Document KJ286BegDXkzymEB8ZpnMEaDo

FILE NAME: Hampshire (HAMP) DATE: 1988 Nov 11 DOC#: HAMP110 DOCUMENT DESCRIPTION: Legal - Answers of Defendant Hampshire to Interrogatories of Plaintiffs c i i r:' II'''it 7 4* IN RE: PLAINTIFF'S yd EXHIBIT in the * h A m m o i PERSONAL INJURY ASBESTOS CASES CIRCUIT COURT FOR m ****** ****** " 8 1990 it BALTIMORE COUNTY TRADE CASES J iir*Hr************************** ANSWERS OF DEFENDANT HAMPSHIRE INDUSTRIES, INC. TO INTERROGATORIES OF PLAINTIFFS Now comes Hampshire ji || MOORE, LIBOWITZ & THOMAS, !jil 1 Plaintiffs as follows: Industries, Inc. and answers the by its attorneys, Interrogatories of GENERAL OBJECTIONS ( A. Information supplied in these Answers is not based ij solely on the knowledge of the executing patty but includes the :i knowledge of the party's agents, representatives, and attorneys unless privileged. i B. The word usage and sentence structure may be that of the attorney assisting in the preparation of these Answers and : does not necessarily purport to be the precise language of the j executing party. C. Defendant objects to the definitions of the terms Defendant", "you" or "your" on the grounds that such definitions seek information from persons over which Defendant has no control or to whom it has no access and Defendant further objects on the ground that this definition requires a particular Defendant to make a determination as to whether persons or firms purported to act on its behalf. D. Defendant objects to the terms "which you have knowledge of" or "your knowledge" for the reasons set out previously in general objection C above. l a w o f f ic e s MOORE, LIBOW ITZ ft THOMAS '"O F JAL ASSOCIATION . TH F L O O R OO N . C H A R L E S S T R E E T BA LTIM O R E, MARYLAND 2J0-4303 E. Defendant objects generally to Plaintiff's use throughout these Interrogatories of the terms "predecessors" or "predecessors-in-interest" inasmuch as these terms are subject to a variety of meanings, and the Plaintiff has not assigned the definition which it intends to these terms. F. Defendant objects to providing information sought by 29989871003 29089871003 I * e <9 a- JjjjW/'pdwJL 4t> OvdlAM^t%U~r f lt^snuu vouJL II. ANSWERS uhfa INTERROGATORY NQ, Jj. State the name, address, and official capacity of each person who has supplied information used in answering these Interrogatories and indicate for which Interrogatory each such person is responsible. ANSWER TO INTERROGATORY NO, 1 Charles E. Fry, Jr. , Secretary/Treasurer of Hampshire Industries, Inc., 320 W. 24th Street, Baltimore, Maryland 21211, and from the knowledge of current employees. INTERROGATORY NO. 2 : Identify each document that was examined, reviewed and/or used in answering each Interrogatory, specify the Interrogatory and identify the present custodian of each document. ANSWER TO INTERROGATORY NO. 2 : Defendant objects to this Interrogatory on the ground that it is vague, overly broad, and unduly burdensome, j INTERROGATORY NO. 3: State whether you are a corporation. If so, state: your ;i corporate name; state of incorporation; .date of incorporation; j address of principal place of business; address(es) of any ! other place of business; whether, if you are a "foreign i corporation" as defined in Maryland General Corporation Law Sec. 1-101(1), you are now or have ever been registered or qualified to do business in the State of Maryland; and the corporate name, state of incorporation, and date of incorporation of any subsidiary, predecessor or affiliate corporation. ANSWER TO INTERROGATORY. NQ^ 3 : Yes. Defendant was incorporated on March 15, 1921, under the laws of the State of Maryland as John H. Hampshire, Inc. LA W O F F IC E S M OORE. LIBO W ITZ TH OM A S IA L A SSO C IA T IO N FTH FLO O R SO N . C H A R L E S S T R E E T 'A L T I M O R E . M A R Y L A N D r ' 21201-4303 On June 1, 1981, pursuant to approval by the Board of Directors and Shareholders of John H. Hampshire, Inc., the name of the corporation was changed to Hampshire Industries, INTERROGATORY NO. 4 : Inc. Identify all prior names by which you have existed. 3 29989871005 a- j i t were caused by an intervening acts or superseding negligence. If so, states all facts and identify all documents which form the basis of such a contention. ANSWER TO INTERROGATORY NO. 16 See Answer to Interrogatory 15, Part II. I, CHARLES E. FRY, JR., Secretary/Treasure of Hampshire Industries, Inc. declare and affirm under the penalties of perjury that the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information and belief. HAMPSHIRE INDUSTRIES, INC, BY: Charles E i CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this day of 1988, a copy of the foregoing was mailed, postage prepaid, to all counsel of record. LAW O F F IC E * MOORE, U B O W IT Z & THOMAS tO FC Z SIO N A X. A S S O C IA T IO N j ' FLO O * >0 M. *.a A R L E 8 S T R E E T I|*' A V.TIM O RE, M A H V LA N D ij *r* ! E 2 0 I-A805 ; i *. iiiiiiiiiiiiiiiiiiiiiiiinii