Document K8MD8xKVkBbwgb99rExjEdJw

FILE NAME: Ford (FD) DATE: 2014 DOC#: FD239 DOCUMENT DESCRIPTION: Legal - Ford's Answers to Interrogatories in Evans vs. Union Carbide SD&li Sanchez Daniels & Hoffman llp Attorneys and Counselors Manuel "Manny" Sanchez Tlmolhy V. Hoffman'***' Hugh C. O'Donnell1 John S Hartley John J. Plegora Mark S. Villmek Gerald M. Dombrowski Susan K. Chae Paige C. Donaldson1 Mark E, Winters Hugo Chaviano" LairyC Jurgens Andrew P. Rice Bradley D. Alexander Emanuel C. Welch RyanJ. McQueens/ Joseph P. Sullivan1**" Heather D, Erickson Neal B. MoQueene/ Michael T. Franz" Leo P. Dombrowski Elaine C Davenport Michelle A. Franz" Patrick M Ward Bryan K Duptechain Edrio S. Bautista Craig A. Ziolkowski Camille Crlbaro-Mello N oraC Bloom Renee Zloikowskt Yifan Xu Sanchez Brian H. Sanchez Shawnte M. Raines Elizabeth J. Dalton Burt Baum stark O'BRIEN LAW FIRM, P.C. 815 Geyer Avenue St. Louis, MO 63104 333 West Wacker Drive, Suite 500 Chicago, Illinois 60606 Phone (312) 641-1555 Facsimile: (312) 641-3004 , E-mail: sdh@sanchezdh.com www.sanchezdh.com March 14, 2014. Via UPS RE: Ricky R. Evans vs. Union C arbide C orporation, e t al. C ourt No: 1322-CC00881 . Our File No: FD -81028_______________________ Wheaton Office 2100 Manchester Road Building A, Suite 309 Wheaton, Illinois 60187 Phone: (630) 752-9880Facsimile: (630) 752-9881 i Also admitted m Indiana *Also admitted mWisconsin i Also admitted mMassachusetts 4Also admitted mMissouri 5 Also admitted in Ohio s Also admflled sn New York t Ateoadmatsd rn Minnesota 4 Abo admitted In Pennsylvania * Abo admitted in Michigan 6Abo admitted in Arizona itA ls o adm itted In Florida John D Daniels John D Cummins Robert T. Varneys CH Counsel D ear CounseJ; Enclosed please find answ ers and responses to plaintiffs interrogatories and request for production regarding paym ents to certain doctors, scientists, authors an d /o r organizations from our client, Ford M otor Company.' Executed verifications will be forw arded to your attention shortly. Contact Renee Ziolkowski if you have any questions. Very truly yours, JANHEZ DANIELS & HOFFMAN LLP End CC: ACOR via C ase.net w /o e n d . SuzaVihe H erzog - Paralga IN THE CIRCUIT COURT OF THE CITY OF ST. LOUTS STATE OF MISSOURI Ricky R. Evans, ) Plaintiff, vs. ) ) ) Cause No. 1322-CC00881 ) . . ) Union Carbide Corporation, et al., ) Defendants. ) Asbestos Personal Injury ) . FORD M O T O R COM PANY'S ANSW ERS TO INTERROGATORIES TO DEFENDANT FORD MOTOR COMPANY REGARDING PAYMENTS TO CERTAIN DOCTORS, SCIENTISTS. AUTHORS AND/OR ORGANIZATIONS Ford M otor Company ("Ford") herein submits its Answers to Plaintiff's Interrogatories to Defendant Ford Motor Company Regarding Payments to Certain Doctors, Scientists, Authors and/or Organizations, PRELIMINARY STATEMENT AND GENERAL OBJECTIONS F o rd 's responses to P la in tiffs interrogatories have been prepared in accordance w ith the Missouri Rules o f Civil Procedure, pursuant to a reasonable and duly diligent investigation and search in the United States for the information requested. These answers are based upon facts known or believed by Ford at the time o f responding to these requests. Ford notes that, although it has made a good faith effort to respond to these requests, Ford's investigation and discovery regarding these matters is ongoing. Accordingly, Ford's answers are based on information currently available, and Ford expressly reserves the right to supplement or amend these responses should additional and/or contradictory information come to light at a later date. ANSWERS TO INDIVIDUAL INTERROGATORIES .. Subject to the foregoing statement and objections, Ford answers each individual interrogatory as follows: INTERROG ATORY NO. 1; Please state whether you, your agents or your counsel, have paid any money and/or retained the services o f The Chrysotile Institute, including, but not limited to, anyone affiliated with, associated with or employed by The Chrysotile Institute (collectively, "The Chrysotile institute") from its inception until the present date. ANSWER: Ford has not identified any expert witness at The Chrysotile Institute to be called at the trial o f this lawsuit. As such, the information sought in this interrogatory, is neither relevant to the subject matter o f this action nor reasonably calculated to lead to the discovery o f admissible evidence. Ford also objects to this interrogatory because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevantto the subject matter o f this acton nor reasonably calculated to lead to the discovery o f admissible evidence. This interrogatory is not limited to a reasonable time ftame or scope, and instead seeks information pertaining to whether Ford ever paid money and/or retained the services o f the Chrysotile Institute for any purpose whatsoever, i f at all, at anytime from th organization's inception until the present date, and without any reasonable limitation to those payments made in connection with the defeuseof asbestos friction litigation claims or to those particular experts identified in this matter. Ford further objects to this interrogatory to the extent it seeks information that is protected from disclosure by the attorney client privilege, workproduct doctrine, consulting expert privilege, or any other applicable privilege. Ford also objects to this interrogatory to the extent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure o f information which is properly the subject o f expert witness testimony and/or reports. INTERROGATORY NO . 