Document Jr7NXaQNaM7kGLe0N1B4qoDGe

'LAINTIFF'S exhibit IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO ELDON CLAUDE DICKERSON AND RUTH VIRGINA DICKERSON, Plaintiffs, CASE NO. 398302 (JUDGE HARRY A. HANNA) -vs- A-BEST PRODUCTS COMPANY, ET AL,, Defendants. RSC-1 DEFENDANT. ROCKBESTOS-SURPRENANT CABLE CORPUS ANSWERS AND OBJECTIONS TO PLAINTIFFS' FIRST MASTER SET OF INTERROGATORIES Defendant THE ROCKBESTOS COMPANY n/k/a Rockbestos-Surprenant Cable Corp. (hereinafter referred to as "Rockbestos"), by and through counsel of record, Hermann Cahn & Schneider, as and for its responses to Plaintiffs' First Master Set of Interrogatories, sets forth the following: GENERAL OBJECTIONS Rockbestos, a Delaware Corporation with its principle place of business in East Granby, Connecticut, makes the following general and specific objections to Plaintiffs' First Master Set of Interrogatories (the "discovery requests") which appear generally to have been prepared for cases pending against thermal insulation manufacturers and not against wire and cable manufacturers. These objections are asserted to each of the discovery requests propounded by the Plaintiffs. Within the context of these general and specific objections. Rockbestos asserts that it has made reasonable efforts to locate and/or compile responsive information and will attempt to prov ide answers to these discovery requests, or parts thereof. In so proceeding, Rockbestos does not waive its right to assert any objection to such discovery request, including the following general and specific objections. Rockbestos reserves the right to advance such objections and to supplement, modify or amend them at a later time if any effort is made by any party to obtain more specific answers to these discovery requests than as herein provided by Rockbestos. On the basis of this foregoing general statement of objection, the following continuing objections are made to Plaintiffs' discovery requests: 1. The discovery requests as drawn are directed to a myriad of defendants, generally, whose business operations involved the manufacture and sale of asbestos-containing insulation and other products without any attempt to tailor or individualize the discovery requests to obtain information reasonably calculated to lead to the discovery- of admissible evidence against Rockbestos. Rockbestos only manufactures wire and cable products, some of which formerly contained bonded, saturated and encapsulated chrvsotile asbestos. Rockbestos did not manufacture and sell asbestos-containing insulation or any other asbestos-containing product. As a result, such general discovery requests are overly broad, unduly burdensome and not reasonably calculated to lead the discovery of admissible evidence against Rockbestos. 2. Rockbestos objects to Plaintiffs' discovery requests to the extent that they seek the general or "corporate knowledge" of Rockbestos or its employees in as much as it is impossible to set forth the corporate knowledge of all Rockbestos employees, past and present. 3. Rockbestos objects to Plaintiffs' discovery requests as overly broad and not reasonably calculated to lead to the discovery of admissible evidence insofar as they are unlimited in scope as to time or as to a specific Rockbestos product to which the Plaintiffs claim exposure. 4. Rockbestos objects to each discovery request as vague and ambiguous to the extent that it contains terms that are undefined or to the extent that the definitions provided for those terms go beyond the customary and accepted definitions of those terms. 5. Rockbestos objects to each discovery request to the extent that it seeks information or the production of documents which are privileged as attorney work-product, attorneyclient communications, or as self-critical analysis. The foregoing general objections to Plaintiffs' discovery requests for production are incorporated by reference into each and every Rockbestos response that follows as though and as if the same had been set forth fully at length therein. Rockbestos does not waive its right to object at trial, on any ground, whether or not asserted herein. Discovery is ongoing and Rockbestos expressly reserves the right to amend its responses to the discovery requests as allowed under the applicable rules governing the Courts of the State of Ohio. INTERROGATORIES I. For each Interrogatory below, please state the name and last known address of each person answering it, including whether he/she is employed by Defendant and ifemployed by Defendant include job title, length oftime employed by Defendant and a year by year list of all other positions, titles, or jobs held when working for Defendant. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as harassing and overly burdensome. The responses to these interrogatories are provided based upon conversations with many Rockbestos employees over many years. It would be extremely burdensome, if not impossible, for Rockbestos to identify each and every individual who provided information that went into the preparation of these responses. 1.1 Please identify all documents used, related to, or referred to in connection with the preparation ofor answers to these Interrogatories and state the number of the Interrogatory and its subpart to each such document. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and harassing. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogator}' exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 2. Please state whether or not Defendant is a corporation, [f so, please state: (a) Your correct corporate name; (b) The state of your incorporation; (c) The address of your principal place of business; (d) Your registered agent for service in the state of Ohio; t e) For each Defendant claiming that this Court lacks personal jurisdiction, list year by year the total amount ofincome received by Defendant from entities in Ohio, any and all years that Defendant, as defined, has been licensed to do business in Ohio, and any real property owned at any time by Defendant or its present or past subsidiaries. ANSWER: a. Rockbestos-Surprenant Cable Corp. b. Delaware c. 172 Sterling St. Clinton, Massachusetts d. United States Corporation, Co. 16 E. Broad St. Columbus, OH 43215 e. N/A 3. State Defendant's complete corporate or business history, including dates of incorporation, mergers, consolidations, reincorporations, and the like. Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs. In addition: (a) if Defendant or any of its predecessors or subsidiaries at anytime purchased, assumed, or in any other manner acquired ANY of the assets and/or liabilities of any corporation or entity at any prior time engaged in any aspect ofthe placing of asbestos-containing products into the stream of commerce or the insuring of asbestos related risks, then please state the following as to each acquisition: (b) the name or description of each corporation, entity or assets acquired by Defendant, that entity's state of incorporation and principal place ofbusiness, its date of incorporation, and the name of Defendant at the time of acquisition; (c) the manner by which each such corporation, entity or interest therein, was acquired (e.g., merger, consolidation, change of name, stock sale, transfer or purchase of assets or product line); (d) the date of each such acquisition; (e) the state in which each such acquisition was effected; (f) the state law governing each such acquisition if specified by contract; (g) whether Defendant became legally responsible for the past torts of each such corporation or entity; (h) identify each document reflecting or related to the history and/or transaction(s) set forth in answer to this Interrogatory. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as it is unlimited in scope as to time and therefore not reasonably calculated to lead to the discovery of admissible evidence. W ithin this context and subject to these objections, Rockbestos states that it is a successor in interest to the Rockbestos Products Corp. which was organized in Delaware in 1920. Rockbestos states that effective June 1, 1996, Rockbestos acquired the assets ofthe Surprenant Cable Corp. Unless and until Plaintiffs allege exposure to any product manufactured by Surprenant Cable Corp., Rockbestos objects to the balance of this interrogatory as neither relevant to the subject matter ofthis litigation nor reasonably calculated to lead to the discovery of admissible evidence. 4. Please state whether or not Defendant has purchased, assumed, or in any other manner acquired any ofthe assets and/or liabilities o fany corporation or entity (such corporations or entities being limited to those engaged in the mining, selling, manufacturing, marketing or distribution of asbestos- containing products.) If so, please state the following: (a) the name or description of each corporation, entity or assets acquired by Defendant, its state ofincorporation and principal place ofbusiness, its date of incorporation, and the name of Defendant at the time of acquisition; (b) the manner by which each such corporation, entity, or interest therein, was acquired (e.g. merger, consolidation, change of name, stock sale, transfer or purchase of assets or product line); (c) the date of each such acquisition; (d) the state in which each such acquisition was effected; (e) the state law governing each such acquisition if specified by contract; (0 whether Defendant became legally responsible for the past torts of each such corporation or entity; (g) whether the acquisition concerned asbestos-containing products. .ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is duplicative of interrogatory no. 3a. See Rockbestos' answer and objections to interrogatory no. 3. -4- 4.1 For each corporation, other than the answering Defendant, that has at any time in the past been involved in the placing ofasbestos-containing products into the stream ofcommerce for which officers of the answering Defendant's corporation have also served as officers, directors or served in any managerial position while employed by the answering defendant, state: (a) the name ofthe entity involved in the placing ofasbestos products into the stream of commerce; (b) the manner in which the entity was involved in the plac ing o fasbestos containing products into the stream of commerce (i.e., mining, milling, manufacturing, distributing, installing, rebranding, etc.); (c) the specific products placed into the stream o fcommerce by the entity, year by year and by brand or trade name; (d) the name, positions and a briefdescription ofthe responsibilities ofthe person or persons serving the answering Defendant and the entity simultaneously, including the positions held with the entity and with the answering Defendant. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome as it is unlimited in scope as to time and the information sought as it is irrelevant to the subject matter ofthis litigation and not reasonably calculated to lead to the discovery of admissible evidence. 