Document JNr0n7kpM0Bga4NdB7mod3Da

IN RE BRIDGEPORT ASBESTOS LITIGATION CV 96-0332364S SUPERIOR COURT IN RE-.BRIDGEPORT ASBESTOS LITIGATION VS . ABEX CORPORATION et., al. BAL#1- 8 JUDICIAL DISTRICT OF FAIRFIELD AT BRIDGEPORT AUGUST 29, 1996 RILEY STOKER CORPORATION'S ANSWERS TO PLAINTIFFS' STANDARD INTERROGATORIES Riley Stoker Corporation ("Riley Stoker" or the "Company"), pursuant to and under the protection of the Connecticut Rules of I Practice and the Bridgeport Asbestos Litigation Amended Pre-Trial Order, hereby files these answers to Plaintiffs' Standard Interrogatories (hereinafter "Interrogatories"). PRELIMINARY STATEMENT These Interrogatories concern events which occurred years ago. The answers are believed to be accurate as of the date of filing, but Riley Stoker Corporation's investigation of the underlying facts is continuing. If further discovery of additional facts, adds meaning to the known facts, or establishes new factual conclusions or legal contentions, these answers will be supplemented if required by applicable law. Thus, the 1 following answers are made without prejudice to Riley Stoker Corporation's right to produce evidence of any subsequently discovered fact or facts Riley Stoker Corporation may later recall. Riley Stoker Corporation accordingly reserves the right to amend or supplement any and all answers herein, if permitted or required by applicable law, as additional facts are ascertained, or as the contentions of the plaintiffs herein may be discovered or amended. Plaintiffs' Interrogatories are addressed to a corporation which has no independent knowledge of the information supplied in these answers. Riley Stoker Corporation refers to and is limited to the officers and directors of Riley Stoker Corporation located in Worcester, Massachusetts, and those Riley Stoker Corporation employees who the Company believes are responsible for and in possession of corporate documents or information that is responsive to plaintiffs' Interrogatories. The information supplied in these answers is based on the knowledge of Riley Stoker Corporation's employees and authorized agents as to which the affiant may not have personal knowledge of the matter stated herein. The answers contained herein are made in a good faith effort to supply as much factual information and as much specification 2 of legal contentions as is presently known, but in no way should prejudice Riley Stoker Corporation in relation to further discovery, research or analysis. Neither Riley Stoker Corporation nor any company it controlled, purchased, or acquired any interest in has ever made, mined, manufactured, sold, distributed or processed, as Riley Stoker Corporation understands these terms, any asbestoscontaining products, which Riley Stoker Corporation understands to mean thermal insulation products that contain asbestos as an ingredient.pertain boilers designed by Riley Stoker, however, had components that contained asbestos. Riley Stoker Corporation's product line of industrial and utility fuel burning equipment is marketed and sold primarily to large, sophisticated and knowledgeable commercial customers whose architects, engineers, consultants or other agents frequently specified the type, brand and quality of component parts to be utilized in the installation of their boilers. Moreover, component manufacturers supplied product selection and instructions for proper and safe application, use and installation of their asbestos products. Riley Stoker Corporation incorporates by reference this preliminary statement into the answer to each interrogatory. 3 GENERAL OBJECTIONS Riley Stoker Corporation objects to these Interrogatories on the grounds that they are overly broad, vague, unduly burdensome, beyond the scope of product identification in this litigation, and not reasonably calculated to lead to the discovery of relevant or admissible evidence. Riley Stoker Corporation also objects to the form, as well as the ambiguous and compound nature of many of the Interrogatories, in addition to the false predicate contained therein. Moreover, these Interrogatories call for information which is necessarily outside of the scope of Riley Stoker's knowledge, and therefore, each answer is formulated on the basis of the best information available to Riley Stoker. Any response by Riley Stoker Corporation to these Interrogatories does not in any way constitute a waiver as to any information which is protected by the attorney-client and/or attorney work product privileges, or any other proprietary rights or material including, but not limited to, trade secrets. Moreover, Riley Stoker Corporation objects to any interrogatory which implies or assumes that any individual plaintiff actually has an asbestos related disease or any injury 4 allegedly related to asbestos. Riley Stoker Corporation in no way admits, by responding to these Interrogatories, that any plaintiff has an asbestos related disease or injury. The burden of proof is on each plaintiff to prove that he/she has an asbestos related disease, and Riley Stoker has a constitutional right to deny same. Moreover, Riley Stoker Corporation objects to any interrogatory which is not reasonably calculated to lead to the discovery of admissible evidence. All of these objections are incorporated by reference and adopted as to each and every interrogatory contained herein. LIMITATIONS 1. Trial preparation and factual investigation are ongoing. Accordingly, Riley Stoker Corporation's answers to these Interrogatories are based solely on information known to it at the time of the service of these answers. Riley Stoker Corporation therefore reserves the right to make reference at trial, or in any other hearings, in this action, to facts and documents not identified in these answers, the existence or relevance of which is subsequently discovered by Riley Stoker or its counsel. 5 2. Plaintiffs' Interrogatories are addressed to persons who have no independent personal knowledge of the information supplied in these answers. The information supplied in these answers to Interrogatories is based upon information as to which the affiant may not have personal knowledge of the matter stated herein. INTERROGATORIES INTERROGATORY NO. 1 Identify the registered name of the answering defendant as well as all prior names or predecessor entities by which the defendant has existed. a. - For each give the current or past address, where applicable, and the state of incorporation and whether or not it is an active corporation. ANSWER NO. 1 See attached corporate history. INTERROGATORY NO. 2 Set forth and full and correct name, the principal place of business and the state and date of incorporation of the answering defendant. ANSWER NO. 2 See attached corporate history. 6 INTERROGATORY NO....3 Identify all divisions, subsidiaries or affiliated companies of the answering defendant. For each entity state whether or not it ever has or presently engages in any phase of mining, manufacturing, sale, supply, distribution, or design of asbestos or asbestos-containing products or materials. ANSWER NO. 3 See attached corporate history. INTERROGATORY NO. 4 State the name, present business address, present residence, and capacity or title of the individual signing these Interrogatories on behalf of the answering defendant. ANSWER NO. 4 Riley Stoker objects to this interrogatory to the extent it requests a residential address, and on the on the grounds that it is irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states: James Brantl, General Counsel, DB Riley Inc., P.0. Box 15040, Worcester, MA 01615-0040. 7 INTERROGATORY NO. 5 Has this defendant or any divisions, subsidiary or company listed in [sic] No. 4, ever conducted business in the states of Connecticut, Rhode Island, Maine, New Hampshire, Vermont, Massachusetts, (hereinafter referred to collectively as "New England") as well as New York and/or New Jersey, at any time from 1930 to present. If so, please state the inclusive dates during which such business was conducted. As used in the Interrogatory, the phrase "conducted business" is intended to be construed in the broadest sense, and includes, but is not limited to: a. the maintenance by you or your behalf of any office, plant, warehouse or any other structure, in fee or by lease, in New England, New York and/or New Jersey,- b. the employment by you or on your behalf of any person residing in the said states; c. the employment of any person residing outside the said states who traveled to or communicated with any person in New England, New York and/or New Jersey on your behalf; d. the transportation or deliver of any products, material or service by you or on your behalf to any person or business in New England, New York and/or New Jersey; and, e. the solicitation by you on your behalf, through any form of communication, of any person or business in New England, New York and/or New Jersey. ANSWER NO. 5 Riley Stoker objects to this interrogatory to the extent it 8 requests information concerning Riley Stoker's business activities in states other than Connecticut, and on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states that it has conducted business in Connecticut. INTERROGATORY NO. 6 Please state whether or not you have ever held a certificate of authority to do business in the State of Connecticut and the address for your registered agent for service in this state. ANSWER NO. 6 Riley Stoker states that it has been authorized to conduct business in the State of Connecticut. INTERROGATORY NO. 7 Has this answering defendant been sued under its correct name? If not, please state the correct legal name of the defendant and provide the information requested in Interrogatory No. 1 above concerning the defendant as correctly named. ANSWER NO. 7 Riley Stoker states that its legal name/is DB Riley, Inc. 9 INTERROGATORY NO. 8 Has this defendant mined asbestos at any time from 1930 to the present? ANSWER NO. 8 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states no. INTERROGATORY NO. 9 If your answer to Interrogatory 8 is "yes", please state: a. the inclusive dates during which asbestos was mined; b. the location or locations of the mine; c. the identity of each person employed by you as the highest supervisory employee at the mine, at any time from 1930 to the present, and for each such person, please state his or her 1. title, duties and responsibilities at the mine; 2. inclusive years of employment at the mine; and 3. present or last known business and residential address; d. each other present or former office, employee, agent and representative of yours who has knowledge of the mining activity; and e. the custodian, location and identity of each document in your possession, custody or control which describes or contains information relevant to the mining activity. 