2: 2 If your response to the Interrogatory No. 1 is yes, please: (a) Identify each and every transaction (Le,, all instances where m oney was paid to The Chrysotile Institute, and/or where The Chrysotile Institute was retained) between you, your agents or your counsel with The. Chrysotile Institute? (b) State to whom (individual or company) a fee, money, retainer and/or the like was paid? (c) State the amount o f each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? (e) State whether any documentation was generated from the transaction(s), including, but not restricted to invoices, reports, notes and the like? (I) . If your response to Subparagraph (e) is yes, identify: (i) the documents generated; (ii) where such documents went; and (iii) who currently has the documents in their possession, custody or control l ANSWER: Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory No. 1. INTERROGATORY NO. 3: Please state whether you, your agents or your counsel, have paid money and/or retained the services o f Exponent, Inc., including, but not limited to, anyone affiliated with, associated with or em ployed b y Exponent, Inc. (collectively, "Exponent, Inc.") from its inception until the present date. ANSWER: . After a reasonable inquiry and diligent search in those areas o f the company where information responsive to this interrogatory would likely be' located, Ford states that it has paid Exponent, Inc. the following approximate amounts in connection with the defense of asbestos 3 friction litigation claims from January 1,2001 through the present: Exponent, Inc. 2001 2002 2003 2004 $853,650.69 $1,988,754.17 l $1,602,457.30 l $1,844,472.33 i 2005 2006 $837,500.29 $796,284.58 2007 2008 2009 2010 2011 $510,674.76 $652,409.09 $713,911.49 $2,012,109.86 $1,722,498.24 2012 2013 2014 $1,666,604.78 $1,503,624.92 $287,381.50 Ford otherwise objects to this interrogatory because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevant to the subjectmatter ofthis action nor reasonably calculated to lead to the discovery o f admissible evidence, This interrogatory is not limited to a reasonable time frame ot scope, and instead seeks information pertaining to whether Ford ever paid money and/or retained the services o f the Exponent, Inc. for any purpose whatsoever, at any time from the organization's inception nntU the present date, and without any reasonable limitation to those payments made in connection with the defense o f asbestos frietion litigation claims or to those particular experts identified in this matter. Ford further objects to this 4 interrogatory to the extent it seeks information that is protected from disclosure by the attorney client privilege, work product doctrine, consulting expert privilege, or any other applicable privilege. Ford also objects to this interrogatory to the extent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure o f information which is properly the subject o f expert witness testimony and/or reports. INTERROG ATORY NO , 4: I f your response to the Interrogatory No. 3 is yes, please: (a) Identify each and every transaction (ie., all instances where money was paid to Exponent, and/or where Exponent Inc. was retained) between you, your agents or your counsel with Exponent, Inc.? . (b) State to whom (individual or company) a fee, money, retainer and/or the like was . paid? (c) State the amount of each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? (e) State whether any documentation was generated from the transaction(s), including, but not restricted to invoices, reports, notes and the like? (f) I f your response to Subparagraph (e) is yes, identify: (i) the documents generated; (ii) where such documents went; and (iii) who currently has the documents in their possession, custody or control? ANSWER; , Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory No. 3. INTERROGATORY NO. 5; Please state whether you, your agents or your counsel,, have paid money and/or retained the 5 services o f Chemrisk, including, but not limited to, anyone affiliated with, associated with or employed by Chemrisk (collectively, "Chemrisk") from its inception until the present date? ANSWER: After a reasonable inquiry and diligent search in those areas o f the company where information responsive to this interrogatory would likely be located, Ford states that it has paid Chemrisk, Inc. the following approximate amounts in connection with the defense o f asbestos friction litigation claims from January 1,2001 through the present: Chemrisk, Inc. 2001 $0 2002 $0 2003 $171,214.15 2004 $735,030.32 2005 $797,787.75 2006 $984,427.77 2007 $703,423.38 2008 $834,334.55 2009 $695,591.23 2010 $2,528,949.20 2011 $1,143,989.72 2012 .