5. Has Defendant ever engaged in the mining, manufacturing, selling, marketing, installation or distribution of asbestos-containing products? If so, please state the following: (a) The name of the company engaged in the activity (whether it is Defendant, Defendant's predecessor, Defendant's subsidiary or some other entity related to Defendant); (b) As to each product mined, manufactured, sold, marketed, installed or distributed, please state the following: (1) The trade or brand name. (2) Its identification number (model, serial number, etc.). (3) The time period it was manufactured, mined, marketed, distributed or sold. (4) Its physical description including color, general composition, and form. (5) A detailed description of its intended use and purpose. (6) A detailed description ofthe type [sic] package in which it was sold, listing the dates of each type of package used, a physical description of the package, and a description of any printed material or trademarks that appeared thereon. (7) The percent of asbestos which it contained. (8) The percent of asbestos by asbestos type (amosite, crocidolite, tremolite, anthophyllite, chrysotile). -o- (c) The time period during which each of these products were on the market; (d) The material component's/ingredients ofeach such product, giving specific or approximate percentage both by weight and by volume of each material component/ingredient (this interrogatory is not limited to the asbestos component ofthe product but seeks information as to the nature, weight and volume ofnonasbestos ingredients, as well) of each such product; (e) How each ofthese asbestos-containing product can be distinguished from those of competitors; (0 A description of the physical appearance of such product; (g) A detailed description of the intended uses. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as harassing, unduly burdensome, overly broad and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs claim exposure. This interrogatory is also objectionable because it seeks the disclosure ofconfidential trade secret information. Within this context and subject to these objections, Rockbestos states that it only manufactures wire and cable products, some of which formerly contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos never mined, manufactured, sold, marketed, installed or distributed any raw asbestos or other asbestos-containing product. Rockbestos manufactured its bonded, saturated and encapsulated chrysotile asbestos-containing wire and cable productsfrom 1920 through 1986. Rockbestos states that it would be impossible to list each and every wire and cable product containing bonded, saturated and encapsulated chrysotile asbestos that it manufactured from 1920 to 1986, and to provide the exact mineralogical content of each product, as Rockbestos manufactured literally hundreds ofdifferent types of wire over that period oftime and the composition of the wire varied over time. Many Rockbestos wire and cable products contained no asbestos at all. In an effort to respond to this interrogatory, Rockbestos states that it utilized only chrysotile asbestos in the construction ofits asbestos-containing wire and cable products. The purpose ofRockbestos' wire and cable products was to conduct electrical -6- current. Rockbestos' wire and cable products were packaged on reels, spools and in boxes. Rockbestos' logo was an hourglass in a circle. Ifthe Plaintiffs can identify a specific Rockbestos product to which they claim exposure, and the dates ofthe alleged exposure, it is possible that more information might be supplied. 6. Does Defendant or any ofits subsidiary companies claim that any patent would cover any product listed in answer to Interrogatory No. 5 If so, please state the following: (a) The date of each patent; (b) The date same was issued; (c) The number of each patent application that is pending. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year time period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that to the extent is possesses documents responsive to this interrogatory, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are available for inspection at reasonable times upon reasonable notice. 7. Have any of the products listed above in answer to Interrogatory No. 5 been altered in chemical composition since first being marketed? If so, please state the following: ( a) The trade name of each such product; (b) The date each such product was altered; (c) The nature of the alteration; (d) The reason for the alteration. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it is unlimited in scope as to time or as to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos further objects to this interrogatory on the grounds that it is -7- vague and ambiguous in its use ofthe undefined phrase "altered in chemical composition." Within this context and subject to these objections, Rockbestos states that it would be impossible to list each and every wire and cable product containing bonded, saturated and encapsulated chrysotile asbestos that it manufacturedfrom 1920 to 1986, and to provide the exact mineralogical content ofeach product, as Rockbestos manufactured literally hundreds ofdifferent types of wire over that period oftime and the composition ofthe wire varied over time. Ifthe Plaintiffs can identify a specific Rockbestos product to which they claim exposure, and the dates ofthe alleged exposure, it is possible that more information might be supplied. See also, Rockbestos ' answer and objections to interrogatory no. 5. 8. Have any ofthe asbestos-containing products listed in response to Interrogatory No. 5 ever been marketed, distributed, packaged, labeled, and/or sold by any other company or business? If so, please state the following: (a) The name and address of each such company. (b) The names and address of Defendant's distributors in Ohio, West Virginia, Pennsylvania and Kentucky since 1940. (c) The date of each sale. (d) The name of the person at each location with whom you primarily dealt. (e) A list of all asbestos-containing products that you sold to each location from 1945 to 1980. (f) The amount of each asbestos product sold to each location during this period. (g) Please identify all documents relating to this distnbutor for the particular location. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year time period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times and upon reasonable notice. Ifthe Plaintiffs can -8- identify a specific Rockbestos product to which they claim exposure, and the dates ofthe alleged exposure, it is possible that more information might be supplied. 8.01 Has Defendant ever purchased asbestos-containing products from any other Defendant? ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it is unlimited in scope as to time or as to particular products to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times and upon reasonable notice. Ifthe Plaintiffs can identify a specific Rockbestos product to which they claim exposure, and the dates ofthe alleged exposure, it is possible that more information might be supplied. 8.02 If the answer to the preceding Interrogatory is yes, please state the following: (a) name each Defendant from whom this Defendant purchased any asbestoscontaining product; (b) list each product purchased from each co-Defendant; (c) list the dates of each purchase of asbestos-containing products from each co- Defendant. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, see Rockbestos' answer and objections to interrogatory no. 8. 8.03 Has Defendant ever sold asbestos-containing products to any other Defendant? ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly -9- broad, unduly burdensome and not reasonably calculated to lead to the discover ofadmissible evidence as it seeks information over a 66 year period and is not limited to particular products to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times and upon reasonable notice. Ifthe Plaintiffs can identify specific products to which they claim exposure, and the dates of the alleged exposure, it is possible that more information might be supplied. 8.04 If the answer to the preceding Interrogatory is yes, please state the following: (a) name each Defendant to whom this Defendant sold any asbestos-containing product; (b) list each product sold to each co-Defendant; (c) list the dates of each sale ofasbestos-containing products to each co-Defendant. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, see Rockbestos' answer and objections to interrogatory no. 8.03. 8.05 Has Defendant engaged in the manufacture and/or sale and/or distribution and/or marketing and/or supply and/or purchase and/or use ofnon-asbestos-containing products for use in connection with temperatures above 125 0 Fahrenheit since 1930? If so, please state: (a) the date such activity began; (b) the years during which such activity took place; (c) the date when such activity was terminated; (d) if such activity was terminated, the reason(s) why; fe) the geographical area into which you claim the product(s) were sold, purchased, or used; (0 identify the organizational unit of Defendant so engaged; (S) the site(s) at w hich each such product was manufactured; (h) the material components of each such product, giving specific or approximate percentage both by weight and by volume of each material component of each such product; (0 the temperature ranges for which each product(s) was intended to be used; (J) the product's generic name; 00 the product's trade or brand name; -10- (l) the container in which the product was shipped (i.e., paper bags, cardboard boxes) including the size and amount of the container; (m) a description ofany logos, writing impressions or identifying markings which appeared on the product, as well as a description of the package used, the dates that type ofpackage was used, and any logos, product names, trademarks, etc. which appeared on the package; (n) whether the words "non-asbestos" or "asbestos free" were used on the package; (o) a detailed description ofthe intended method ofpreparation and application ofthe product; (p) a description of the physical appearance of the product, including size, shape, color and texture. A XSIVER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as harassing, unduly burdensome, overly broad and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs claim exposure. This interrogatory is also objectionable because it seeks the disclosure ofconfidential trade secret information. Within this context and subject to these objections, Rockbestos states that it only manufactured wire and cable products. Rockbestos states that it would be impossible to list each and every non asbestos containing wire and cable product that it manufacturedfront 1930 to the present, and to provide the exact ntineralogical content ofeach product, as Rockbestos manufactured literally hundreds of different types of wire over that period oftime and the composition of the wire varied over time. In an effort to respond to this interrogatory, Rockbestos states that the purpose ofRockbestos' wire and cable products was to conduct electrical current. Rockbestos' wire and cable products were packaged on reels, spools and in boxes. Rockbestos' logo was an hourglass in a circle. Ifthe Plaintiffs can identify a specific Rockbestos product to which they claim exposure, and the dates ofthe alleged exposure, it is possible that more information might be supplied. 8.06 Did Defendant ever market or distribute any asbestos-containing product manufactured -11- in whole or in part by someone else0 If so, please state the following for each such product: (a) the name and address of the manufacturer; (b) the product's trade and brand name; (c) the organizational unit of Defendant who did so; (d) date(s) beginning, ending and during which the marketing or distributing took place; (e) whether the product was distributed through the same channels as those used for products manufactured by Defendant, and ifnot, please explain the exact channels of distribution; (f) identify all documents relating the marketing or distribution. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that, to the best ofits knowledge, the answer is no. 8.1 Does Defendant have reason to believe that any ofthe asbestos-containing products listed in response to Interrogatory No. 5 were used at any of the sites listed on Exhibit A, attached hereto? If your answer is "yes", please state: (a) The basis of your answer. (b) Which ofDefendant's asbestos-containing products listed in Interrogatory No. 5 were used at each job site listed on Exhibit A. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year time period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that it possesses a summary ofthe sales of bonded, saturated and encapsulated chrysotile asbestos-containing wire and cable products onlyfor the years 1981-96; except that documents ofsales to nuclear power plants are retainedforforty (40) years pursuant to government regulations. A review ofthe 1981 to -12- 1986 summary does not reveal any sales ofRockbestos' asbestos-containing wire and cable products to any ofthe entities listed on Exhibit A during that time period. To the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are availablefor inspection at reasonable times and upon reasonable notice. Ifthe Plaintiffs can identify a specific Rockbestos product to which they claim exposure, and the dates of the alleged exposure, it is possible that more information might be supplied. 8.2 For each company or business that Defendant knows may have marketed, distributed, installed, and/or sold those products listed in response to Interrogatory No. 5, please state the following as to each job site listed on Exhibit A: (a) The name and address of each such company; (b) The date of each sale from Defendant to such other company; (c) The name ofthe person at each other company with whom Defendant primarily dealt. (d) Names and quantities of the asbestos-containing products that you marketed, distributed, installed, and/or sold to each such company from 1950 to 1974. (e) Identify all documents relating to the sales to each such company. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year time period and is not limited to a particular product to which the Plaintiffs allege exposure. Within this context and subject to these objections, to the extent documents responsive to this interrogatory exist and are in Rockbestos' possession, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are available for inspection at reasonable times upon reasonable notice. See also, Rockbestos' answer and objections to interrogatory no. 8.1. 8.3 Ifyou do not know any business that may have marketed, distributed, installed, and/or sold the products listed in response to Interrogatory No. 5 to any ofthejob sites listed on Exhibit A, please state -13- the names and last known addresses ofthose companies who Defendant knows marketed, distributed, installed and/or sold their asbestos-containing products in Ohio from 1950 to 1974. For each of those companies, please state the following: (a) Name and address of each such company; (b) The dates of each sale from Defendant to such other company; (c) The name ofthe person at each other company with whom Defendant primarily dealt; (d) The names of the asbestos-containing products that Defendant marketed, distributed, and/or sold to each such company from 1950 to 1974. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 24 year period and is not limited to a particular product to which Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times and upon reasonable notice. 8.4 Does Defendant have records and/or any knowledge that reflects sales oftheir asbestoscontaining products to any ofthe sites listed on Exhibit A, attached hereto? If so, please state the following as to each job site listed on Exhibit A: (a) The names and last known addresses of those people with such knowledge. (b) The location of such records. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, see Rockbestos' answer and objections to interrogatory no. 8.L -14- 9. Did Defendant or any of Defendant's distributors, as listed in response to Interrogatory Nos. 8.1,8.2, and/or 8.3 have sales representatives who specifically called on the sites listed on Exhibit A, attached hereto, from 1945 to 1975? Ifyour response is yes, as to each site listed on Exhibit A, please state the following: (a) (b) (c) (d) (e) The name and last known address ofeach such representative and whether they are still employed by Defendant; The period of time they acted as your representative; Their general responsibility as to each facility; Whether that person is still alive; and Any documents relating, referring or pertaining thereto. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 30 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, see Rockbestos' answer and objections to interrogatory nos. 8.1, 8.2 and 8.3. 9.1 Identify all managers and sales personnel responsible for your sales or installation ofany asbestos-containing products in Ohio from 1930 to the present and state their position, last known address and the local or regional office through which they were employed. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 56 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, see Rockbestos ' answer and objections to interrogatory nos. 8.1, 8.2 and 8.3. -15- 10. Did Defendant ever have any division or subsidiary engaged in the contract business of applying or removing asbestos-containing products? If so, please state: (a) The name of each subdivision; (b) The full address ofthe home office and the date such subdivision or subsidiary was engaged in this contracting business; and (c) Whether said division or subsidiary conducted such business at any ofthe sites listed on Exhibit A from 1940 to 1975? Ifso, please state the following as to each job site listed on Exhibit A: (1) The dates of such contracts; (2) The specific asbestos-containing products that were used or removed in each contract. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 35 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos further objects to this interrogatory on the grounds that it is vague and ambiguous in its use of the undefined phrase "contract business. " Within this context and subject to these objections, and as Rockbestos understands the phrase "contract business, " to the best ofRockbestos ' knowledge, the answer is no. 11. Did Defendant ever have any division or subsidiary engaged in the contract business of applying or removing asbestos-containing refractory? Ifso, please give the name ofeach subdivision, the full address ofthe home office and the date such subdivision or subsidiary was engaged in this contracting business. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos further objects to this interrogatory on the grounds that it is vague and ambiguous in its use ofthe -16- undefined phrase "contract business. " Within this context and subject to these objections, and as Rockbestos understands the phrase "contract business, " to the best ofRockbestos' knowledge, the answer is no. 12. Please identify by location and product produced, each plant in which products listed in your answer to Interrogatory No. 5 have been manufactured and/or assembled and the dates said plants have been in operation. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that it manufactured the majority ofits wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos at 285 Nicoll Street, New Haven, CT, and certain ofthese products at 20 Bradley Park Road, East Granby, CT. 13. Has Defendant, at any time, entered into a "rebranding" agreement with any other company, either as a buyer or a seller, concerning any asbestos-containing products and/or materials? If so, please state: (a) (b) (c) (d) (e) (f) The name of the company manufacturing the asbestos products under such agreement; The trade name affixed to such products; The periods of time covered by each such agreement; The volume (in dollars amounts) of each such transaction; The purchaser of such products; Does Defendant currently have in its possession any ofthe writings or contracts concerning such rebranding agreement? ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of -17- admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that, to the best ofits knowledge, it is aware of "relabeling " only in one instance, for Joy Manufacturing Co. Unless and until Plaintiffs alleges exposure to Joy Manufacturing Co. products, Rockbestos objects to the balance ofthis interrogatory as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 13.1 Have you ever owned or operated a business or portion thereof which engaged in construction, erection or tear-out of furnaces, pipes, boilers, turbines, lehrs, ovens, kilns, etc? Ifso, please state: (a) the name of said business; (b) the date of commencing business and cessation of business, if applicable; (c) type of construction or tear-out performed; (d) state whether said business installed or supplied asbestos-containing products on the furnaces, pipes, boilers, turbines, lehrs, etc., i.e.. gaskets, pipe-covering, block, cement, rope, cloth, clothes, etc., containing asbestos, asbestos pipe, board, etc.; (e) state the trade name and/or manufacturer of any asbestos-containing product which you installed or supplied to any site on Exhibit A. (f) provide the dates for the applicable construction, installation or tear-out project. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, Rockbestos states that the answer is no. 13.2 Do you have within your custody, possession, or control any packages that presently or formerly packaged asbestos-containing products or were produced for the purpose ofpackaging asbestos- containing products contemporaneous with your manufacture sale or distribution of such asbestos- containing products? If so, provide the following: (a) a description of each such package; (b) the present location and custodian of each such package; (c) the date or approximate date on which each such package was produced. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of -18- admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, see Rockbestos' answer and objections to interrogatory no. 5. Rockbestos further states that to the extent documents responsive to this interrogatory exist and are in Rockbestos' possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are available for inspection at reasonable times and upon reasonable notice. 14. What is the name, address and job title ofeach individual who participated in the design and preparation of manufacturing specifications for each such product listed above in answer to Interrogatory No. 5? ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are available for inspection at reasonable times and upon reasonable notice. 15. As to each product listed in response to Interrogatory No. 5, please describe how each product was to be cut, shaped, scribed, mixed and applied on the job. In answering this question, give particular reference as to whether or not the materials were to be sawed or cut on the job, blown into confined areas, mixed with water in a cement or paste. ANSWER: See General Objections which are incorporated herein by -19- reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that it only manufactures wire and cable products, some of which formerly contained bonded, saturated and encapsulated chrysotile asbestos. To the best ofRockbestos ' knowledge, its wire and cable products containing bonded, saturated and encapsulated products were never scribed, mixed, blown into confined areas or mixed with water in a cement or paste. Rockbestos wire and cable products containing bonded, saturated and encapsulated chrysotile asbestos were cut and stripped as part ofthe installation process. 1 6. Based upon the material contents of the asbestos-containing products, the method of manufacturing, and the method of application, please state which products listed in Interrogatory No. 5 could be applied by a worker without creating dust. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos further objects to this interrogatory on the grounds that it assumes that Rockbestos ' wire and cable products created dust. Within this context and subject to these objections, see Rockbestos' answer and objections to interrogatory nos. 5. Rockbestos further states that it only manufactures wire and cable products, some of which formerly contained bonded, saturated and encapsulated chrysotile asbestos. All of the wire and cable manufactured by Rockbestos met the specifications ofthe National Electrical Code and government specifications regarding asbestos, for the wire and cable -20- products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that it at all times adhered to applicable and controlling guidelines promulgated by OSHA and that it is unaware ofany credible scientific evidence regarding the alleged adverse health hazards ofelectrical wire and cable products containing bonded, saturated, and encapsulated chrysotile asbestos. Rockbestos further asserts that its products were safe at all times when used properly andfor their intended purpose. 17. Do any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials ofany kind or character now exist relating to the design and preparation of the products listed in answer to Interrogatory No. 5? If so, please: (a) List each such written material or document; (b) Identify the person or persons presently in possession of each such document; (c) State where each such document is located. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facilit)' located at 20 Bradley Park Road, East Granby, CT and are available for inspection at reasonable times and upon reasonable notice. 18. Prior to releasing the products listed in Interrogatory No. 5 for sale and usage, were any tests (either animal or human) conducted on said products to determine potential health hazards involved in the use of, or exposure to, the materials and/or products? If so, please state: (a) The name of the products tested and the date of each test. (b) The name, address, and job classification ofeach individual who conducted such tests; (c) The results of such tests. -21- ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos further objects to this interrogatory on the grounds that it seeks information protected by the privilege of self-critical analysis. Within this context and subject to these objections, Rockbestos states that it only manufactures wire and cable products, some of which formerly contained bonded, saturated and encapsulated chrysotile asbestos. All ofthe wire and cable manufactured by Rockbestos met the specifications ofthe National Electrical Code and government specifications regarding asbestos, for the wire and cable products that contained bonded, saturated, and encapsulated chrysotile asbestos. Rockbestos further states that it at all times adhered to applicable and controlling guidelines promulgated by OSHA and that it is unaware ofany credible scientific evidence regarding the alleged adverse health hazards of electrical wire and cable products containing bonded, saturated, and encapsulated chrysotile asbestos. Rockbestos further asserts that its products at all times were safe when used properly andfor their intended purpose. Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are availablefor inspection at reasonable times and upon reasonable notice. 18.1 Pnor to releasing any products for sale and usage (whether asbestos-containing or not), were any tests (either animal or human) conducted on said products to determine potential health hazards involved in the use of, or exposure to, the materials and/or products? If so, please state: (a) The name of the product's tested and the date of each test. (b) The name, address, and job classification ofeach individual who conducted such tests; (c) The results of such tests. ANSWER: See General Objections which are incorporated herein by -22- reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos further objects to this interrogatory to the extent that it is duplicative of interrogatory no. 18.1 Rockbestos also objects to this interrogatory on the grounds that it seeks information protected by the privilege ofself-critical analysis. Within this context and subject to these objections, Rockbestos states that it only manufactures wire and cable products, some of which formerly contained bonded, saturated and encapsulated chrysotile asbestos. All ofthe wire and cable manufactured by Rockbestos met the specifications ofthe National Electrical Code and government specifications regarding asbestos, for the products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that it at all times adhered to applicable and controlling guidelines promulgated by OSHA and that it is unaware ofany credible scientific evidence regarding the alleged adverse health hazards of electrical wire and cable products containing bonded, saturated, and encapsulated chrysotile asbestos. Rockbestos further asserts that its products were safe at all times when used properly andfor their intended purpose. Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are available for inspection at reasonable times and upon reasonable notice. See also, Rockbestos' answer and objections to interrogatory no. 18.1. 19. Does Defendant have or control any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials ofany kind or character relating to the testing of the products listed in Interrogatory No. 5 hereinabove? (a) Identify each such written material or document; (b) Identify each person who presently has possession of each such document; (c) State where each such document is located. -23- ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 66 year time period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos also objects to this interrogatory on the grounds that it seeks information protected by the privilege ofself-critical analysis. Within this context and subject to these objections, Rockbestos states that all ofthe wire and cable manufactured by Rockbestos met the specifications ofthe National Electric Code and government specifications regarding asbestos, for those wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that it at all times adhered to all applicable and controlling guidelines promulgated by OSHA and asserts that its products were safe at all times when used properly andfor their intended purpose. Rockbestos notes that on January 31, 1994, Clayton Environmental Consultants, Inc., issued a report entitled "Industrial Hygiene Assessment Limited to the Evaluation ofAsbestos Fibers Released During Stripping ofRockbestos Cables", a copy of which is being produced herewith. Rockbestos further states that to the extent additional documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are availablefor inspection at reasonable times and upon reasonable notice. 20. Were any design changes or modi fications made as a result of such tests listed in answer to Interrogatory No. 18 hereinabove? If so, please state: (a) The trade name of the product changed or modified; (b) The nature of the change made and the date of such changes or modifications (c) The name, address, and job classification of each person in charge of making a change. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome and not reasonably calculated to lead to the discovery ofadmissible evidence as -24- it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that, to the best ofits knowledge, the answer is no. 21. After releasing for sale, distribution or marketing the products listed in answer to Interrogatory No. 5, did Defendant conduct any tests (either on animals or humans) to determine potential health hazards involved in the use of said materials and/or products? (a) The names of the products tested and the dates of said tests; (b) The name, address, and job classification of each person and/or agency conducting said tests; (c) The results of said tests; (d) Whether, as a result ofany tests conducted, any products were removed from the market; (e) The names of all products removed from the market as a result of said tests. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos also objects to this interrogatory on the grounds that it seeks information protected by the privilege ofself-critical analysis. Within this context and subject to these objections, Rockbestos states that all ofthe wire and cable manufactured by Rockbestos met the specifications ofthe National Electric Code and government specifications regarding asbestos, for those wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that it at all times adhered to all applicable and controlling guidelines promulgated by OSHA and asserts that its products were safe at all times when used properly andfor their intended purpose. Rockbestos notes that on January 31, 1994, Clayton Environmental Consultants, Inc., issued a report entitled "Industrial Hygiene Assessment Limited to the Evaluation ofAsbestos Fibers Released During Stripping ofRockbestos Cables", a copy of which is being produced herewith. Rockbestos further states that to the extent documents -25- responsive to this interrogatory exist and are in Rockbestos' possession, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are availablefor inspection at reasonable times and upon reasonable notice. 22. Has Defendant ever conducted or caused to be conducted any studies concerning the effects ofthe inhalation ofasbestos dust and/or fibers on workers or other persons applying, using and/or working around any of the asbestos products manufactured, sold, distributed and/or relabelled for distribution by you or your predecessor? If so, please state: (a) The dates and nature of such studies; (b) The names and addresses of persons conducting such studies; (c) The purpose of such studies; (d) Identify and list those persons to whom such reports were given and the date of such dissemination; (e) State any publication or other written dissemination o fthe results ofsuch studies; (f) State the nature ofany action to eliminate or minimize the inhalation ofasbestos dust fibers; and (g) Attach a copy of reports based upon such studies. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos also objects to this interrogatory on the grounds that it seeks information protected by the privilege of self-critical analysis. Rockbestos further objects to this interrogatory on the grounds that it is vague and ambiguous in its use ofthe undefined phrase "effects ofthe inhalation of asbestos dust and/or fibers ", Within this context and subject to these objections, Rockbestos states that, to the best of its knowledge, and as it understands the question, the answer is no. See also Rockbestos' answer and objections to interrogatory' nos. 19 and 21. 23. Before placing in the market the asbestos-containing products that Defendant, mined, manufactured, sold, marketed, installed or distributed on the market, did Defendant make or cause to be -26- made, any studies to determine whether their asbestos-containing products would be hazardous to people? If so, please state: (a) (b) (c) The date of said studies; What studies were done; and The titles of each study. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 66 year time period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos further objects to this interrogatory on the grounds that it is vague and ambiguous in its use of the undefined phrase "hazardous to people. " Rockbestos also objects to this interrogatory on the grounds that it is duplicative of interrogatory no. 18. See Rockbestos' answer and objections to interrogatory no. 18. 