10 ANSWER NO. 9 Not applicable. See answer to Interrogatory No. 8 which, together with objections stated therein, is incorporated by reference. inxerrqg&tqrtlncl _1CL Has this defendant sold, distributed or supplied raw asbestos fiber at any time from 1930 to the present? ANSWER NO. 10 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states no. INTERROGATORY NO. 11 If your answer to Interrogatory 10 is "yes," then for any raw asbestos fibers sold, distributed or supplied, please describe: a. the type and grate of asbestos sold, distributed or supplied, e.g. amosite, chrysotile, crocidolite; b. the source of the asbestos fiber, including the location or locations where it was mined and the identity for each person or business which furnished, sold or supplied it to you; c. the inclusive dates of sale, distribution or supply; d. the type of container in which the raw asbestos fiber was sold, distributed or supplied, e.g. bags, drums, 11 boxes; e. the date any warnings, cautions, caveats or directions first appeared on any containers of mined asbestos fiber, the content of each warning, caution, caveat or direction, and the inclusive dates of each warning, caution, caveat or direction. f. whether the raw asbestos fiber sold, distributed or supplied to any person or business located in New England, New York and/or New Jersey or to any defendant in this litigation; g. the identity and title of each present or former officer, employee, agent or representative of yours, at any time from 1930 to the present, with knowledge of such sale, distribution or supply; and h. the identity of the custodian, location and identity of each document in your possession, custody or control which describes or contains information relevant to such sale, distribution or supply. ANSWER NO. 11 Not applicable. See answer to Interrogatory No. 10 which, together with objections stated therein, is incorporated by reference. INTERROGATORY NO. 12 If your answer to Interrogatory 11(f) is "yes", then identify each defendant or business or person you sold or distributed raw asbestos fiber to, and with regard to each please state: a. the type of raw asbestos sold to that entity; b. the year or years in which such sales were made; c. the quantity sold in each year; d. the identity of each person employed by you to direct, arrange or otherwise process such sale, distribution or supply. 12 ANSWER NO. 12 Not applicable. See answer to Interrogatory No. 10 which, together with objections stated therein, is incorporated by reference. INTERROGATORY NO. 13 Has this defendant manufactured, processed, produced, sold, distributed, supplied or furnished any product containing asbestos at any time from 1930 to the present? ANSWER NO. 13 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. 13 JKEgRSOq&TQBY_yoJ LI If your answer to Interrogatory 13 is "yes," then for each asbestos-containing product manufactured, produced, processed, sold, distributed, supplied or furnished by you, please state: a. the brand name, if any, and the generic name of the product; b. the inclusive dates of manufacture, production or supply; c. any other name, number or designation by which the product may be identified; d. a physical description of the product, including its color, shape, size and weight per unit, its texture, the percentage of asbestos content, the type of asbestos and other mineralogical content; and e. the use for which the product was manufactured or sold, e.g., as a cement, pipecovering, board, block, cloth, rope, plaster, fireproofing material, acoustical plaster or brake lining. ANSWER NO. 14 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, 14 processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Riley Stoker further responds that this interrogatory appears to be directed to manufacturers of asbestos-containing thermal insulation products. It is not apparent whether, with respect to Riley Stoker, this interrogatory seeks product information such as trade names as to Riley Stoker's own products (i.e., boilers and steam generating equipment) or, for example, trade name information with respect to asbestos-containing insulation products which may have been components of Riley Stoker boilers. In either event, Riley Stoker is unable to respond further to this interrogatory without reference to a specific boiler. INTERROGATORY NO. 15 For each product identified in your answer to Interrogatory 14 (hereinafter "your asbestos-containing products"), please identify: a. whether your designed the product, and if not, the identity of the business or person who did; b. the year in which the product was designed or developed; c. the year in which the product was first offered for 15 sale; d. the supplier or suppliers of raw asbestos used in the product, the mines where the raw asbestos was mined, and the locations from where it was shipped; e. if you did not manufacture, product or process the asbestos-containing product, but sold, distributed, supplied or furnished it, the party who manufactured, produced or processed the product, and the party who supplied it to you; f. the location or locations where each product was manufactured or produced; and g. the identity of each person employed by you a the highest supervisory employee at the place of manufacturing or production of your asbestos-containing products at any time from 1930 to the present; and for each such person, please state his or her: 1. title, duties and responsibilities; 2. inclusive dates of employment at the place of manufacture or production; and 3. present or last known business and residential address. ANSWER NO. 15 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 14. INTERROGATORY NO. 16 For each of your asbestos-containing products, please describe: a. the container in which the product was sold, distributed or supplied and the inclusive dates when it was used; 16 b. the color of the container and the inclusive dates when it was used; c. any logo or other design on the container and the inclusive dates when it appeared on the container,- d. the content of any printing on the container and the inclusive dates when it appeared on the container; e. any instructions on the container and the inclusive dates when they appeared on the container; f. any warning on the container and the inclusive dates when they appeared on the container; g. any other markings on the container and the inclusive dates when such markings appeared on any container. ANSWER NO. 16 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Riley Stoker further responds that this interrogatory appears to be directed to manufacturers of asbestos-containing thermal insulation 17 products. It is not apparent whether, with respect to Riley Stoker, this interrogatory seeks product information as to Riley Stoker's own products (i.e., boilers and steam generating equipment) or information with respect to asbestos-containing insulation products which may have been components of Riley Stoker boilers. In either event, Riley Stoker is unable to respond further to this interrogatory without reference to a specific boiler. INTERROGATORY NO. 17 Did this defendant or any of its predecessors change any aspect of the container as identified in your answer to Interrogatory 16, from the time the container was first introduced to the present? If so, then for each container, please indicate: a. each change, e.g., in size, shape or texture, or regarding the placement, modification or removal of any color, logo, design, name, word, number, instruction, warning or other marking on the container; b. the date the defendant decided to make the change; c. the date the container was actually changed; d. the reason for the change; e. each present or former employee, officer, representative or agent of yours at any time from 1930 to the present with knowledge of information regarding your decision to change some aspect of the container, and; f. the custodian, location and identity of each document in your custody, control or possession which contains information relevant to your decision to change some 18 aspect of the container. ANSWER NO. 17 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 16. INTERROGATORY NO, 18 Please identify each present and former employee, officer, agent or representative of yours who directed, handled, solicited, supervised, promoted or otherwise participated in the sale, supply, distribution, delivery, installation or removal in New England, New York and/or New Jersey at any time from 1930 to the present of any of your asbestoscontaining products. ANSWER NO. 18 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker 19 Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 19 Please describe your corporate structure concerning the manufacture, sale, advertising and supply of your asbestoscontaining products from 1930 to the present. In your answer to this Interrogatory, please identify each present or former corporate department, division or other such subdivision of yours responsible for any of these activities, and with respect to each, please identify the name, title, duties, responsibilities, and current or last known business and residential address of the highest supervising employee for each such department, division or subdivision, with knowledge of any of those activities during any time from 1930 to the present. ANSWER NO. 19 Riley Stoker objects to this interrogatory on the grounds 20 that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 20 For each person identified in your answer to Interrogatory 18, who participated in the sale of any of your asbestoscontaining products in New England, New York and/or New Jersey at any time from 1930 to the present, please state: a. the person's name, title, responsibilities and inclusive years of employment; b. each product which they sold for you; c. whether they ever sold asbestos-containing products for any other defendant in this litigation, and if so, the name of said other defendant in this litigation; d. the geographic territory in which they promoted such sales. 