thermo plastic plastic resin and plastic compound materials referred to in Answer 5 above identify the following a The product's packaging b Writing that appears on the product packaging including any logos c Colors of products packaging and colors of writing , including logos on product's packaging d The name and current or last known address of each current or former employee with knowledge of the design manufacturing and sale of asbestos containing products Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 5 above Responding further Reichhold personnel responsible for warnings and MSDS for molding compounds include former employees Tom Madden and Charles Windsor deceased 8 If you have stopped producing distributing and selling any of the asbestos thermoset plastics thermo plastic plastic resin and plastic compound materials listed in Answer 5 state for each product J^^ The reason you stopped J^^ The date you stopped J^^ Whether any studies were conducted before you directed that production and sale to be stopped and if so identify each such study by title date author and subject matter Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery ofadmissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 5 above Responding further see documents produced by Reichhold 9 State whether any brochures writing or other materials written or photographic were made available to distributors drywall commercial buyers installation workers users or the general public concerning the design manufacture distribution selling installation and use of the asbestos thermoset plastics thermo plastic plastic resin and plastic Page 6 14 Page Case No. CC01123 compound materials referred to in Answer 5. For each such brochure or material identify the material author date and present location and custodian Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery ofadmissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 5 above Responding further see documents produced by Reichhold 10 Between 1958 and 1978 did you or any predecessor entity sell or deliver any material or products to the Square D Facility located in Cedar Rapids Iowa If your Answer is yes identify a Type brand name full name and complete trade name of each product sold . and delivered to facility b The dates on which each product identified in a was sold and delivered to the facility c | Which products identified in a contained asbestos as any part ingredient or component d The type grade brand name full name and complete trade name of asbestos in each product identified in a e The products package f Writing that appears on the product packaging including logos g Colors of products packaging and colors of writing including logos on product's packaging h Each entity from which you or any predecessor entity acquired each product identified in a for sale or delivery to the facility ) Each warning which you provided with each product identified in a and ( All persons who were involved with or who have knowledge of the sale or delivery of each product identified in a Specify which person is the most knowledgeable concerning each product at the facility Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections Reichhold's former Carteret New Jersey facility commercially manufactured molding compounds that may have contained short chrysotile in a bonded matrix Reichhold states that it sold its molding compound business to BTL Specialty Resins in June 1986. The terms of the sales agreement between Reichhold and BTL Page 7 of 14 Case No. CC01123 required Reichhold to transfer all documents pertaining to its molding compound operations to BTL Accordingly records and information which might be responsive to this Interrogatory if any ever existed are no longer in Reichhold's possession 11 Between 1958 and 1978 did you or any predecessor entity have any contracts or agreements with any entity to provide sell or supply materials or products to the Square D Facility located in Cedar Rapids Iowa If your Answer is yes identify a The date of each contract or agreement b Each entity with which you or any predecessor entity had each agreement c The materials or products provided sold or supplied to each entity identified in b at each location d The name address job title and employer of all persons who were involved with or who have knowledge of each contract or agreement Specify which person is the most knowledgeable concerning each subject matter Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 10 incorporated herein 12. With respect to any product you or any predecessor entity sold or distributed to the Square D Facility located in Cedar Rapids Iowa between 1958 and 1978 did you or any predecessor entity ever provide to anyone any warning or caution or like information concerning any of the following a b c d Answer Asbestos or containing products Possible health effects hazards or any other risks associated with exposure to asbestos or containing materials Threshold limit values of exposure to asbestos and | Recommendations related to working with or around asbestos or asbestos- containing materials Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery ofadmissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 10 incorporated herein Page 8 14 14 Page of 14 Case No. CC01123 13 At any time between 1958 and 1978 did you sell deliver or have contracts to provide a phenolic compound theromoset plastic resin and plastic compound material identified as 25310 25346 25347 25338 25397 25398 25506 92936 and 92506 to the Square D Facility located in Cedar Rapids Iowa If so for each state a The dates on which it was sold and delivered to the facility b The amount delivered on each date identified in a c The type grade brand name full name and complete trade name of asbestos in the phenolic compound theromoset plastic resin and plastic compound material ; d The products package , Writing that appears on the product packaging including logos , Colors of products packaging and colors of writing including logos on product's packaging How it was delivered to the facility Each warning which you provided with the product and All persons who were involved with or who have knowledge of the sale or delivery of the phenolic compound theromoset plastic resin and plastic compound material Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery ofadmissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 10 incorporated herein 14 Between 1978 and 1995 did you or any predecessor entity sell or deliver any material or products to the Square D Facility located in Springfield Missouri Ifyour Answer is yes identify a Type brand name full name and complete trade name of each product sold and delivered to the facility b The dates on which each product identified in a was sold and delivered to the facility c Which products identified in a contained asbestos as any part ingredient or component d The type grade brand name full name and complete trade name ofasbestos in each product identified in a e The products package f Writing that appears on the product packaging including logos g Colors of products packaging and colors of writing including logos on product's packaging h Each entity from which you or any predecessor entity acquired each product identified in a for sale or delivery to the facility i Each warning which you provided with each product identified in a and Page 9 of 14 