24. Please state whether or not Defendant ever conducted or caused to be conducted any tests in the field (where asbestos-containing products were applied, removed or utilized) to determine the nature and extent of asbestos dust and/or fiber exposure to insulators, applicators, fellow employees, or other workers removing and/or tearing out asbestos-containing products, and/or other workers in the vicinity thereof1 If so. please identify: (a) The date, place and nature of each and every test; (b) The particular asbestos-containing products to which each test applied; (c) The results ofeach test with particular reference to the number of asbestos fibers per cubic centimeter of air found at each site; and (d) The persons to whom the results said tests were given and the date of such dissemination. A NS WER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that it only manufactures wire and cable products, some of -27- which formerly contained bonded, saturated and encapsulated chrysotile asbestos. To the best ofRockbestos' knowledge, its wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos were installed by electricians, and not by "insulators " or "applicators". See also, Rockbestos' answers and objections to interrogatory nos. 18, 19, and 21. 25. Please state whether or not Defendant ever obtained any knowledge concerning the likelihood of asbestos being hazardous to human health. If so, please state: (a) When Defendant first became aware ofthe hazardous potential ofasbestos dust and asbestos fibers; (b) The manner in which the Defendant, Defendant's predecessor, or Defendant's subsidiary companies first obtained this knowledge and became aware of said hazards and from what source this information was obtained; (c) What information was disseminated within Defendant's company, or its subsidiary or predecessor regarding such adverse consequences or effects; (d) Whether any such information is still maintained by Defendant or its subsidiary or predecessor in any written form. (e) The name, address and job classification of the custodian of such information. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad and unduly burdensome as it is unlimited in scope as to time. Within this context and subject to these objections, Rockbestos states that its first knowledge ofthe possibility of health hazards posed by exposure to unbonded, unsaturated, and unencapsulated asbestos is believed to have come from OSHA required warning labels attached to raw asbestos that it purchasedfrom asbestos suppliers. Rockbestos further states that it received a communication from NEMA in 1973 that advised of the possible health hazards posed by exposure to unbonded, unsaturated, and unencapsulated asbestos. 26. Please state when Defendant first became aware of the possible association between inhalation of asbestos dust and/or fibers and the contraction of asbestosis and cancers including, but not limited to gastrointestinal cancer, laryngeal cancer, renal cancer, lymphoma, lung cancer and mesothelioma. As to each disease or condition, please state the source ofthat information, including a description of all tests conducted relative to the possibility of such a relationship. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, see Rockbestos ' answer and objections to interrogatory no. 25. 27. Please identify all physicians, industrial hygienists, and other employees (including their names and addresses) who were employed, retained or otherwise engaged by Defendant for research, investigation or study concerning asbestos or asbestos-related diseases. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory to the extent it seeks information protected by the attorney work product doctrine. Rockbestos also objects to this interrogatory as overly broad and unduly burdensome as it seeks information over a 66 year period. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are available for inspection at reasonable times and upon reasonable notice. 28. As to each person who acted in a medical advisory capacity (as it relates in any way to asbestos) to Defendant, please list their name, the date individual acted in this capacity, and that person's current address and job title. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory to the extent it seeks information protected by the attorney work product doctrine. Rockbestos also objects to this interrogatory as overly broad and unduly burdensome as it seeks information over a 66 year period. Within this context and subject to these objections, Rockbestos states that to the -29- extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are availablefor inspection at reasonable times and upon reasonable notice. 29. Please state ifany medical officer or industrial hygienist or medical consultant ever made at any time any recommendations and/or suggestions to Defendant pertaining to the risks or hazards to persons involved in the manufacture or use of asbestos products and, ifso, please state when, by whom or to whom such recommendations and/or suggestions were made and the substance of each recommendation. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome as it seeks information over a 66 year period. Rockbestos further objects to this interrogatory to the extent that it seeks information about individuals that worked at plants where wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos were manufactured. Such information is irrelevant to the subject matter ofthis litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are available for inspection at reasonable times and upon reasonable notice. 30. Please state the scientific and. or medical periodicals to which Defendant, its medical department, research department, industrial hygiene divisions, engineering department or consulting physicians subscribed between 1945 and 1975. ANSWER: See General Objections which are incorporated herein by -30- reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome as it seeks information over a 30 year period. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are available for inspection at reasonable times and upon reasonable notice. See also, Rockbestos ' response to interrogatory no. 3 7. 30.1 Please state whether Defendant, its medical officer or industrial hygienist or medical consultant or physicians were ever involved in testing or received literature or correspondence from the Mellon Institute. ANS WER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory to the extent it seeks information protected by the attorney work product doctrine. Rockbestos also objects to this interrogatory as overly broad and unduly burdensome as it is unlimited in scope as to time. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are availablefor inspection at reasonable times and upon reasonable notice. 30.2 Has Defendant, or any engineer, industrial hygienist or physician in Defendant's employ, been a member in any professional group, trade group or any of the following groups: American Ceramics Society Asbestos Textile Institute National Insulation Manufacturers Association Thermal Insulation Manufacturers Association Quebec Asbestos Mining Association Asbestos Information Association Industrial Health Foundation Industrial Hygiene Foundation Iron and Steel Institute -31- National Safety Counsel Refractories Institute Air Hygiene Foundation of America, Inc. Sprayed Mineral Fiber Association American Society of Mechanical Engineers If the answer is yes, state the following: (a) The name of the group or groups in which Defendant or individual(s) were members; (b) The name and position individual(s) within the Defendant, as defined, who were members; (c) The years Defendant or individual(s) were members of the groups; (d) Whether Defendant paid the individual(s) dues or membership fees or reimbursed the individual(s) for dues or membership fees in the group. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome as it is unlimited in scope as to time. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos ' possession, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are availablefor inspection at reasonable times and upon reasonable notice. See also, Rockbestos' answer and objections to interrogatory no. 37. 31. State in detai 1 what test, i f any, Defendant ever made with regard to the quantity, qual ity, or threshold limit values of asbestos dust, fibers or particles to which workers were exposed while using, working u ith and. or around, installing and/or applying your asbestos containing products. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 66 year time period and is not limited to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos further objects to this interrogatory on the grounds that it is vague and ambiguous in its use ofthe undefined phrase "threshold limit values. " Rockbestos also objects to this interrogatory on the grounds that it seeks information protected by the privilege ofself-critical analysis. Within this context and subject to these objections, Rockbestos states that all ofthe wire and cable manufactured by Rockbestos met the specifications ofthe National Electric Code and government specifications regarding asbestos, for those wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that it at all times adhered to all applicable and controlling guidelines promulgated by OSHA and asserts that its products were safe at all times when usedproperly andfor their intended purpose. Rockbestos notes that on January 31, 1994, Clayton Environmental Consultants, Inc., issued a report entitled "Industrial Hygiene Assessment Limited to the Evaluation ofAsbestos Fibers Released During Stripping ofRockbestos Cable", a copy of which is being produced herewith. Rockbestos further states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT and are availablefor inspection at reasonable times and upon reasonable notice. 32. For each test described in Interrogatory No. 31, please give the name of the person conducting the test, the date ofthe test, and attach true copies ofany documents, including but not limited to, reports, findings or memoranda concerning such tests or studies. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, see Rockbestos' answer and objections to interrogatory no. 31. 33. Please state the year that Defendant was first advised of either threshold limit values or maximum allowable concentrations ofboth asbestos dust and total dust by the American Conference of Governmental Industrial Flygienists and state the name ofthe employee/official ofthe company receiving such advice. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome. Rockbestos further objects to this interrogatory on the grounds that it assumes that Rockbestos was advised by the American Conference of Governmental Industrial Hygienists. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 33.1 State whether Defendant at any time conducted, caused to be conducted, or had conducted on anyjob site, or at any ofDefendant's plants or buildings, any air sampling, dust counts, dust observations, dust sampling tests or other activities to determine air quality. If your answer is in the affirmative, please indicate: (a) the date of any such air samples, tests, or activities; (b) by whom such activities were performed; (c) where such activities were performed; (d) the results of any such activities. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence as it is unlimited in scope as to time or as to a particular Rockbestos product to which Plaintiffs allege exposure. Rockbestos further objects to this interrogatory to the extent it seeks information about individuals who worked with raw asbestos fiber at plants where wire and cable containing bonded, saturated and encapsulated chrysotile asbestos were manufactured. Such information is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos' -34- possession, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 34. Does Defendant maintain a library dealing with industrial hygiene, medicine, safety and engineering and/or research? If so, state: (a) The date each such library was established; (b) The location of each library; (c) The name(s) of the librarian(s) since 1930; (d) List all journals subscribed to by you concerning asbestos, industrial hygiene, medicine, safety, and/or engineering; (e) List all books and articles dealing with asbestos and asbestos-related diseases and the date acquired. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 68 year time period. Within this context and subject to these objections, Rockbestos states that to the best of its knowledge, the answer is no. To the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 35. Did Defendant in the 1920'sor 1930's commission, orparticipate in the arrangements with Metropolitan Life Insurance Company for studies at the Trudeau Foundation at Saranac Lake, New York, concerning the effect of inhalation or ingestion of asbestos fibers upon human and/or animal bodies. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, Rockbestos states that, to the best ofits knowledge, the answer is no. 36. When was Defendant first aware of reports of studies of the Trudeau Foundation at Saranac Lake, New York, entitled "Effects ofthe Inhalation ofAsbestos Dust in the Lungs ofAsbestos Workers" by A.J. Lanza, Assistant Medical Director published in the J. Public Health Report, Vol. 50, No. 1, dated January 4, 1935 (`Lanza Report")? ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it assumes that Rockbestos ever was aware ofthe reports listed in the interrogatory. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are available for inspection at reasonable times upon reasonable notice. 36.1 Did Defendant ever contract with Saranac Laboratories to study the hazards ofany dust producing product manufactured by you (whether asbestos-containing or not)? Ifso, identify by date and author all documents concerning or any way related to such study. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, Rockbestos states that, to the best of its knowledge, the answer is no. 36.2 Did Defendant ever contract with Saranac Laboratories to analyze dust or products? If so, identify by date and author all documents concerning or any way related to such analysis. ANSff ER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory to the extent that it is duplicative ofinterrogatory no. 36.1. Within this context and subject to these objections, Rockbestos states that, to the best of its knowledge, the answer is no. See also, Rockbestos ' answer and objections to interrogatory no. 36.1. -36- 3 7. Please state whether Defendant at any time has been a member ofany "trade organization" or "trade association" composed ofother manufacturers, miners, distributors, and/or sellers ofasbestoscontaining products and, if so, please identify the name and address of each such association or organization, the dates of membership, and the names of any publications issued or written by such association or organization. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome in that it is unlimited in scope as to time. Within this context and subject to these objections, Rockbestos states that it has belonged to thefollowing trade and professional associations: 1. National Electrical Manufacturing Association; 2. Insulated Cable Engineers Association; 3. Institute ofElectrical and Electronic Engineers; 4. American Society of Testing and Materials Wire Association; 5. American Chemical Society; 6. National Fire Protection Association; 7. Asbestos Information Association (1979-1982); 8. Industrial Hygiene Foundation (1987 - present) The dates ofmembership are not available for organizations 1-6. Rockbestos further states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are available for inspection at reasonable times upon reasonable notice. 3 8. With respect to each trade organization or association listed in answer to Interrogatory No. 37, please state whether the minutes of the group's meetings and any correspondence between the members of such groups concerning the hazards of asbestos exposure are available. -37- ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome in that it is unlimited in scope as to time. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 39. Please identify by name the technical and trade association periodicals to which Defendant subscribed, and state whether Defendant had knowledge ofany articles being printed, or withheld from printing, in said periodicals pertaining to the potential hazards ofasbestos. Ifso, please state the following: (a) The title of each such article; (b) The periodical in which each such article was published; (c) The date each such article was published; (d) A detailed explanation of the reason for withholding any such article for printing; (e) Produce documentation which refers, alludes or mentions articles which were withheld for publication. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome in that it is unlimited in scope as to time. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are available for inspection at reasonable times upon reasonable notice. 40. Please state whether, prior to 1975, Defendant sponsored, or attended any meeting, seminar, conference, convention or legislative hearing where the subject of occupational health and exposure to asbestos was discussed and, if so, please state the date and place of such meeting and the name and address of any speakers or participants. -38- ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome in that it seeks information over a 55 year period. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 41. As to each product listed in response to Interrogatory No. 5, please state whether Defendant, at any time, published and/or distributed any printed materials, including but not limited to brochures, pamphlets, catalogs, packagings or other written materials ofany kind or character that contain any warnings, cautions, caveats or directions concerning the possible health effects ofthe products on a person. If so, please state as to each product: (a) The name of each relevant product; (b) The wording of each such warning; (c) A description of each such printed material; (d) The method used to distribute the warning to persons who are likely to use the products; (e) The date each such warning was issued; (f) Whether any warning accompanied any ofyour asbestos-containing products ' sales literature, handout or pamphlets; (g) Please attach a copy of the warning and date said warning was issued; (h) The name, address, and job classification of each person who presently has possession of the above-described documents; (i) The name or names and addresses ofthe company who provided, produced, or manufactured the boxes or containers on which the warning appeared and dates these boxes with the warnings appeared. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory> on the grounds that it is overly broad, unduly burdensome, and harassing as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that by responding to this and to other interrogatories, Rockbestos neither admits nor agrees that it had a duty to -39- communicate to the Plaintiffs or with Plaintiffs' employers, nor does Rockbestos admit that there were any adverse health effects front exposure to its wire and cable products. Although specifically exemptedfrom labeling requirements pursuant to OSHA's exemption for encapsulated products, after December l, 1979, labels were attached to all Rockbestos wire and cable products containing bonded, saturated and encapsulated chrysotile asbestos. These labels read "Caution. Contains asbestos fibers. Avoid creating dust. Breathing asbestos dust may cause serious bodily injury." The text ofthis label never changed. Rockbestos further states that all ofthe wire and cable it manufactured met the specifications ofthe National Electrical Code and government specifications regarding asbestos, for those wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that it at all times adhered to all applicable and controlling guidelines promulgated by OSHA and is unaware ofany credible scientific evidence regarding the alleged adverse health hazards of electrical wire and cable products containing bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that all ofits wire and cable products were safe when used properly andfor their intended purpose. Rockbestos further states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 42. Has sales material been prepared by Defendant or its agents for purposes ofmarketing or advertising the asbestos products listed in answer to Interrogatory No. 5? If so, please state: (a) The name and address of each person or entity w ho prepared same; (b) The name, address and job title ofeach person who presently has possession of same; (c) The date same was prepared; (d) The media used to disseminate the sales material. ANSWER: See General Objections which are incorporated herein by -40- reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that documents responsive to this interrogatory exist and are in Rockbestos ' possession; they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 43. Has any written material of any kind or character been prepared by Defendant, Defendant's predecessor or any ofDefendant's subsidiary companies or their agents indicating how the products listed in answer to Interrogatory No. 5 should be used or maintained by the ultimate user or those working in facilities or atjob sites where the product was used, installed or removed, including, but not limited to, those sites listed on the job site list attached as Exhibit A? If so, please state the following (a) The name, address and job classification of each person who prepared same; (b) The name, address and job classification of each person who presently has possession of same; (c) The dates and manner in which said material was distributed to purchasers ofthe products in answer to Interrogatory No. 5. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. -41- 44. Was any written material of any kind prepared by Defendant and distributed to those individuals listed in response to Interrogatory No. 9? If so, please state the following: (a) Identify the written maters- by content and date; (b) To whom was it delivered. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 45. Does Defendant contend that asbestos-containing products can be manufactured so as to eliminate all potential health hazards to persons working with or around, installing or applying same? Ifso, please state the following: (a) The date that Defendant first determined that another product could be used in place of asbestos; (b) The chemical of the substitute; (c) Whether the substitute is suitable for the purpose for which they are to be used; (d) Whether Defendant used the substitute for asbestos to 1971; (e) Whether Defendant ever used the substitute for asbestos for high or low heat insulation. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as argumentative in that it assumes the Rockbestos' wire and cable products containing bonded, saturated and encapsulated chrysotile asbestos were not safe. Rockbestos states that is only manufactures wire and cable products, some of which formerly contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos states that all ofthe wire and cable it manufactured met the specifications of the National Electrical Code and government -42- specifications regarding asbestos, for those wire and cable products that contained bonded, saturated and encapsulated clirysotile asbestos. Rockbestos further states that it at all times adhered to all applicable and controlling guidelines promulgated by OSHA and is unaware ofany credible scientific evidence regarding the alleged adverse health hazards ofelectrical wire and cable products containing bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that all ofits wire and cable products were safe when used properly andfor their intended purpose. 