21 ANSWER NO. 20 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 21 For each person identified in your answer to Interrogatory 18, who participated in the distribution or supply of any of your asbestos-containing products in New England, New York and/or New Jersey at any time from 1930 to the present, please state: a. the person's name, title, responsibilities and inclusive years of employment; b. each product which they distributed or supplied for 22 you; c. the geographic territory in which they promoted the distribution or supply of your products. ANSWER NO. 21 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 22 For each person identified in your answer to Interrogatory 18, who participated in the delivery of any of your asbestos-containing products in New England, New York and/or New Jersey at any time from 1930 to the present, please state: 23 a. the person's name, title, responsibilities and inclusive years of employment; b. each product which they delivered for you; and c. the geographic territory in which they made or arranged such deliveries. ANSWER NO. 22 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 23 For each person identified in your answer to Interrogatory 18, who participated in the installation of any of your asbestos-containing products in New England, New York and/or New Jersey at any time from 1930 to the present, please 24 state: a. the person's name, title, responsibilities and inclusive years of employment; b. each product which they installed for you; c. the geographic territory in which they promoted such installations. ANSWER NO. 23 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 24 For each person identified in your answer to Interrogatory 18, who participated in the removal of any of your asbestos- 25 containing products in New England, New York and/or New Jersey at any time from 1930 to the present, please state (as used in this Interrogatory the term removal shall mean the removal or encapsulation of any asbestos-containing product from or in any structure or thing): a. the person's name, title, responsibilities and inclusive years of employment; b. each product which was removed; c. the date when each product was removed; d. the location or locations where the product was removed; e. the geographic territory in which they performed or arranged such removals. ANSWER NO. 24 Riley Stoker objects to this interrogatory on the grounds that- it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block 26 insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 25 For each person identified in your answer to Interrogatory 18, who participated in the advertising of any of your asbestos-containing products in New England, New York and/or New Jersey at any time from 1930 to the present, please state: a. name, title, responsibilities and inclusive years of employment ,- b. each product advertised, marketed or promoted; c. the method by which each product was advertised, marketed or promoted, and if by print, the name of the publication, the inclusive dates in which it appeared therein, the publisher; and the identity of asbestoscontaining products of other defendants in this litigation which also appeared in the publication d. the geographic territory in which the advertising appeared; e. the identity of all persons who have a copy of advertisements or promotional materials. ANSWER NO. 25 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker 27 Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 26 Please describe your corporate structure procedures and practices concerning the subject of employee safety and product safety in the design, development, manufacture, testing and use of your asbestos containing products from 1930 to the present. In your answer to this Interrogatory, please identify each present or former corporate department, division or other such subdivision of yours responsible for any of these activities, and with respect to each, please identify the name, title, duties, responsibilities, and current or last known business and residential address of the highest supervising employee for each such department, division or subdivision, with knowledge of any of those activities during any time from 1930 to the present. 28 ANSWER NO. 26 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 27 Please describe your corporation structure procedures and practices concerning the subject of the research and development of your asbestos-containing products from 1930 to the present. In your answer to this Interrogatory, please identify each present or former corporate department, division or other such subdivision of yours responsible for any of these activities, and with respect to each, please 29 identify the name, title, duties, responsibilities, and current or last known business and residential address of the highest supervising employee for each such department, division of subdivision, with knowledge of any of those activities during anytime from 1930 to the present. ANSWER NO. 27 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 28 Did the defendant have, between 1930 and 1967, any system or 30 follow any procedures for following technical and medical literature for new developments relating to its products containing asbestos, including new learning concerning hazards associated with asbestos. If yes, please describe such system or systems in the fullest detail you are able, including in your description any changes in the system and the years and reasons for each change. ANSWER NO. 2 B Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. 31 INTERROGATORY NO - 2 9 Were any of your asbestos-containing products stored or warehoused by you in New England, New York and/or New Jersey at any time from 1930 to the present? If so, please identify the address of each warehouse and, for each address, the identity of the product stored or warehoused there, the year or years of such storage or warehousing and the custodian, location and identity of each document in your custody, possession or control which describes or contains information relevant to such storage or warehousing. ANSWER NO. 29 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to 32 thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 30 Please identify the means by which your asbestos-containing products were transported to New England, New York and/or New Jersey at any from 1930 to the present. a. If the products were transported by rail, please identify the name or names of the railroad companies providing that service and the years during which that service was made. b. If these products were transported by truck, please identify the name or names of the carrier providing that service and the years during which the service was used. c. If the products were transported by vessel, please identify the name or names of the shiplien providing that service and the years during which the services was used. d. Please identify each present or former employee of yours responsible for coordinating the transporting or delivery of your asbestos-containing products to New England at any time from 1930 to the present,. e. Please identify each employee, officer, agent or representative of yours with knowledge of the transporting of these products and the custodian, location and identity of each document which describes or contains information relevant to these activities. ANSWER NO. 30 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of 33 admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 31 Please identify the person or business who distributed any of your asbestos-containing products in New England, New York and/or New Jersey at any time from 1930 to the present. As used in this Interrogatory, a distributor is any person or business who purchased your product for resale, use or installation or who arranged or facilitated the resale, use or installation of your product for its benefit or the benefit of any third part. For each distributor, please indicate: a. whether the distribution relationship was exclusive or non-exclusive; b. the year or years in which the distribution 34 relationship was in effect; c. the identity of the particular asbestos-containing product(s)of yours which the distributor was authorized to or did distribute, and in each year of distribution, the quantity of each product distributed; d. whether the distribution relationship was pursuant to a written or an oral agreement and in either case the terms of any such agreement; e. the name, title, and inclusive dates of employment of each present or former employee responsible for locating, developing, maintaining, supervising or otherwise coordinating the distribution of your asbestos or asbestos-containing products by the distributors identified herein at any time from 1930 to the present; f. each employee, officer, agent or representative of yours with knowledge of such distribution agreements or relationships, and the custodian, location and identity of each document in your possession, custody or control which describes or contains information relevant to such distribution agreement or relationship. ANSWER NO. 31 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to 35 thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 32 Please state whether you sold, distributed, supplied, delivered or otherwise furnished any of the following entities in New England, New York and/or New Jersey: United States Government, Central Services Agency, United States Navy, any naval shipyard, and shipyard at any time from 1930 to the present. For each entity identified by you your answer to this Interrogatory, please state: a. the brand name or trade name of the asbestos-containing -product sold, supplied, distributed, delivered or furnished by you to such person or business; b. the year or years in which the product was sold, distributed, delivered or furnished and for each year, the quantity sold, distributed, delivered or furnished; c. the means of transportation by which the product was delivered to the person or business; d. each location or locations from which the product was transported; e. the location to which the product was delivered; f. the location or locations where the product was installed, applied or used in New England, New York and/or New Jersey; g. the identity of each contractor, sub-contractor, installer or other business which ultimately installed, applied or used the product in New Ungulate, New York and/or New Jersey; h. the identity of each present or former employee, officer, agent or representative of yours responsible for supervising, overseeing, promoting, developing. 