$1,171,810.50 2013 $1,180,433.85 2014 $94,875.00 Ford otherwise objects to this interrogatory because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevant to the subject matter of this action nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is not 6 limited to a reasonable time frame or scope, and instead seeks information pertaining to whether Ford ever paid money and/or retained the services of the Chemrisk, Inc. for any purpose whatsoever, at any tim e from the organization's inception until the present date, and without any reasonable limitation to those payments made in connection with the defense of asbestos friction litigation claims or to those particular experts identified in this matter. Ford further objects to this interrogatory to the extent it seeks information that is protected from disclosure by the attorney client privilege, work product doctrine, consulting expert privilege, or any other applicable privilege. Ford also objects to this interrogatory to the extent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure of information which is properly the subject o f expert witness testimony and/or reports. INTERROGATORY NO . 6: I f your response to the Interrogatory No. 5 is yes, please: (a) Identify each and ev ery transaction (i.e., all instances where money was paid to Chemrisk, and/or where Chemrisk. was retained) between you, your agents or your counsel with Chemrisk? (b) State to whom (individual or company) a fee, money, retainer and/or the like was paid? . (c) State the amount o f each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? (e) State whether any documentation was generated from the transaction(s), including, but not restricted to invoices, reports, notes and the like? (f) If your response to Subparagraph (e) is yes, identity: (i) . (ii) (iii) the documents generated; where such documents went; and who currently has the documents in their possession, custody or control? 7 ANSWER: Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory No. 5. INTERROGATORY NO. 7: Please state whether you, your agents or your counsel, have paid money and/or retained the services o f Tetra Tech Sciences, including, but not limited to, anyone affiliated with, associated with or employed by Tetra Tech Sciences (collectively, "Tetra Tech Sciences") from its inception until the present date? . ANSWER: ' After a reasonable inquiry and diligent search in those areas o f the company where information responsive to this interrogatory would likely be located, Ford states that it has paid Tetra Tech Sciences (f/k/a Sciences International) the following approximate amounts in connection with the defense of asbestos friction litigation claims from January 1,2001 through the present: Tetra Tech Sciences (formerly Sciences International) 2001 $0 2002 $0 2003 $0 2004 $53,725.89 2005 $225,767.27 2006 $200,119.67 2007 $51,689.39 2008 $49,516.33 2009 $133,425.42 2010 $299,139.97 8 2011 $405,174.26 2012 - $291,805.51 2013 $369,907.38 2014 ' $31,254.12 I ! Ford otherwise objects to this interrogatory because it is vague, ambiguous, overly broad, | unduly burdensome, and seeks information that is neither relevant to the subject matter of this action ' nor reasonably calculated to lead to the discovery o f admissible evidence. This interrogatory is not limited to a reasonable time frame or scope, and instead seeks information pertaining to whether Ford ever paid money and/or retained the services o f the Tetra Tech Sciences, for any purpose whatsoever, at any time from the organization's inception until the present date, and without any reasonable limitation to those payments made in connection with the defense of asbestos friction litigation claims or to those particular experts identified in this matter. Ford further objects to this interrogatory to the extent it seeks information that is protected from disclosure by the attorney client privilege, work product doctrine, consulting expert privilege, or any other applicable privilege. Ford also objects to this interrogatory to the e9xtent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure o f information which is properly the subject o f expert witness testimony and/or reports. (b) State to whom (individual or company) a fe.e, money, retainer and/or the like was paid? . (c) State the amount o f each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? (e) State whether any documentation was generated from the transaction(s), including, but not restricted to invoices, reports, notes and the like? (f) If your response to Subparagraph (e) is yes, identify: (i) . (ii) (iii) the documents generated; where such documents went; and who currently has the documents in their possession, custody or control? ANSWER: Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory No. 7. ' INTERROGATORY NO . 