Document KJJDzNXGONLdykrGE6vQq3Oy2

FILE NAME: American Cyanamid (AMCY) DATE: 1998 DOC#: AMCY021 DOCUMENT DESCRIPTION: Legal - Response to Interrogatories M rk S. Geraghty (State Bar No. 79043) M pni M . Lee (State Bar No. 155803) 2 DICKSON, CARLSON & CAMPILLO 120 Broadway, Third Floor 3 p O . Box 2122 Santa M onica, California 90407-2122 4 (310) 451-2273 5 Attorneys fo r Defendant, AMERICAN CYANAMID COMPANY 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 10 11 IN RE: COMPLEX ASBESTOS LITIGATION 12 13 14 CASE NO. 967546 . DEFENDANT AMERICAN CYANAMID COMPANY'S RESPONSE TO STANDARD INTERROGATORIES TO ALL DEFENDANTS 15 American Cyanamid Company ("Cyanamid") responds to the Standard Interrogatories 16 to all Defendants pursuant to San Francisco Revised General Order No. 129, as follows: 17 ' PRELIMINARY STATEMENT 18 A fter reasonable search and diligent inquiry, defendant has made a good faith effort to 19 respond to these interrogatories based on information presently available. Defendant reserves the right to amend these interrogatory answers at any time additional information become * 21 available in the future. 22 INTERRQGAIQBY-NO.l. 23 IDENTIFY the person verifying these answers on YOUR behalf. 24 RESPONSE: 25 . Timothy T . Slater, Esq., who may be contacted through counsel for Cyanamid. 26 RRPQATQRY-MQ.-2: 27 State the date o f first employment with YOU. and the dates and titles o f each job 28 SCAMMUO bccatAiBUsiJOtomti i PROOF O P SERVICE BY M AIL 2 STATE OF CALIFORNIA 3 COUNTY OF LOS ANGELES 4 ) ) ss.: ) 5 I am employed in the County o f Los Angeles, State o f California. I am over the age o f 18 and not a party to the within action; my business address is 333 S. Grand Avenue, Suite 3400. 6 Los Angeles, California 90071-3193. 7 On October 16,1998,1served on interested parties in said action the within: 8 DEFENDANT AMERICAN CYANAMID COMPANY'S FURTHER RESPONSE TO CERTAIN STANDARD INTERROGATORIES TO ALL 9 DEFENDANTS 10 by placing a true copy thereofenclosed in sealed envek>pe(s) addressed as stated below: 11 . 12 13 Frandne Curtis, Esq. Brayton H trtey Curtis 222 Rush LandingRoad P.O .B ox 2109 Novato, California 94948 14 IS . Berry & B eny Station D P.O .B ox 70250 Oakland, California 946124)250 16 and depositing such envdope(s) in this firm's pick-up box for collection and mailing by placing 17 them in a postal box in my work area. 18 . I am "readily familiar" with this firm's practice o f collection and processing conespondence, pleadings and other documents for maifing. Under that practice such papers are 19 deported in the U.S. postal sendee on that same day I place them in the postal box in my work area in the ordinary course o f business. I am aware that on motion o fparty served, service is 20 presumed invalid if the postal cancellation date or postage m eter date is more than 1 day after the stated date o f deposit for mining set forth in an affidavit for proof o f service. 21 I declare under penalty o fpeijuiy under the laws o f the State o f California that the 22 above is true and correct. 23 Executed on the 16th day o fOctober, 1998, at Los Angeles, California. 24 25 Ten French 26 27 28 -l-  position the person verifying these interrogatories has held while employed by YOU. 2 RESPONSE 3 On o r about November 22, 1994, Timothy Slater was given the assignment o f 4 Assistant Secretary to American Cyanamid Company. . 5 M Q gA T P R Y flQ iJ: 6 State whether or not YOU are a corporation, and if so, state: 7 A. YOUR correct corporate name; 8 B. YOUR state o f incorporation; 9 C . The date o f YOUR incorporation; 10 D . The address o f YOUR principal place o f business; . 11 E. W hether o r not YOU have ever held acertificate o f authority to do business hr 12 the State of California, and if so, the inclusive dates o f any certificate; . 13 F . I f YOU are wholly owned or the majority interest o f YOUR company is owned 14 by another business rarity, state the entity's name and principal place of business; 15 G. W hether YOU have any business offices in California, and, if so, YOUR 16 principal place o f business in California. 17 RESPONSE: 18 Yes. 19 A. American Cyanamid Company 20 B. M aine . 21 C. 1907 22 D. Five Giralda Farms . . 23 M adison, New Jersey 24 E. Authorized to do business in California on March 6 , 1940 25 F. American Home Products ` ' 26 Five Giralda Farms . 