36 maintaining, or otherwise coordinating the sale, distribution, delivery or furnishing of these products to such entities,i. the name and title of each present or former employee of yours from 1930 to the present who holds or held the highest supervisory position concerning any of the activities described in subpart (h), above; and j. the custodian, identity and location of each document which refers to or contains information relevant to such sale, distribution, delivery or furnishing. ANSWER NO. 32 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos- containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 33 Did this defendant ever sell, distribute or otherwise 37 furnish any asbestos-containing products to any defendant in this litigation for delivery, use, installation or resale or redistribution in New England at any time from 1930 to the present? If so, please identify each defendant to which you sold, distributed or furnished your product, and for each defendant identified, please state: a. the brand name of each product sold, distributed or furnished to it ,- b. whether the product was intended to be used, installed, distributed or resold by that defendant in the condition when shipped by you; c. whether the product, if used, installed, distributed, or resold by that defendant was so used, installed, distributed or resold under the name indicated in your answer to subpart (a) of this Interrogatory or if not, the name under which it was intended to be used, installed, distributed or resold; d. _whether any intended use of the product by that defendant was pursuant to any relabeling agreement or other agreement, and if so, please identify and describe the agreement; e. for each product described in subparts (a-d), state the year or years in which the product was sold, distributed, delivered or otherwise furnished by you to the defendant, and for each such year, the quantity of each product sold, delivered, distributed or furnished to the defendant; f. the location where the product was delivered, applied, used or installed; g. the identity of any contractor, sub-contractor, installer or other business which ultimately applied, used or installed the product in New England, New York and/or New Jersey; h. the identity of each present or former employee, officer, agent or representative of yours with the highest supervisory, responsibility for supervising, overseeing, developing, maintaining or otherwise 38 handling the sale, distribution, delivery or furnishing of the product to that defendant; and i. the identity of each employee, officer, agent or representative of yours with knowledge of such sale, distribution, delivery or furnishing and the custodian, location, and identity of each document in your custody, possession or control which refers to or contains information relevant to such sale, distribution, delivery or furnishing. ANSWER NO. 33 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 34 Please describe the method by which you have maintained records concerning the manufacture, sale, advertising. 39 distribution, delivery and installation of each of your asbestos-containing products form 1930 to the present. In your description, please identify: a. each present or former corporate department, division or such subdivision of yours responsible for maintaining those records; b. how the records are kept, e.g. in boxes, files, on microfilm, microfiche or computer tape or disk; c. the inclusive dates of manufacture, sale, advertising, distribution, delivery and installation that the record keeping system covers; d. the location or locations where they are kept; and e. the identity of each person employed by you at any time from 1930 to the present, in the highest supervisory capacity, who is or was directly responsible for the collection and maintenance of these records, and with respect to each person, his or her 1. title, duties and responsibilities; 2. inclusive dates of employment; and 3. present or last known business and residential address. ANSWER NO. 34 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, 40 processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 35 Does your record keeping system identify: a. persons or businesses who purchased, distributed, sold, installed or used any of your asbestos-containing products in New England, New York and/or New Jersey? If so, for each person or business, does it identify: 1. the particular product purchased, distributed, sold, installed or sued, '2. the date or dates of such activities: and 3. the amount of the product used by that person or business; b. -any location where the product was 1) manufactured; 2) delivered; 3) stored; or 4) installed; c. the source or supplier of the raw asbestos fiber used in the manufacture or production of the product; and d. the manufacturer or producer of the product, if not manufactured or produced by you; and e. the process by which each product was 1) developed, 2) designed, 3)tested, 4) marketed. ANSWER NO. 35 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley 41 Stoker Corporation does not concede that its boilers are or were ''asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 36 If your record keeping system consists of microfilm, microfiche, computer tape or disk or other system whereby data is taken from other records, have you retained the documents or other materials from which the information entered into these record keeping systems was obtained? If so, please identify the custodian and location of those records. If not, please indicate the date when and the location where the records were destroyed, the custodian and location of the records prior to their destruction and each employee, representative, official or agent of yours who ordered, authorized or supervised the destruction of these records. 42 ANSWER NO. 36 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 37 Please identify any location in New England, New York and/or New Jersey where any of your asbestos products were used, applied or installed from 1930 to the present. For each location identified, please state: a. the name of the product used, applied or installed; b. each date on which the product was used, applied or installed at that location; c. the quantity of the product used, applied or installed for each date at that location; d. the person, business or employer who ultimately used, applied or installed the product at that location; e. whether you sold or distributed the product directly to the person or business ultimately installing, applying or using the product, and if not, the identity of each distributor, retailer or wholesaler of your product involved in that particular sale or distribution,f. the identity of each employee, official, representative or agent of yours who participated in the sale or distribution of the product for that location; and g. the custodian, location and identity of each document in your custody, possession or control which refers to or contains information relevant to the sale or distribution of your product and its ultimate installation, application or use at that location. 43 ANSWER NO. 37 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 38 Please identify each competitor of yours for the sale or distribution of asbestos-containing products in New England, New York and/or New Jersey at any time from 1930 to the present. As used in these Interrogatories, the term "competitor" is intended to include any person or business which manufactured, produced, processed, sold, distributed or supplied any asbestos-containing products intended for 44 the same or similar use as any asbestos-containing product of this defendant. ANSWER NO. 38 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steamgenerating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 39 For each competitor identified in Interrogatory 38, please identify: a. each asbestos-containing product which it sold or distributed in New England, New York and/or New Jersey, and with respect to each, your asbestos-containing product(s) intended for the same or similar use; and b. each person or business in New England, New York and/or 45 New Jersey which sold, supplied or distributed its asbestos-containing products. ANSWER NO. 39 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 38. INTERROGATORY NO. 40 Are you aware that any other miners, millers, manufacturers, distributors or suppliers of asbestos or asbestos-containing products have placed a warning concerning pulmonary hazards on any of its products? If your answer is in the affirmative, please identify each miner, miller, manufacturer, distributor or supplier and the date, by month and year, that it placed a warning on each of its products. ANSWER NO. 40 Riley Stoker objects to this interrogatory to the extent it assumes Riley Stoker is a miner, miller, manufacturer, distributor or supplier of asbestos or asbestos-containing products, and on the grounds that it is vague, ambiguous, 46 overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 41 Have you ever conducted any dust studies in any of your asbestos product manufacturing facilities? If so, please state: a. the date of each such