9: Please state whether you, your agents or your counsel, have paid money and/or retained the services of The Quebec Asbestos M ining Association, including, but not limited to, anyone affiliated with, associated with or employed by The Quebec Asbestos Mining Association (collectively, "QAMA") from its inception until the present date. ANSWER: Ford has not identified any expert witness at The Quebec Asbestos Mining Association to be called at the trial o f this lawsuit. As such, the information sought in this interrogatory, is neither relevant to the subject matter o f this action nor reasonably, calculated to lead to the discovery of admissible evidence. Ford also objects to this interrogatory because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevant to the subj ect matter o f this 10 action nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is not limited to a reasonable time frame or scope, and instead seeks information pertaining to whether Ford ever paid money and/or retained the services of The Quebec Asbestos Mining Association, for any purpose whatsoever, i f at all, at any time from the organization's inception until the present date, and without any reasonable limitation to those payments made in connection with the defense of asbestos friction litigation claims or to those particular experts identified in this matter, Ford further objects to this interrogatory to the extent it seeks information that is protected from disclosure by the attorney-client privilege, work product doctrine, consulting expert privilege, or any other applicable privilege. Ford also objects to this interrogatory to the extent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure of information which is properly the subject o f expert witness testimony and/or reports. INTERROGATORY NO. 10: If your response to the Interrogatory No. 9 is yes, please: (a) Identity each and every transaction (/, e., all instances where money was paid to The Quebec Asbestos Mining Association and/or The Quebec Asbestos Mining Association was retained) between you, your agents or your counsel with The The [sic] Quebec Asbestos Mining Association? (b) State to whom (individual or company) a fee, money, retainer and/or the like was paid? ' (c) State the amount o f each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? (e) State whether any documentation was generated from the transaction(s), including, but not restricted to invoices, reports, notes and the like? (f) If your response to Subparagraph (e) is yes, identify: (i) the documents generated; 11 (ii) where such documents went; and (iii) who currently has the documents in their possession, custody or control? ANSWER: . Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory N o. 9. ' INTERROGATORY NO. 11; Please state whether you, your agents or your counsel, have paid money and/or retained the services of Veritox, Inc., including, but not limited to, anyone affiliated with, associated with or em ployed by Veritox, Inc. (collectively, "Veritox, Inc.") from its inception until the present date. ANSWER: Ford has not identified any expert witness at Veritox, Inc. to be called at the trial of this lawsuit. As such, the information sought in this interrogatory, is neither relevant to the subject matter o fthis action nor reasonably calculated to lead to the discovery o f admissible evidence. Ford also objects to this interrogatory because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevant to the subject matter o f this action nor reasonably calculated to lead to the discovery o f admissible evidence. This interrogatory is not limited to a reasonable time frame or scope, and instead seeks information pertaining to whether Ford ever paid money and/or retained the services of the Veritox, Inc., for any purpose whatsoever, if at all, at any tim e from the organization's inception until the present date, and without any reasonable limitation to those payments made in connection with the defense of asbestos friction litigation claims or to those particular experts identified in this matter. Ford further objects to this interrogatory to the extent it seeks information that is protected from disclosure by the attorney-client privilege, work product doctrine, consulting expert privilege, or any other applicable privilege, Ford also objects to 12 this interrogatory to the extent it calls for expert opinions, materials and conclusions and therefore prem aturely seeks the disclosure o f information which is properly the subject o f expert witness testimony and/or reports. . INTERROGATORY NO. 12; I f your response to the Interrogatory No. 11 is yes, please: (a) Identify each and every transaction {le., all instances where money was paid to Veritox, Inc. and/or Veritox, Inc. was retained) between you, your agents or your counsel with Veritox, Inc.? (b) State to whom (individual or company) a fee, money, retainer and/or the like was paid? (c) State the amount of each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? (e) State whether any documentation was generated horn the transaction^), including, but not restricted to invoices, reports, notes and the like? (f) If your response to Subparagraph (e) is yes, identify: (i) the documents generated; (ii) where such documents went; and (iii) who currently has the documents in their possession, custody or control? ANSWER: Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory N o. 11. INTERROGATORY NO. 13: Please state whether you, your agents or your counsel, have paid money and/or retained the services o f Environ, Inc., including, but not limited to, anyone affiliated with, associated with or employed by Environ, Inc. (collectively, "Environ, Inc.") from its inception until the present date. 13 ANSWER: Ford has not identified any expert witness at Environ, Inc. to be called at the trial o f this