46. Did Defendant give any warnings to any individuals at the sites listed on Exhibit A, including any individuals who owned, operated, or managed the facilities at the sites listed on Exhibit A, regarding the potential health hazards of any product listed in response to Interrogatory No. 5. If yes, please state: (a) Name of person most knowledgeable about this communication. (b) Name of person at the sites listed on Exhibit A, attached hereto most knowledgeable about this communication. (c) Dates of each communication. (d) Contents of each communication. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Within this context and subject to these objections, see Rockbestos ' answer and objections to interrogatory no. 41. 47. Did any person prior to 1970, file a claim against any Workers' Compensation carrier covering Defendant alleging that he or she contracted a disease as a result of exposure to asbestos? If so, please state the following: (a) A list ofeach such claim by claimant's name, date filed, the caption andjurisdiction involved; (b) The disease alleged in each such claim; (c) A brief summary of the disposition of each such claim; and (d) The name, address and job classification ofthe person or persons having custody of the records pertaining to each such claim. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly -43- burdensome, and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 50 year period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Rockbestos also objects to this interrogatory to the extent that it seeks information relating to potential health risks to individuals who worked with raw asbestos fibers at plants where wire and cable containing bonded, saturated, and encapsulated chrysotile asbestos were manufactured. Such information is neither relevant to the subject matter of this litigation nor reasonably calculated to lead to the discovery of admissible evidence. Within this context and subject to these objections, to the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 47.1 Please identify all documents concerning or in any way related to any decisions made by you to cease manufacturing asbestos-containing products. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that the only asbestos-containing products that it manufactured were wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that it ceased manufacturing wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos in 1986, and the reasons for discontinuing their manufacture included changes in technology and customer specifications. To the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at -44- 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 47.2 Has any person or company from which you purchased asbestos-containing products ever issued a recall of their products or taken any action to take those products off the market after said products were in your possession? Ifso, provide: (a) the date ofsaid recall; (b) the name ofthe company which issued the recall; (c) a copy of the recall. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 66 year period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that, to the best of its knowledge, the answer is no. To the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, they are stored in Rockbestos' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 47.3 State what action, ifany, you have ever taken since 1930 to minimize or eliminate any risk ofoccupational disease or pneumoconiosis to those at any time engaged in the manufacture or production of asbestos-containing products. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 56 year period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Rockbestos also objects to this interrogatory to the extent that it seeks information relating to potential health risks to individuals who -45- worked with raw asbestos fibers at plants where wire and cable containing bonded, saturated, and encapsulated chrysotile asbestos were manufactured. Such information is neither relevant to the subject matter ofthis litigation nor reasonably calculated to lead to the discovery ofadmissible evidence. 47.4 State what action, ifany, you have ever taken since 1930 to minimize or eliminate any risk ofoccupational disease or pneumoconiosis to those at anytime engaged in the use, as distinguished from the manufacture, or exposed to the use ofasbestos-containing or industrial insulation products or who were otherwise exposed to asbestos-containing or industrial insulation products. (a) describe such action; (b) state when such action was taken; (c) state what written material exists related to such action; (d) state the names,job titles and last known address ofthe individuals who undertook such actions. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as argumentative in that it assumes the Rockbestos ' wire and cable products containing bonded, saturated and encapsulated chrysotile asbestos were not safe. Rockbestos further objects to this interrogatory as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery ofadmissible evidence as it seeks information over a 56 year period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that is only manufactures wire and cable products, some of which formerly contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos states that all of the wire and cable it manufactured met the specifications ofthe National Electrical Code and government specifications regarding asbestos, for those wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that it at all times adhered to all applicable and controlling guidelines promulgated by OSHA and is unaware ofany credible scientific evidence regarding the alleged adverse health hazards of electrical wire and cable -46- products containing bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that all ofits wire and cable products were safe when used properly andfor their intended purpose. 48. Did Defendant receive notice prior to 1968 that any person was claiming inj ury or had sustained an abnormal x-ray reading as a result ofusing asbestos products manufactured, sold, installed, and/or distributed by Defendant? If so, please state: (a) The name and address of each claimant; (b) The date of notice of each claim; (c) A description of the claim; (d) The type of injuries allegedly sustained; (e) The name and address ofeach attorney representing the individuals making such claims; (f) The style and court number of each such claim; (g) The resolution of each claim. ANS WER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence as it seeks information over a 48 year period and is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that is only manufactures wire and cable products, some of which formerly contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos states that all of the wire and cable it manufactured met the specifications of the National Electrical Code and government specifications regarding asbestos, for those wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestosfurther states that it at all times adhered to all applicable and controlling guidelines promulgated by OSHA and is unaware of any credible scientific evidence regarding the alleged adverse health hazards of electrical wire and cable products containing bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that all of its wire and cable products were safe when used properly andfor their intended purpose. To the extent documents responsive to this interrogatory exist and are in Rockbestos'possession, -47- they are stored in Rockbestos ' Document Storage Facility located at 20 Bradley Park Road, East Granby, CT, and are availablefor inspection at reasonable times upon reasonable notice. 48.1 Describe the method by which you have maintained records concerning the manufacture, sale, supply, distribution, use, advertising, delivery and/or installation or tear-out of each ofasbestos- containing products. For each description provide the following: (a) each present and former company or corporate department, division or subdivision responsible for maintaining such records; (b) the manner in which the records are kept (e.g., boxes, computer tape, microfilm, etc.); (c) the inclusive dates of any such manufacture, sale, supply, distribution, use, advertising, delivery, and/or installation or tear out which such record keeping system covers; (d) the present location at which all such records are maintained; (e) the identity ofeach person employed by you at any time from 1930 to the present who is or was responsible for the collection and maintenance of such records. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as overly broad and unduly burdensome as it seeks information over a 66 year period. Within this context and subject to these objections, Rockbestos states that its documents are maintained in its Document Storage Facility located at 20 Bradley Park Road, East Granby, CT. 48.2 State whether any records concerning the manufacture, sale, supply, distribution, advertising, delivery, use or installation or tear-out of asbestos-containing products have been destroyed or discarded and if so, indicate: (a) the date and location of such destruction or discard; (b) the custodian and location of such records prior to their destruction or discard and the identity of each employee, representative, official or agent who ordered, authorized or supervised such destruction or discard. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, Rockbestos states that it retains documents in its Document Storage Facility located at 20 Bradley Park Road, East Granby, CT. These documents have been subject to destruction periodically due to space -48- limitations. 48.3 For ail documents, other than invoices, work orders and/or purchase orders, which relate to matters relevant to all the preceding interrogatories: (a) Is there any kind of index for the documents? (b) How many pages is the index of documents? (c) How many documents are referred to in the index? (d) Is the index maintained in electronic format (i.e. database, word processing or other computerized format)? (e) What manner of electronic format is used? ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, Rockbestos states that it does not possess an index ofthe documents stored in its Document Storage Facility located at 20 Bradley Park Road, East Granby, CT. A list ofsome ofthe boxes of documents in the Document Storage Facility exists in paperformat. 48.4 For all invoices, work orders and/or purchase orders, which relate to matters relevant to all the preceding interrogatories: (a) Is there any kind of index for the documents? (b) How many pages is the index of documents? (c) How many documents are referred to in the index? (d) Is the index maintained in electronic format (i.e. database, word processing or other computerized format)? (e) What manner of electronic format is used? ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, see Rockbestos' answer and objections to interrogatory no. 48.3. 49. Has Defendant obtained statements from any witnesses including Plaintiffs? If so, please: (a) list each witness who has given a statement and the name, address, and job title of each person having custody of any such statement. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it is vague -49- and ambiguous in its use of the undefined word "statements. " Within this context and subject to these objections, Rockbestos states that, to the best ofits knowledge, with the exception ofstatements obtained through depositions in this matter, there are none. Rockbestos notes that discovery is ongoing and its investigation is continuing and specifically reserves its right to supplement its response to this interrogatory. 