Page of 14 Case No. CC01123 ( Answer All persons who were involved with or who have knowledge of the sale or delivery of each product identified in a Specify which person is the most knowledgeable concerning each product the facility Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections Reichhold's former Carteret New JerseyJersey facility commercially manufactured molding compounds that may have contained short chrysotile in a bonded matrix Reichhold states that it sold its molding compound business to BTL Specialty Resins in June 1986. The terms of the sales agreement between Reichhold and BTL required Reichhold to transfer all documents pertaining to its molding compound operations to BTL Accordingly records and information which might be responsive to this Interrogatory if any ever existed are no longer in Reichhold's possession 15 Between 1978 and 1995 did you or any predecessor entity have any contracts or agreements with any entity to provide sell or supply materials or products to the Square D Facility located in Springfield Missouri If your Answer is yes identify a The date of each contract or agreement b _ _Each entity with which you or any predecessor entity had each agreement c The materials or products provided sold or supplied to each entity identified in b at each location d The name address job title and employer of all persons who were involved with or who have knowledge of each contract or agreement Specify which person is the most knowledgeable concerning each subject matter Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 14 incorporated herein 16 With respect to any product you or any predecessor entity sold or distributed to the Square D Facility located in Springfield Missouri between 1978 and 1995 did you or any predecessor entity ever provide to anyone any warning or caution or like information concerning any of the following a Asbestos or containing products Page 10 14 14 14 Page of Case No. CC01123 b 33 33 Answer Possible health effects hazards or any other risks associated with exposure to asbestos or containing materials Threshold limit values of exposure to asbestos and Recommendations related to working with or around asbestos or asbestos- containing materials Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery ofadmissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 14 incorporated herein 17 At any time between 1958 and 1978 did you sell deliver or have contracts to provide a phenolic compound theromoset plastic resin and plastic compound material identified as 25310 25346 25347 25338 25397 25398 25506 92936 and 92506 to the Square D Facility located in Springfield Missouri If so for each state a The dates on which it was sold and delivered to the facility b The amount delivered on each date identified in a (c) The type grade brand name full name and complete trade name ofasbestos in the phenolic compound theromoset plastic resin and plastic compound material ; <The products package 39 Writing that appears on the product packaging including logos 39 Colors of products packaging and colors of writing including logos on product's packaging 033 How it was delivered to the facility 033 Each warning which you provided with the product and 033 All persons who were involved with or who have knowledge of the sale or delivery of the phenolic compound theromoset plastic resin and plastic compound material Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 14 incorporated herein 18 Has Defendant ever provided to anyone a warning or caution concerning any of the following a Asbestos or containing thermoset plastic materials Page 11 of 14 Case No. CC01123 b c d Answer Possible health effects hazards or any other risks associated with exposure to asbestos or containing thermoset plastic materials Threshold limit values of exposure to asbestos and Recommendations related to working with or around asbestos or asbestos- containing thermoset plastic materials Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery ofadmissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 5 incorporated herein 19 If your Answer to the preceding interrogatory is yes identify a The date the first warning or caution was provided b The content of the warning or caution c The date of each change of the warning or caution and d | The changes made on each date identified in c Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery ofadmissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 5 incorporated herein 20 Has Defendant ever placed a caution advisory or warning related to asbestos thermoset plastics thermo plastic plastic resin and plastic compound materials If your answer is yes identify a type brand name full name and complete trade name of each product on which a caution advisory or warning was placed b The date on which the caution advisory or warning was first placed on each product identified in a c The exact wording location and size of the caution advisory or warning which was first placed on each product identified in a and d Pursuant to Missouri Rule of Civil Procedure 56.01 identify and provide the location of each p erson whom you believe has knowledge ofthe caution advisory or warning identified herein oe Page 12 of 14 Case No. CC01123 Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections see Reichhold's answer to Interrogatory No. 5 incorporated herein 21 Identify the date on which the Defendant first became aware that exposure to asbestos could cause a Mesothelioma b c Lung cancer and Asbestosis Answer Reichhold objects to this Interrogatory as compound impermissibly vague overly broad unduly burdensome and harassing Reichhold also objects to this Interrogatory because it is not relevant and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving the foregoing objections Reichhold denies that chrysotile in bonded matrix such as is found in molding compounds causes mesothelioma or any asbestosrelated diseases based on published scientific information Reichhold does not currently know when it first received information about the potential dangers from breathing some forms of asbestos fibers Reichhold generally received information on regulations promulgated by federal OSHA on topics of workplace safety Reichhold is aware of an internal memorandum dated December 22 1971 that includes as attachments a copy ofthe asbestos OSHA regulations section 29 CFR 1910.93a and an April 1 1970 Asbestos Toxicology Report from Union Carbide Page 13 14 Case No. CC01123 Respectfully submitted By Tracy J. Cowan 40229 Reno R. Cova III 57155 10 S. Broadway Suite 1300 St. Louis MO 63102 Phone 314-678-8600 Fax 314-678-8686 tcowan@hptylaw.com rcova@hptylaw.com Attorneys for Defendant Reichhold Inc. OF COUNSEL HAWKINS PARNELL THACKSTON & YOUNG LLP 84699v.1 Page 14 of 14 Case No. CC01123 STATE OF NORTH CAROLINA COUNTY OF DURHAM ) SS ) JOHN OLDHAM of lawful age and being first duly sworn on his oath states that the above Objections and Answers to Plaintiff'sPlaintf's First Interrogatories KOVAR KOVAR of Defendant Reichhold Inc. are true and correct to the best of his knowledge information and belief REICHHOLD INC JOHN OLDHAM Title Director of Site Remediation SUBSCRIBED AND SWORN TO before me this it day of APRIL 2014 ----,--... My Commission Expires Nov. 2014 Notary Public ----,--... Defendant Reichhold Inc.'s Objections and Answers to Plaintiffs First Interrogatories