lawsuit. As such, the information sought in this interrogatory, is neither relevant to the subject matter of this action nor reasonably calculated to lead to the discovery of admissible evidence, Ford also objects to this interrogatory because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevant to the subject matter o f this action nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is not limited to a reasonable time frame or scope, and instead seeks information pertaining to whether Ford ever paid money and/or retained the services o f Environ, Inc., for any purpose whatsoever, if at all, at any time from the organization's inception until the present date, and without any reasonable limitation to those payments made in connection with the defense of asbestos friction litigation claims or to those particular experts identified in this matter. Ford further objects to this interrogatory to the extent it seeks information that is protected from disclosure by the attorney-client privilege, work product doctrine, consulting expert privilege, or any other applicable privilege. Ford also objects to this interrogatory to the extent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure o f information which is properly the subject o f expert witness testimony and/or reports. INTERROGATORY NO. 14: I f your response to the Interrogatory No. 13 is yes, please: (a) , Identify each and every transaction {le., all instances where money was paid to Environ, Inc., and/or Environ, Inc. was retained) between you, your agents or your counsel with Environ, Inc.? (b) State to whom (individual or company) a fee; money, retainer and/or the like was paid? 14 (c) State the amount of each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? (e) State whether any documentation was generated from the transaction(s), including, but not restricted to invoices, reports, notes and the like? ' (1) I f your response to Subparagraph (e) is yes, identify: (i) the documents generated; (ii) where such documents went; and (iii) who currently has the documents in their possession, custody or control? ANSWER: Ford refers Plaintiffto, and incorporates herein, its answer and objections to Interrogatory No. 13. INTERROGATORY NO. 15: Please state whether you, your agents or your counsel, have paid money and/or retained the services of Material Analytical Services, Inc., including, but not limited to, anyone affiliated with, associated with or employed by Material Analytical Services, Inc. (collectively, "MAS, Inc.") from its inception until the present date. ANSWER: ^ Ford has not identified any expert witness at M aterial Analytical Services, Inc. to be called at the trial o f this lawsuit. As such, the information sought in this interrogatory, is neither relevant to the subject matter of this action nor reasonably calculated to lead to the discovery of admissible evidence. Ford also objects to this interrogatory because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevant to the subject matter o fthis action nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is not 15 limited to a reasonable time frame or scope, and instead seeks information pertaining to whether Ford ever paid money and/or retained the services of Material Analytical Services, Inc., for any purpose whatsoever, if at all, at any tim e from the organization'5s inception until the present date, and without any reasonable limitation to those payments made in connection with the defense of asbestos friction litigation claims or to those particular experts identified in this matter. Ford further objects to this interrogatory to the extent it seeks information that is protected from disclosure by the attorney-client privilege, work product doctrine, consulting expert privilege, or any other applicable privilege. Ford also objects to this interrogatory to the extent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure of information which is properly the subject o f expert witness testimony and/or reports. INTERROGATORY NO. 16: I f your response to the Interrogatory No. 15 is yes, please: (a) Identify each and every transaction (i.e., all instances where money was paid to Material Analytical Services, Inc. and/or Material Analytical Services, Inc. was retained) between you, your agents or your counsel with Material Analytical Services, Inc.? (b) State to whom (individual or company) a fee, money, retainer and/or the like was paid? (c) State the amount o f each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? (e) State whether any documentation was generated from the transaction(s), including, but not restricted to invoices, reports, notes and the like? (f) If your response to Subparagraph (e) is yes, identify: (i) the documents generated; (ii) where such docufnents went; and (iii) who currently has the documents in their possession, custody or control? 