study; b. the person conducting the study; c. the result or conclusion; d. who presently has possession of the report or study; e. the purpose of each study. ANSWER NO. 41 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block 47 insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 42 Has this defendant or any of its predecessors ever changed the percentage of asbestos in any of its asbestos-containing products manufactured or produced since 1930? If so, then for each product in which the asbestos content has been changed, please identify: a. the name of the product; b. the original asbestos content beginning in 1930 or in any year thereafter, when it was first produced if the product was not produced in 1930; c. each change in the asbestos content; d. the year in which each change occurred; e. the reason for each change in the asbestos content; and f. the identity of each employee or officer of yours who participated in any decision or was present at any meeting at which the decision to change the asbestos content was discussed or made. ANSWER NO. 42 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam- 48 generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 43 Did this defendant or any of its predecessors ever discontinue using asbestos in any of the products identified in your answer to Interrogatory 14, or introduce an asbestos-free product as a replacement, substitution or alternative for any of your asbestos-containing products? a. If you discontinued using asbestos in any of the products identified in your answer to Interrogatory 14, please state: 1. the name of the product; 2. the date on which asbestos was removed from the product; 3. the reason for discontinuation or removal of asbestos from the product; and 4. the identity of each employee or officer of yours who participated in the decision or was present at any meeting at which the decision to remove or discontinue using asbestos in the product was discussed or made. ANSWER NO. 43 Riley Stoker objects to this interrogatory on the grounds 49 that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 44 Did you ever conduct or has anyone on your behalf conducted any tests concerning the human health consequences of the use of your asbestos-containing product. If so, please state: a. what tests were done; b. who was responsible for conducting the tests; c. what the results of the tests were, and d. identify any documents concerning the tests. ANSWER NO. 44 Riley Stoker objects to this interrogatory on the grounds 50 that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 45 Did you ever conduct any tests concerning the human health consequences related to the manufacture of your asbestoscontaining product. If so, please state: a. what tests were done; b. who was responsible for conducting the tests; c. what the results of the tests were; and d. identify any documents concerning the tests ANSWER NO. 45 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome 51 and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 46 Do any written memoranda, specifications, recommendations or other written material of any kind or character exist related to the testing referred to in Interrogatory Nos. 44 and 45? If so please state: a. identity of each such written material or document,b. the present custodian of each such document and where the document located. ANSWER NO. 46 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of 52 admissible evidence. Without waiving its objections, Riley Stoker states see answers to Interrogatories No. 44 and 45. INTERROGATORY NO. 47 Have you ever conducted any tests concerning the human health consequences of the use and manufacture of your product following the date that the asbestos content was removed from said products or materials? If so, please state: a. what tests were done; b. who was responsible for conducting the tests,c. what the results of the tests were; and d. identity any documents concerning the tests. ANSWER NO. 47 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to 53 thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 48 When, if ever, did you specifically inform the purchaser or user of your products or materials that contained asbestos that the use of that product or material exposure to asbestos dust could cause cancer, asbestosis or other serious disease? Please identify the document containing this information by date and location. ANSWER NO. 48 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block 54 insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 49 Identify any and all labeling or relabeling agreements for asbestos-containing products in existence since 1930 between you and any other person including defendants as defined in the introductory Instructions and Definitions. ANSWER NO. 49 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states none. INTERROGATORY NO. 50 Has this defendant ever acquired the assets, stock or property of another person, corporation, company or business entity which manufactured, sold, processed or distributed products or materials containing asbestos? ANSWER NO. 50 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome 55 and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving it objections, Riley Stoker states see attached corporate history. INTERROGATORY NO. 51 If the answer to the above interrogatory is "yes," please state the following concerning such other persons or entities: a. the full and correct name; b. the principal place of business; c. the state of incorporation; d. the date of its acquisition by you; and e. the products or materials that theother person or entity manufactured, distributed, sold or used; f. the date of the agreement; h. whether the agreement contained any provisions regarding indemnification to you by such other person or entity for any claims concerning the condition or merchantability of the product; and i. the custodian and location of the original agreement and each note, draft, memorandum or correspondence relating to the agreement. ANSWER NO. 51 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 50. 56 INTERROGATORY NO. 52 Is the defendant the result of, or the surviving corporation of any combination, consolidation, merger or reorganization involving another person, corporation, company, partnership or business entity which mined, manufactured, produced, sold, distributed or supplied asbestos or any asbestos- containing product or material from 1930 to the present? ANSWER NO, 52 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and hot reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see attached corporate history. INTERROGATORY NO. 53 If your answer to Interrogatory 52 is "yes," then for each such person or business, please state: a. its full and correct name,b. its date of incorporation and principal place of business; c. the date of its incorporation; d. the date of the combination, consolidation, merger or reorganization e. a description of any contract or agreement describing the combination, consolidation, merger or reorganization; f. the name, title and present or last known business and residential address of the signatories of any agreement 57 identified in subpart (e); g. the name, title and present or last known business and residential address of the custodian of each record which describes or relates to the said combination, consolidation, merger or reorganization. ANSWER NO. 53 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 52. INTERROGATORY NO. 54 For each product manufactured, sold or distributed by you state: a. whether or not you have actual containers or photographs of containers in which said products were sold or distributed; b. the name of the custodian or keeper of said containers or photographs including his/her address and telephone number. ANSWER NO. 54 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or 58 were "asbestos-containing products. Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Riley Stoker further responds that this interrogatory appears to be directed to manufacturers of asbestos-containing thermal insulation products. It is not apparent whether, with respect to Riley Stoker, this interrogatory seeks product information as to Riley Stoker's own products (i.e., boilers and steam generating equipment) or information with respect to asbestos-containing insulation products which may have been components of Riley Stoker boilers. In either event, Riley Stoker is unable to respond further to this interrogatory without reference to a specific boiler. INTERROGATORY NO. 5 5 State whether or not any warnings, cautions, caveats or directions accompanied the raw asbestos fiber referred to in Interrogatory 15 (e) and identify the nature and extent of said warnings, cautions, caveats or directions accompanying 59 said fiber. ANSWER NO. 55 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 15. INTERROGATORY NO. 56 When was the first time that you received notice that any person was claiming an injury as the result of using asbestos-containing products manufactured and/or sold by your company, including, but not limited to, worker's compensation claims. ANSWER NO. 56 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, 60 processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 57 For each such asbestos related injury that you received notice of a claim prior to December 31, 1973, please list: a. the name and address of each claimant; b. the date of the notice of each claim; c. a description of the claim (i.e., worker's compensation, disability, or a third-party liability action); d. the type of injury allegedly sustained; e. the name and address of each attorney who represents -individuals making such claims; f. the jurisdiction or district and the court number of each claim; g. the resolution of each claim that has been disposed of and h. the custodian of the records that relate to the claim (in lieu of answering the above question, you may attach copies of any and all claims). ANSWER NO. 57 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. 