50. Do you contend that PlaintiffTDecedent improperly used those products listed in response to Interrogatory No. 5? If so, please set forth in detail in what respect the product was improperly used. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it seeks information protected by the attorney work-product doctrine. Rockbestos intends to comply fully with the Rules Governing the Courts ofthis State and any Case Management Orders entered in this matter. Rockbestos notes that discovery is ongoing and its investigation is continuing and specifically reserves its right to supplement its response to this interrogatory. 51. As to the sites listed on Exhibit A, and as to each Plaintiff'Decedent, please state whether Defendant contends that there was any substance other than asbestos which contributed to or caused Plaintiff/Decedent's injuries. If your answer is yes, please state the following: (a) The facts upon which you rely; (b) The identity of the sources upon which you rely which substantiate these facts. A NS WER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory on the grounds that it seeks information protected by the attorney work-product privilege. Rockbestos further objects to this interrogatory on the grounds that it calls for a medical conclusion subject to expert testimony. Rockbestos intends to complyfully with the Rules Governing the Courts of this State and any Case Management Orders entered in this matter. Rockbestos notes that discovery is ongoing and its investigation is continuing and specifically reserves its right to supplement its response to this interrogatory. -50- 52. Would any respirator, mask or other breathing devices prevent inhalation ofthe asbestos dust and fibers contained in products listed in answer to Interrogatory No. 5? If so, state: (a) When the respirator was sold; (b) A detailed description of such respirator or other breathing devices, including name of manufacturer and model number; (c) The basis of your claim that such respirators or other breathing devices will prevent the inhalation of such dust and fibers; (d) Identify any tests performed regarding the efficaciousness ofsuch respirators and other breathing devices in preventing the inhalation of asbestos dust and fibers including date, title, author and number; (e) List all documents which mention, allude or refer to tests performed on breathing devices which prevented the inhalation of asbestos dust and/or fibers. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as argumentative in that it assumes the Rockbestos' wire and cable products containing bonded, saturated and encapsulated chrysotile asbestos release asbestos dust or fibers. Rockbestos states that it only manufactures wire and cable products, some of which formerly contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos states that all ofthe wire and cable it manufactured met the specifications ofthe National Electrical Code and government specifications regarding asbestos, for those wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that it at all times adhered to all applicable and controlling guidelines promulgated by OSHA and is unaware ofany credible scientific evidence regarding the alleged adverse health hazards ofelectrical wire and cable products containing bonded, saturated and encapsulated chrysotile asbestos. Rockbestos further states that all ofits wire and cable products were safe when used properly andfor their intended purpose. 5 3. Does Defendant expect to call expert witnesses at the trial of this case? If so, please state the following: (a) (b) (c) (d) Their identity and last known address; The subject matter on which the expert is expected to testify; The expert's specific conclusion and specific opinions and the specific basis therefore; The expert's qualifications to render the opinions set forth above; (e) Whether any person identified in sub-paragraph (a) above has provided a report or other documentation to you, and if so, identify such document or report; (f) Identity all documents that you have provided to each person identified in response to sub-paragraph (a) above; and (g) Describe in detail the education and work history of, and identify any books, treaties, article, published and unpublished reports, studies or other scholarly works authored by any individual identified in response to subparagraph (a) above. Alternatively, in lieu of said response, attach a copy of a resume or curriculum vitae and a list of publications to your answer. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, Rockbestos states that it has not yet identified the expert witnesses it intends to call at the trial of this matter. Rockbestos intends to complyfully with the Rules Governing the Courts ofthis State and any Case Management Orders entered in this matter. Rockbestos expressly reserves its right to supplement its response to this interrogatory. 54. Please state the name and last known address ofeach expert witness who is not retained or employed for that purpose who is an employee of Defendant and will render an opinion within his expertise at the time of trial. ANS WER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, Rockbestos states that it has not yet identified the witnesses it intends to call at the trial of this matter. Rockbestos intends to complyfully with the Rules Governing the Courts of this State and any Case Management Orders entered in this matter. Rockbestos expressly reserves its right to supplement its response to this interrogatory. 55. Does Defendant admit that service ofprocess was properly had on it in these cases? Ifnot, please state why. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, Rockbestos states that the answer is yes. -52- 55.1 For each and every affirmative defense asserted in Defendant's Answer to Plaintiffs' Complaint, or the cross-claims or counter-claims of any party against Defendant, state: (a) the facts upon which Defendant relies for each and every affirmative defense; (b) each and every document which will be offered to prove each and every affirmative defense; and (c) each and every witness who will testify in support ofeach and every affirmative defense. (d) the substance and subject matter of the anticipated testimony of each witness identified in the preceding response. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos specifically objects to this interrogatory as unduly burdensome. Rockbestos further objects to this interrogatory on the grounds that it seeks information protected by the attorney work-product privilege. Within this context and subject to these objections, Rockbestos states that it has not yet identified the witnesses, documents, and other evidence it intends to call and use at the trial ofthis matter. Rockbestos intends to comply fully with the Rules Governing the Courts ofthis State and any Case Management Orders entered in this matter. Rockbestos expressly reserves its right to supplement its response to this interrogatory. 56. Does Defendant have policies ofinsurance that might cover the claims that have been made by Plaintiffs herein? (a) If so, please list the name of each insurance carrier who may have coverage, the amount of such coverage, and the dates of each such policy. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos further objects to this request on the grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence as it is unlimited in scope as to time. Rockbestos also objects to this request on the grounds that it seeks information which is neither relevant to the subject matter of this action nor reasonably calculated to lead to the discovery of admissible evidence. -53- 56.1 Has Defendant ever been involved in any litigation concerning potential insurance coverage for asbestos products liability matters? If so, please state: (a) the case caption, court and date of filing of each case in which you have been involved; (b) whether you were Plaintiff or Defendant; (c) a brief statement of the issues; (d) identify by date, author and recipient(s), (including recipients ofcarbon copies) all documents listed as exhibits by either party in this litigation; (e) identify by deponent and date all individuals who were deposed in these cases; (0 identi fy by date, author and recipient(s) all documents that have been placed on a protective order in such litigation; (g) identify all expert witnesses retained for use at trial in any ofthe above litigation by name, address and telephone number. ANSWER: See General Objections which are incorporated herein by reference. Rockbestos further objects to this request on the grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery ofadmissible evidence as it is unlimited in scope as to time. Rockbestos also objects to this request on the grounds that it seeks information which is neither relevant to the subject matter of this action nor reasonably calculated to lead to the discovery ofadmissible evidence. 57. Please state the name and address ofeach person who has knowledge of relevant facts regarding claims and defenses of this lawsuit. ANSWER: See General Objections which are incorporated herein by reference. Within this context and subject to these objections, Rockbestos states that the parties to this lawsuit have knowledge relevant to the claims and defenses in this lawsuit. Rockbestos notes that discovery is ongoing and expressly reserves its right to supplement its response to this interrogatory. 58. State the last date that Defendant sold, distributed, manufactured, installed, and/or otherwise placed asbestos-containing products into the stream of commerce. ANSWER: See General Objections which are incorporated herein by -54- reference. Rockbestos specifically objects to this interrogatory on the grounds that it is overly broad and unduly burdensome as it is not limited to a particular Rockbestos product to which the Plaintiffs allege exposure. Within this context and subject to these objections, Rockbestos states that that only asbestos-containing products that it manufactured were wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos. Rockbestos ceased manufacturing its wire and cable products that contained bonded, saturated and encapsulated chrysotile asbestos in 1986. 03- AFFIDAVIT STATE OF CONNECTICUT COUNTY OF NEW HAVEN SS: BRANFORD BEFORE ME, the undersigned authority in and for said State and County, personally appeared George G. Littlehales, who being duly sworn deposes and says that he is authorized to make this affidavit on behalf of Rockbestos-Surprenant Cable Corp. and that the facts contained in the foregoing responses to Plaintiffs' First Master Set of Interrogatories are true and correct to the best of his knowledge or information and belief. SWORN AND SUBSCRIBED BEFORE ME thisday of2001. Notary Public George G. Littlehales -56- STATE OF CONNECTICUT COUNTY OF NEW HAVEN AFFIDAVIT } SS: BRANFORD BEFORE ME, the undersigned authority in and for said State and County, personally appeared George G. Littlehales, who being duly sworn deposes and says that he is authorized to make this affidavit on behalf of Rockbestos-Surprenant Cable Corp. and that the facts contained in the foregoing responses to Plaintiffs' First Master Set of Interrogatories are true and correct to the best of his knowledge or information and belief. SWORN AND SUBSCRIBED BEFORE ME Notary Public My Commission Exp. Mar. 31,2004 -67- Court: Court of Common Pleas - Cuyahoga County (Asbestos) Case ID: CV-073958 Docket Number: 63047 Person Filing: Gary Hermann Firm: Hermann Cahn & Schneider Party: #LIST#00615.1 Party Designation: Defendant Category: Notice of Service of Other Discovery Date Filed: 10/25/2001 Time Filed: 3:31 P.M. Title: ROCKBESTOS' FILING OF RESPONSES TO PL RUTH DICKERSON'S INTERROGATORIES AND REQUESTS FOR PRODUCTION File Type: Document Additional Docket Numbers: [CV-398302:411];