16 . ANSWER: Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory No. 15. INTERROGATORY NO. 17: Please state whether you, your agents or your counsel, have paid money and/or retained the services o f R J Lee Group, Inc., including, but not limited to, anyone affiliated with, associated with or employed by R J Lee Group, Inc. (collectively, "R J Lee Group") from its inception until the present date. ' ANSWER: Ford has not identified any expert witness at R J Lee Group, Inc., to be called at the trial of this lawsuit. As such, the information sought in this interrogatory, is neither relevant to the subject matter o f this action nor reasonably calculated to lead to the discovery o f admissible evidence. Ford also objects to this interrogatory because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevant to the subject matter o f this action nor reasonably calculated to lead to the discovery o f admissible evidence. This interrogatory is not limited to a reasonable time frame or scope, and instead seeks information pertaining to whether Ford ever paid money and/or retained the services o f R J Lee Group, Inc., for any purpose whatsoever, if at all, at any time from the organization's inception until the present date, and without any reasonable limitation to those payments made in connection with the defense o f asbestos friction litigation claims or Uv those, particular experts identified in this matter. Ford further objects to this interrogatory to the extent it seeks information that is protected from disclosure by the attorney client privilege, work product doctrine, consulting expert privilege, or any other applicable privilege. 17 Ford also objects to this interrogatory to the extent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure o f information which is properly the subject o f expert witness testimony and/or reports. INTERROGATORY NO, 18: I f your response to the Interrogatory No. 17 is yes, please: (a) Identify each and every transaction (i.e., all instances where money was paid to R J Lee Group, Inc. and/or R J Lee Group, Inc. was retained) between you, your agents or your counsel with R J Lee Group, Inc.? (b) State to whom (individual or company) a fee, money, retainer and/or the like was paid? (c) State the amount o f each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? (e) State whether any documentation was generated from the transaction(s), including, ' but not restricted to invoices, reports, notes and the like? (f) If your response to Subparagraph (e) is yes, identify: (i) the documents generated; (ii) where such documents went; and (iii) who currently has the documents in their possession, custody or control? ANSWER: Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory No. 17. . INTERROGATORY NO. 19: Please state whether you, your agents or your counsel, have paid money and/or retained the services o f the following individuals: (a) M arek Banasik 18 (b) Charles Blake, CIH (c) Gregor P, Brorby (d) Kelly Butnor (e) Valerie A, Craven (f) Brent Finley, Ph,D., DABT (g) Herman Gibb, Ph.D. (h) Michael Goodman, M.D., M.P.H. (i) Raymond D. Harbison (j) Patrick Hessel, Ph.D. (k) D.E. Hickish (l) Patric A. Kelsh (m) K.L. Knight (n) Elizabeth T. Lu (o) Fionna S. Mowat (p) Dennis Paustenbach, Ph.D., CIH, DAIBT (q) Sheldon Rabinovitz, Ph.D., CIH (r) Dr. M ark Roberts (s) K. Rodelsperger (t) Victor Roggli,M .D. . (u) Patrick Sheehan, Ph.D. (v) Thomas Sporn, M.D. (w) M ary Jane Teta, PhD., MPA (x) Drew VanOrden 19 (y) H.J. Woitowitz ANSWER: W ith respect to BrentFinley, Ph.D., DABT, Ford refers Plaintiffto the total amount paid to Exponent in connection with.the defense of asbestos friction litigation claims from January 1,2001 through 2004, when Brent Finley was employed by Exponent. Ford also refers Plaintiff to the total amount paid to Chemrisk in connection with the defense o f asbestos friction litigation claims from 2005 through the present when Brent Finley was employed by Chemrisk. Accordingly, Ford refers Plaintiff to its responses and objections to Interrogatory Nos. 3 and 5. W ith respect to Herman Gibb, Ph.D., Ford refers Plaintiffs to the total amount paid to Tetra Tech Sciences in connection with the defense of asbestos friction litigation claims, with whom Herman Gibb was employed. Accordingly, Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory No. 7. . W ith respect to the remaining individuals, Ford has not identified any o f these individuals as expert witness to be called at the trial of this lawsuit. As such, the information sought in this interrogatory, is neither relevant to the subject matter of this action nor reasonably calculated to lead to the discovery of admissible evidence. Ford also objects to this interrogatory because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevant to the subject matter o f this action nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is not limited to a reasonable time frame or scope, and instead seeks information pertaining to whether Ford ever paid money and/or retained the services of 25 individuals listed above, for any purpose whatsoever, if at all, at any tim e during Ford's entire corporate history, and without any reasonable limitation to those payments made in connection with the defense o f asbestos friction litigation . 