61 INTERROGATORY NO. 58 Do you contend that products containing asbestos can be manufactured or treated so as to eliminate all potential health hazards to workers installing the same? If so, please explain in detail what your contentions are and the basis for each contention. ANSWER NO. 58 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. Riley Stoker further objects on the ground that this interrogatory seeks an opinion that Riley Stoker is not qualified to render. INTERROGATORY NO. 59 Did you receive any reports or communications from your worker's compensation insurance carrier, or products liability insurance carrier, with regard to the hazards incident to the use of asbestos-containing products? If so, please state who has possession of such reports, the location of such reports and the substance of the contents of such reports, listing for each such report the respective 62 insurance company, its address, the agents signing such correspondence and the date of such notice or report. ANSWER NO. 59 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states no. INTERROGATORY NO. 60 Have any of the co-defendants named in this litigation ever furnished you with any information as to the state of the medical knowledge regarding the connection between asbestos dust exposure and the contracting of pulmonary diseases including asbestosis and cancer? ANSWER NO. 60 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving these objections, Riley Stoker states no. INTERROGATORY NO. 61 If the answer to the preceding Interrogatory is in the 63 affirmative, please identify: a. what information you were furnished; b. who furnished that information; and c. when the information was furnished. ANSWER NO. 61 Not applicable. See Answer to Interrogatory No. 60 which, together with objections stated therein, is incorporated by reference. INTERROGATORY NO. 62 Have you at any time since 1930 exchanged results of research tests, medical studies or experiments regarding the state of the medical knowledge regarding the connection between asbestos exposure and the contracting of pulmonary diseases including lung cancer and asbestosis with any other person, including any co-defendants in this action? ANSWER NO. 62 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states no. 64 INTERROGATORY NO. 63 If the answer to the preceding interrogatory is in the affirmative, please state: a. when this interchange took place; b. who participated in these interchanges; and c. summarize the content of these interchanges or studies. ANSWER NO. 63 Not applicable. See Answer to Interrogatory No. 62 which, together with objections stated therein, is incorporated by reference. INTERROGATORY NO. 64 Please state if you or anyone on your behalf ever conducted, sponsored or contributed financially to any studies or research to determine if the inhalation of asbestos fibers may be harmful. ANSWER NO. 64 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and seeks information not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states no. INTERROGATORY NO. 65 If the answer to the above question is in the affirmative. 65 please state: a. by whom the research was conducted, giving complete names and addresses; b. the dates that each such research project or test was conducted; c. the complete results of each test or study; d. identify all documents that refer, reflect or relate to the test or study; and e. supply copies of the reports of the research department pertaining to the use by the corporation of asbestos in the manufacture of its products. ANSWER NO. 65 Not applicable. See Answer to Interrogatory No. 64 which, together with objections stated therein, is incorporated by reference. INTERROGATORY NO. 66 Please state the names and addresses of your chief medical officers from 1930 until the present time, listing the periods of time each such medical officer was employed by defendant in that capacity. If you did not have a medical officer, please indicate what person or persons performed that function. ANSWER NO. 66 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and reasonably calculated to lead to the discovery of 66 admissible evidence. Without waiving its objections, Riley Stoker states that it did not employ a chief medical officer. INTERROGATORY NO. 67 Please state the names and addresses of all physicians who were employed, retained or otherwise engaged by you at any of your manufacturing facilities from the years 1930 until the present. ANSWER NO. 67 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and seeks information not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states that it did not employ physicians. INTERROGATORY NO. 68 Please state the names and addresses of all persons employed by you from 1930 until the present time who functioned as industrial hygienist. As used in this interrogatory, an Industrial Hygienist is one who performs engineering or health studies to identify and evaluate potential 67 occupational health hazards and suggest methods of dealing with the same. ANSWER NO. 6 8 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states that it did not employ an Industrial Hygienist. INTERROGATORY NO. 69 For each Industrial Hygienist listed above, please state: a. the facility or office to which that individual was assigned; and b. the complete and precise duties and responsibilities. ANSWER NO. 6 9 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 68. INTERROGATORY NO. 70 Please identify each statement, conclusion, warning, 68 recommendation or suggestion made to you pertaining to the risks and hazards associated with the manufacturing or use of products containing asbestos. ANSWER NO. 70 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 71 With respect to each communication identified in your answer to Interrogatory 70, please state: a. where the communication was made; b. who made the communication; c. to whom the communication was made; 69 d. the substance of the communication; and e. what actions did you take as the result of it. ANSWER NO. 71 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 70. INTERROGATORY NO. 72 Do you agree that there is a causal connection between exposure to asbestos dust and: a. asbestosis; b. lung cancer; c. mesothelioma,d. other cancers of the gastrointestinal tract; e. cancer of the larynx and kidney. ANSWER NO. 72 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states that at sometime after 1972, Riley Stoker became aware that some diseases were alleged to be associated with exposure to asbestos. Riley Stoker does not 70 know precisely how or when it became aware of such allegations. INTERROGATORY NO. 73 If your answer to the previous interrogatory is "yes" as to any or all subparts, please identify the following as to each disease process listed above: a. when and how you first learned of such connection; b. if the knowledge was obtained by the attendance at any conference, lecture, convention, symposium or meeting, identify such event and provide the name of the person attending or the documents obtained from that meeting; c. if knowledge was obtained from a medical or scientific study or any other published works, identify the same; d. if the knowledge was otherwise obtained, identify the manner of receipt of the document or communication. ANSWER NO. 73 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states that at sometime after 1972, Riley Stoker became aware that some diseases were alleged to be associated with exposure to asbestos. Riley Stoker does not know precisely how or when it became aware of such allegations. 71 INTERROGATORY NQ. 74 With regard to any knowledge obtained subsequent to that identified in the previous interrogatory, please identify: a. all documents or other communications, oral or written, concerning the causal connection between exposure to asbestos dust or asbestos products and the disease processes identified in Interrogatory No. 72 above; and b. identify the person communicating the information. ANSWER NO. 74 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states that at sometime after 1972, Riley Stoker became aware that some diseases were alleged to be associated with exposure to asbestos. Riley Stoker does not know precisely how or when it became aware of such allegations. INTERROGATORY NQ. 75 If you do not agree that there is a causal connection between exposure to asbestos dust and any of the diseases listed in Interrogatory No. 72, please state in full detail all the facts on which the defendant bases a contention that there is not such a causal connection. 72 ANSWER NO. 75 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 72. INTERROGATORY NO. 7S When and by what manner were did management personnel of your company first become aware of the hazards of exposure to asbestos or asbestos-containing products? ANSWER NO. 76 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states that at sometime after 1972, Riley Stoker became aware that some diseases were alleged to be associated with exposure to asbestos. Riley Stoker does not know precisely how or when it became aware of such allegations. INTERROGATORY NO. 77 Identify any medical examination programs offered or 73 sponsored by you or your insurance carrier for employees handling or otherwise exposed to asbestos and asbestos containing products. With respect to each such program, please state: a. the manner of communicating with employees about such program; b. whether the examination was mandatory or optional; c. what percentage of workers permitted to undergo such examination actually participated; d. what percentage of workers were found to have either asbestosis, mesothelioma, or bronchogenic carcinoma; e. with respect to (d), what percentage of such workers were paid disability, worker's compensation benefits or for whose benefit medical expenses were paid to undergo treatment for such condition. ANSWER NO. 77 Riley Stoker objects to this interrogatory on the grounds that"it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block 74 insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 78 Identify all trade organizations, associations or other entities, including but not limited to ATI, IHF, NAIMA, AIA, NICA, QAMA, PICA, QAPA, to which you have belonged or