20 claims or to those particular experts identified in this nlatter. Ford further objects to this interrogatory to the extent it seeks information that is protected from disclosure by the attorney client privilege, work product doctrine, consulting expert privilege, or any other applicable privilege. Ford also objects to this interrogatory to the extent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure of information which is properly the subject o f expert witness testimony and/or reports. INTERROGATORY NO. 20: I f your response to any individual listed in Interrogatory No. 19 is yes, please: (a) Identify the transaction(s) between you, your agents or your counsel with the respective individuals set forth in Interrogatory No. 19, subparagraphs (a) to (y)? (b) State to whom a fee, money, retainer and/or the like was paid? (c) State the amount o f each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? ' (e) State whether any documentation was generated from the transaction(s), including, but not restricted to invoices, reports, notes and the like? (f) If your response to Subparagraph (e), immediately above, is yes, identify: (i) the documents generated; (ii) where such documents went; and (iii) who currently has the documents in their possession, custody or control? ANSWER: ' Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory No. 19. _ INTERROGATORY NO. 21: . If your answer to any individual listed in subparagraphs (a) to (y) o f Interrogatory No. 19 is no, please indicate whether or not you paid any money, fees or the like to any of the respective 21 individual's employers and/or consulting companies. ANSWER: Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory No. 19. INTERRO GATORY NO. 22: I f your response to Interrogatory No. 21 is yes, please: (a) Identify the transaction(s) between you, your agents or your counsel with the respective individual's employers and/or consulting companies set forth in Interrogatory No. 19, subparagraphs (a) to (y)? (b) State to whom a fee, money, retainer and/or the like was paid? (c) State the amount of each and every fee, money, retainer and/or the like? (d) State for what purpose said fee, money, retainer and/or the like was paid to these individuals and/or the companies? (e) State whether any documentation was generated from the transaction(s), including, but not restricted to invoices, reports, notes and the like? (f) I f your response to Subparagraph (e), immediately above, is yes, identify: (i) the documents generated; (ii) where such documents went; and (iii) who currently has the documents in their possession, custody or control? ANSWER: Ford refers Plaintiff to, and incorporates herein, its answer and objections to Interrogatory Nos. 19 and 21. 22 STATE OF MICHIGAN ) ) ss. ' COUNTY OF WAYNE ) , ______ M ATTHEW FYTE_________, being duly sworn, deposes and says that the deponent is an authorized agent of Ford M otor Company, and that the deponent verifies the foregoing FORD M OTO R COM PANY'S RESPONSES TO PLAINTIFF'S REQUEST FOR PRODUCTION TO DEFENDANT FORD MOTOR COMPANY REGARDING PAYMENTS TO CERTAIN DOCTORS. SCIENTISTS. AUTHORS AND/OR ORGANIZATIONS for and on behalf o f Ford M otor Company and is duly authorized so to do; that the matters stated therein are not within the personal knowledge of the deponent; that the facts stated therein have been assembled by authorized employees and counsel of Ford Motor Company, and the deponent is informed that the facts stated therein are true, correct and complete to best of my knowledge and belief. Subscribed and sworn to before me this _____ day o f _______________________ 2014 Nicole M. Mundinger, Notary Public State o f Michigan, County o f W ashtenaw M y Commission Expires: July 15, 2019 Acting in County o f Wayne . 23 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATE OF MISSOURI Ricky R. Evans, Plaintiff, vs. ) ) ) ) Cause No. 1322-CC00881 . ) . . . ) Union Carbide Corporation, et al., ) ' ) Defendants. ) Asbestos Personal Injury FORD M OTOR COM PANY'S RESPONSES TO PLAINTIFF'S REQUEST FOR PRODUCTION TO DEFENDANT FORD MOTOR COMPANY REGARDING PAYMENTS TO CERTAIN DOCTORS, SCIENTISTS. AUTHORS AND/OR ORGANIZATIONS Defendant Ford M otor Company ("Ford") herein submits its Response to P lain tiffs Request for Production to Defendant Ford Motor Company Regarding Payments to Certain Doctors, Scientists, Authors and/or Organizations. PRELIMINARY STATEMENT F ord's responses to P la in tiffs requests for production have been prepared in accordance with the Missouri Rules o f Civil Procedure, pursuant to a reasonable and duly diligent investigation and search in the United States for the information requested. These responses are based upon facts known or believed by Ford at the time o f responding to these requests. Ford notes that, although it has m ade a good faith effort to 're sp o n d to these requests, Ford's investigation and discovery regarding these matters is ongoing. Accordingly, Ford's responses are based on information currently available, and Ford expressly reserves the right to supplement or amend these responses should additional and/or contradictory information come to light at a later date. RESPONSES TO INDIVIDUAL REQUESTS FOR PRODUCTION Subject to the foregoing statements and objections, Ford responds to each individual request for production of documents as.follows: REQUEST NO. 1: Please produce any and all documents as identified in response to subparagraphs (f) of the following Interrogatories served herewith: Interrogatory Nos. 2, 4, 6, 8, 10, 12, 14, 16, 18, 20, and 22. RESPONSE: To the extent Ford refers to a document in its answers to Plaintiffs Interrogatories, Ford will make that document available to Plaintiff. Ford also refers Plaintiff to, and incorporates herein, its answers and objections to Plaintiffs Interrogatories, served concurrently herewith. REQUEST NO. 2: Only to the extent that all billing and payment records to experts and expert consulting companies/firms are not being produced in response to Request for Production No. 1 hereof, please produce any and all billing and payment records for any expert and/or expert consulting company/firm paid by you, your agent and/or your counsel to study, research, and/or author reports or articles concerning asbestos, asbestos-related diseases, lung cancer and/or mesothelioma, including, but not limited tax reporting documents, such as Form 1099's, invoices, bills and/or checks. RESPONSE: Ford refers Plaintiff to, and incorporates herein, its response and objections to Request N o. 1. Ford otherwise objects to this request because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevant to the subject matter o f this 2 action nor reasonably calculated to lead to the discovery o f admissible evidence. This request is not limited to a reasonable time frame or scope, and instead seeks any and all billing and payment records for any expert and/or expert consulting company/firm paid by Ford or Ford's counsel to study, research, and/or author reports or articles concerning asbestos, asbestos-related diseases, lung cancer and/or mesothelioma, including, but not limited to tax reporting documents, such as Form 1099's, invoices, bills and/or checks, if any at all, at any time during Ford's entire corporate history, and without any reasonable limitation. Ford further objects to this request to the extent it seeks information that is protected from disclosure by the attorney-client privilege, work product doctrine, consulting expert privilege, or any Other applicable privilege. Ford also objects to this request to the extent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure o f information which is properly the subject o f expert witness testimony and/or reports. REQUEST NO. 3: Only to the extent that all communications between you, your agents and your counsel with experts and expert consulting companies/firms are not being produced in response to Request for Production No. 1 hereof, please produce any and all communications, electronic and otherwise, and any other documents related to such communications, for any expert and/or expert consulting company/firm paid by you, your agent and/or your counsel to study, research, and/or author reports or articles concerning asbestos, asbestos-related diseases, lung cancer and/or mesothelioma. RESPONSE: Ford refers Plaintiff to, and incorporates herein, its response and objections to Request N o. 1. 3 Ford otherwise objects to this request because it is vague, ambiguous, overly broad, unduly burdensome, and seeks information that is neither relevant to the subject matter o f this action nor reasonably calculated to lead to the discovery o f admissible evidence. This request is not limited to a reasonable time frame or scope, and instead seeks any and all communications, electronic and otherwise, and any other documents related to such communications, for any expert and/or expert consulting company/firm paid by Ford or Ford's counsel to study, research, and/or author reports or articles concerning asbestos, asbestos-related diseases, lung cancer and/or mesothelioma, if any at all, at any time during Ford's entire corporate history, and without any reasonable limitation. Ford further objects to this request to the extent it seeks information that is protected from disclosure by the attorney-client privilege, work product doctrine, consulting expert privilege, or any other applicable privilege. Ford also objects to this request to the extent it calls for expert opinions, materials and conclusions and therefore prematurely seeks the disclosure o f information which is properly the subject o f expert witness testimony and/or reports. . 4 STATE OF MICHIGAN ) ' ) ss. COUNTY OF WAYNE ) ----------M ATTHEW FY IE_________ , being duly sworn, deposes and says that the deponent is an authorized agent o f Ford M otor Company, and that the deponent verifies the foregoing FORD M OTOR COM PANY'S RESPONSES TO PLA IN TIFF'S REQUEST FOR PRODUCTION TO DEFENDANT FORD MOTOR COMPANY REGARDING PAYMENTS TO CERTAIN DOCTORS, SCIENTISTS. AUTHORS AND/OR ORGANIZATIONS for and on behalf o f Ford M otor Company and is duly authorized so to do; that the matters stated therein are not within the personal knowledge o f the deponent; that the facts stated therein have been assembled by authorized employees and counsel o f Ford M otor Company, and the deponent is informed that the facts stated therein are true, correct and complete to best o f my knowledge and belief. Subscribed and sworn to before me this _____ day o f _______________________ 2014 Nicole M. Mundinger, Notary Public State of Michigan, County o f Washtenaw M y Commission Expires: July 15,2019 Acting in County o f Wayne 5