in which you have participated since 1925 and the years of your participation. ANSWER NO. 78 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states that it has never belonged to an asbestosrelated trade or industry organization or association. INTERROGATORY NO. 79 Identify all persons attending on your behalf any meetings held by any trade organization listed in the Interrogatory stated above. ANSWER NO. 79 Riley Stoker objects to this interrogatory on the grounds 75 that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 78. INTERROGATORY NO. 80 Identify by name or nature all notes, reports, studies or other writings submitted by you or received you at meetings identified in the interrogatory stated above. ANSWER NO. 80 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 79. INTERROGATORY NO. 81 Identify any documents you received from or submitted to those trade organizations, associations or other entities identified in Interrogatory 78 relating to the relationship between asbestos exposure and disease. ANSWER NO. 81 Riley Stoker objects to this interrogatory on the grounds 76 that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 78. INTERROGATORY NO. 82 Did you direct, sponsor, finance or receive the results of any studies or tests performed by the Saranac Laboratory or the Trudeau Foundation relating to asbestos exposure and its effect on human life? If so, please identify: a. all documents summarizing findings or results of those studies or tests which you have in your possession or control; b. all communications, oral or written, between answering defendant and Saranac personnel, including but not -limited to Gerrit W. H. Schepers, M.D.; c. all documents relating to Saranac studies received or submitted by you, either directly, through associated or predecessor companies, through other companies, or through any trade associations, organizations or entities; d. all recommendations or findings of such studies in relating to: 1. adequacy or inadequacy of the threshold limited values; 2. the substitution of materials other than asbestos to be used in the insulation process; and e. where the documents and/or communications identified in this interrogatory are presently maintained. ANSWER NO. 82 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome 77 and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states no. INTERROGATORY NO. 83 Identify all persons who have testified on your behalf and all documents presented to or utilized in preparation of testimony before the Occupational Safety and Health, any U.S. Congressional committee or sub-committee or governmental hearing or investigative proceeding on the subjects of biological effects on human life from exposure to asbestos and the setting, modification, feasibility and acceptance of allegedly safe or proper levels of such exposure to asbestos and asbestos products. ANSWER NO. 83 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states none. INTERROGATORY NO. 84 For all testimony set forth above, please identify: a. the dates and descriptions of the proceedings; 78 b. the relationship between the person who testified or responded and you, c. all studies, tests results or other scientific or medical documents relied upon by said person as a basis for any recommendation made or testimony given; d. whether at any time prior to or following such testimony you possessed knowledge of documents suggesting that existing or proposed threshold limit values were not safe or proper or that lower threshold limit values were necessary in order to prevent disease, as to this response, please identify the origin of the knowledge and all documents relating thereto; and e. whether at any time prior to or following such testimony you were aware that the proper method for determination of safe levels of asbestos dust was to test concentrations of fibers in the air rather than the total number of particles. IF your answer is in the affirmative, identify the origin of said knowledge and all documents relating thereto. ANSWER NO. 84 Not applicable. See Answer to Interrogatory No. 83 which, together with objections stated therein, is incorporated by reference. INTERROGATORY NO. 85 What do you understand "threshold value limit" to mean and what is being measured when you take the measurement of threshold limit value as you define it? ANSWER NO. 85 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly 79 burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 86 What do you understand "dose response relationship" to mean? ANSWER NO. 86 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 87 Did you ever state in advertising that any of your asbestos containing products were suitable for use on ships or navy vessels: If yes, please state: a. name of product; b. intended use of product; c. years you advertised product; d. where you advertised product. ANSWER NO. 87 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of 80 admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. In further answering, Riley Stoker states no. INTERROGATORY NO. 88 Prior to the first time you used asbestos in any of your products, did you conduct any tests on: a. the effects of asbestos on the health of human beings; and/or b. the level of asbestos dust in the air when your product was used as intended; If yes, fully describe each such test. ANSWER NO. 88 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of 81 admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. In further answering, Riley Stoker states no. INTERROGATORY NO. 89 Prior to the first time you used asbestos in any of your products did you conduct any research in the medical or scientific literature on the effects of asbestos on the health of human beings. If so, fully describe: a. the research done; b. when it was done; c. who conducted the research; and the results of the research. ANSWER NO. fl9 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome 82 and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. In further answering, Riley Stoker states no. INTERROGATORY NO. 90 If the defendant has policies of insurance that might cover the claims that have been made by the plaintiff herein, please list: a. the name of each insurance carrier,b. the amount of such coverage,- and c. the dates of each such policy. ANSWER NO. 90 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of 83 admissible evidence. Without waiving its objections, Riley Stoker states that it anticipates that it has sufficient insurance coverage with which to satisfy reasonable judgments in these cases. INTERROGATORY NO. 91 Please identify each and every job site in the states of Rhode Island, Massachusetts and Connecticut on which you were a contractor, or provided a boiler, furnace, turbine, or generator, from the period of 1930 until 1985 inclusive. For each job site, state: a. the inclusive dates you were on the job; b. the insulation contractors and or subcontractors who were on the job; c. the type of job (e.g., powerhouse, industrial plant, etc.); d. the steamfitting contractors and or subcontractors who were on the job; e. the spray contractors and or subcontractors who were on the job; f. any and all safety precautions against the hazards of inhaling asbestos fibers you undertook on the job, for the protection of persons on the job site, including but not limited to your own employees and those of other contractors or subcontractors; g. whether any provision of the contract or any subcontract arising thereof called for or specified the use asbestos containing products; h. whether you have knowledge of any asbestos containing products used on the job. ANSWER NO. 91 Riley Stoker objects to this interrogatory on the grounds 84 that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states that it is unable to respond to this interrogatory without reference to a specific boiler. INTERROGATORY NO. 92 If your response to subpart (h) above is in the affirmative, state, for each such job site; a. the basis of your knowledge; b. the type, brand name, manufacturer and quantity used for each such asbestos containing product; c. whether the asbestos containing products were; 1. purchased by you; and/or 2. used by you; d. who you purchased the products from; e. whether the asbestos containing products were supplied or furnished to the job site by you or delivered to the job site to your attention. ANSWER NO. 92 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation states see Answer to Interrogatory No. 91. 85 INTERROGATORY NO. 93 For each job site listed in response to Interrogatory 93, state the name, title and union affiliation of each person employed by you on that job. ANSWER NO. 93 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 94 Please identify: a. each present or former employee of yours who has been both employed by you (concerning the sale, promotion, development, research and safety of asbestos-containing products or materials) and who was also a present or former employee of any other defendant in this litigation or any other company which manufactured, processed, developed, sold, distributed or supplied asbestos-containing products or materials; b. with respect to each person identified, please identify their former employer, their title and duties and responsibilities as an employee of any other defendant in this litigation or any other company which manufactured, processed, developed, sold, distributed or supplied asbestos-containing products or materials; c. with respect to each person, please identify, their title and duties and responsibilities as an employee of yours and the inclusive dates of their employment with you; and d. their title and duties and responsibilities as an 86 employee of any other defendant in this litigation or any other company, and the inclusive dates of their employment with that other defendant or other company, if applicable ANSWER NO. 94 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 95 Has this defendant ever placed any warranties, guarantees or other such representations on any of its asbestos or asbestos-containing products or materials, or on or in the containers in which those products were sold, distributed or supplied at any time from 1930 to the present? If so, then for each asbestos product or material, please identify: a. the product or material; b. the inclusive dates on which each warranty, guarantee, or other representation appeared on or with the product or on or in the product's container; c. the exact content of each warranty, guarantee or other representation; d. the location on the product or container where each warranty, guarantee, or other representation was placed; e. if the content or placement of any warranty, guarantee or other representation was ever changed, and if so, then for each change: 87 1. the nature of the change; 2 . the date when the content or placement of the warranty, guarantee, or other representation was changed; 3. the reason for change; and 4. the inclusive dates during which the changed warranty, guarantee or other representation appeared on or with the product of its container; f. the name and title of each of your present or former highest supervisory employees with knowledge of the decision to place any of the aforementioned warranties, guarantees of other representations or the decision to place any of them on or with your asbestos products. ANSWER NO. 95 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. 88 INTERROGATORY NO. 96 Did this defendant make any representation at any time from 1930 to the present that the use of asbestos in any of its products or materials made these products superior, in any way, to any asbestos-free product or material intended for the same or similar use? If so, then with respect to each representation, indicate: a. the date or dates on which the representation was made; b. its exact content; c. the manner in which it was communicated. In lieu of answering subpart (b), you may attach a copy of the representation to these answers. ANSWER NO. 96 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block 89 insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 97 Did this defendant make any representations at any time from 1930 to the present that the use of asbestos or the use of its asbestos-containing products or materials was safe, harmless or not dangerous. If so, then with respect to each representation indicate: a. the date or dates on which it was made; b. its exact content; c. the manner in which it was communicated. In lieu of answering subpart (b), you may attach a copy of the -representation to these answers. ANSWER NO. 97 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled 90 asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 98 Please give the name and address of each person between 1930 and 1967 who had the responsibility for following any new developments or new learning concerning industrial hygiene as it related to your products, indicating whether such person is still alive or not. ANSWER NO. 98 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 99 Please identify, including in your identification, the name and address of the person who has custody of such records, all records which relate to the subject matter of the answers to Interrogatories No. 28. 91 ANSWER NO. 99 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see Answer to Interrogatory No. 28. INTERROGATORY NO. 100 Between 1930 and 1967, did any trade association to which the defendant belonged hold any meetings {including committee meetings), send any written material of any kind to any of its members, or send any communication to the defendant, concerning a possible, probable or alleged association between exposure to asbestos dust and any pulmonary disorder or disease. ANSWER NO. 100 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states no. INTERROGATORY NO. 101 If you answered the previous Interrogatory No. 100 in the 92 affirmative, please identify each such meeting, written material or communication by giving for each: a. the date; b. the place of such meeting or origination of such written material or communication; c. the names and addresses of all persons involved in any way; d. the subject matter of each. ANSWF.R NO. 101 Not applicable. See answer to Interrogatory No. 100 which, together with objections stated therein, is incorporated by reference. INTERROGATORY NO. 102 Please identify by giving its date, the names and addresses of the author and the person to whom it was directed, each and every document, memorandum, letter or writing of any kind addressed to or written by any employee of the defendant concerning any possible, probable, or alleged association between exposure to asbestos dust and any pulmonary disease or disorder, written between January 1, 1930 and January 1, 1968. ANSWER NO. 102 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome 93 and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 103 Please identify defendant's workers compensation, disability and or health insurance carriers or adjusters (if self- insured) from 1930 to the present. For each insurer please state: a. type of coverage; b. dates of coverage; c. whether defendant's rates were increased due to health hazards associated with defendant's employees exposure to asbestos containing products; d. whether any insurance company has denied coverage to you or any subsidiary or division because of asbestos dust conditions at your plant, employee lung disease complaints or any other reason related to asbestos; e. if yes, identify the insurance carrier, the reason for the denial and the dates of each denial. 94 ANSWER NO. 103 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 104 Between 1930 and 1968, did the defendant require or suggest that its employees take any precautions against the inhalation of asbestos dust. ANSWER NO 104 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block 95 insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 105 If you answered the previous Interrogatory No. 104 in the affirmative, for each such precaution please state: a. the date that each was first required or suggested; b. a full description of each such precaution; c. the reason(s) why each precaution was suggested or required; d. the name and address (indicating whether living or dead) of the person or person responsible for requiring or suggesting each such precaution; and, e. a full statement of the wording of each such suggestion or rule requiring each precaution. ANSWER NO. 105 Riley Stoker objects to this interrogatory as vague, ambiguous, overly broad, unduly burdensome and not reasonable calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker states see answer to Interrogatory No. 104. INTERROGATORY NO, 106 If you contend that the defendant could not have known prior to: (a) 1940; (b) 1950; or (c) 1960 that exposure to asbestos dust by workers who worked with or around asbestos products could cause pulmonary injuries or disease, please state, in detail, all the facts on which the defendant 96 relies to support such a contention. ANSWER NO. 106 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objections, Riley Stoker Corporation does not concede that its boilers are or were "asbestos-containing products." Riley Stoker Corporation is a manufacturer of boilers and steam generating equipment, and never designed, manufactured, processed, sold, distributed, patented, or relabeled asbestos-containing products, including but not limited to thermal insulation products such as pipecovering, block insulation and insulation cement. Therefore, this interrogatory is not applicable as to Riley Stoker. INTERROGATORY NO. 107 Have you ever had asbestos removed or abated from any building you own. If so, please state why it was removed, who decided it would be removed, and identify all documents which concern the decision and implementation of the removal. 97 ANSWER NO. 107 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 108 Do you contend that there is any difference between chrysotile fiber, amosite fiber, crocidolite fiber and/or tremolite fiber in the development of mesothelioma or lung cancer? If so, explain in detail your contention as to the distinction between or among fiber types in the development of each disease. ANSWER NO. 108 Riley Stoker objects to this interrogatory on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. Riley Stoker further objects on the ground that this interrogatory seeks medical and/or scientific opinions that Riley Stoker is not 98 qualified to render. INTERROGATORY NO. 109 Prior to answering these Interrogatories, have you made due and diligent search of all books, records, and papers as well as diligent inquiry of all agents and employees of defendant to elicit all possible relevant information. If yes, pleas identify what records or books and papers were searches and what agents and employees were questioned. ANSWER NO. 109 Riley Stoker objects to this interrogatory on the grounds that it is irrelevant to the subject matter of the pending litigation and not reasonably calculated to lead to the discovery of admissible evidence. Furthermore, Riley Stoker states that it compiled the information in these answers from various sources. In doing so, Riley Stoker has complied with its obligations under the applicable rules of 99 court to conduct a reasonable investigation in order to prepare its answers. RILEY STOKER CORPORATION By its Attorneys, DATED: August 29, 1996 Lawrence G. Cetrulo, Esq. Kevin E. Young, Esq. Christopher R. Smith, Esq. Cetrulo & Capone 53 State Street Exchange Place Boston, MA 02109 (617) 624-0111 #1B561 100 VERIFICATION COMMONWEALTH OF MASSACHUSETTS ) COUNTY OF WORCESTER ss JAMES S. BRANTL, being duly sworn, deposes and says that he is an authorized agent of DB Riley, Inc., and that he verifies the foregoing DB Riley, Inc.'s Answers to Plaintiff's Standard Interrogatories for and on behalf of DB Riley, Inc.; that certain of the matters stated therein are not within the personal knowledge of deponent; that the facts stated therein have been assembled by authorized employees and counsel of DB Riley, Inc., and deponent is informed that the facts stated therein are true. SWORN TO BEFORE ME and subscribed in my presence this day of August 1996 . j2th t. My commission expires: January 17, 2003