27 M adison, New Jersey ' 28 VPIC8S 40 CKSOM.CANUOM ftC A M M U O G. W ith respect to the subject tim e frame, no. DCC0>A4M5l4fc9S 2 vi:;ROGATORY NO 4: H ive YOU ever been identified, known, o r done business under any other name in the State o f California? RESPONSE: 5 W ith respect to the subject time am e, no. 6 P IE B R Q g A a m O iQ .J: 7 I f your answ er to Interrogatory N o. 4 is in the affirm ative, please state such me o r 8 names and the tim e period during which THIS DEFENDANT was so known o r identified. 9 RESPONSE: 10 Not applicable. . 11 K INTERROGATORY NO. 6: 12 I I f YOU are not a corporation, what is YOUR business structure (partnership, joint 13 I venture, sole proprietorship, etc.). 14 | RESPONSE: 15 Defendant Is a corporation. 16 ROGATORY NO, 7: 17 I f YOU are not a corporation, please IDENTIFY all persons or other entities with an 18 ownership interest In YOU. 19 20 21 22 23 24 25 26 27 28 . aw m e n o r .KIOM.CAMSOM acAiinus tMMMMICA RESPONSE: Defendant is a corporation. IMVa ROGATORY NO. 8: I f you are not a corporation, please state die following: A. The address where die HISTORICAL RECORDS o f THIS DEFENDANT ar currently located; and B. The name, jo b tide and current address o f the Custodian for THIS . DEFENDANT'S HISTORICAL RECORDS. As used herein, "HISTORICAL RECORDS" shall include all DOCUMENTS relating to the formation o f THIS DEFENDANT, all m inutes o f partners', general partners', o r other DOCOlAAMSiaftWU 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNffMCUW cammvp SAfaiwca owner' m eetings, and all DOCUMENTS relating to THIS DEFENDANTS merger with, acquisition o f o r purchase, o r sale o f or by any other COMPANY. RESPO NSE-' Defendant is a corporation. flflm O ffA X Q R Y m g : IDENTIFY YOUR custodian o f Business Records. fiESEQHSE: Timothy Slater, E sq., Assistant Secretary for Cyanamid may be contacted through counsel for Cyanamid. . INTERROGATORY NO. 10: IDENTIFY the person o r persons most knowledgeable about: A . YOUR acquisition o f RAW ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS; B. YOUR use o f RAW ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS; C . YOUR contracting with others to do w ork involving use or handling o f RAW ASBESTOS o r ASBESTOS-CONTAINING PRODUCTS. RESPONSE: A. Robert Stevens o f Cytec Engineered M aterials, In c., who may be contacted through counsel for Cyanamid. . B. Robert Stevens o f Cytec Engineered M aterials, Inc., who may be contacted through counsel for Cyanamid. C . Cyanamid did not contract with others to "use o r handle" die asbestos in their manufacture o f asbestos-containing products. INTERRQOATORY m I I : For DEFENDANTS involved in the MARKETING o f ASBESTOS-CONTAINING PRODUCTS, state the IDENTITY o f physicians, medical directors and/or industrial hygienists employed by YOU during the tim e frame o r prior to the time YOU discontinued DCOWUHjtMM 4 i the m arket o f such products. All other DEFENDANTS need only respond ts to medical tUrectors and/or Industrial hygienists o r p h y sfo i^jg g p lo y ed in the area o f employee health and safety. PREM ISES owners and domestic corporations need only respond as to the United States. RESPONSE: Richard I . Leswing, Desmond B. Pearce, Joseph C . Caporossi, W illard R . Kara, 7 M ichael U tidjian, N ick Yin and Lisa W estenberger, all o f whom may be contacted through 8 counsel for Cyanamid. 9 CIIPAROGATORY NO. 12: 10 Has any employee o f THIS DEFENDANT testified by deposition or at trial on behalf 11 o f THIS DEFENDANT in a third-party case, in which THIS DEFENDANT was a party, 12 wherein the plaintiff has alleged an asbestos-related injury? I f so, for each such third-party 13 case (except that Prem ises Defendants and Contractor Defendants need answer only with 14 respect to cases relating to sites w ithin the GEOGRAPHIC AREA) please state: 15 A . The caption and case number; 16 B. The court filing including state and county; 17 c. The date o f deposition or trial testimony; 18 D . The name and address o f plaintiffs' counsel of record; 19 E. The name and address o f the court reporter. 20 RESPONSE: 21 12. A. D r. Richard Leswing; 22 B. Buechler v. H.W . Porter, ct a l.. Case N o.: 1^28448-80 23 C . New Jersey; 24 D. January 27,1982; 25 E. Unknown. 26 I F. Seymore Schulman, 10 Gurley Road, Nixon, New Jersey 08817. 27 12. A . D r. Richard Leswing; 28 B. Case N o.: L-25364-91 uxmenM :UM. CMUON kCAMPtUO DCC01/UW M .5W 73J wmjnwmeit ! 5 a C . New Jersey; -"` ' t f . November 22, 1982; E. Unknown. 4 F. M iddlesex Reporting, 11 River D rive, M arlboro, New Jersey 07746. 5 12. A. M r. Bernard Goodwin; 6 B. Buechler v. H .W . Porter, e t a l.. Case N o.: L-28448-80 7 C. New Jersey; 8 D. A pril 18. 1982; 9 E. Unknown. 10 F. Cittone Associates, 1697 Oak Tree Road, Edison, New Jersey 08820. 11 12. A. 12 B. 13 C. 14 D. D a n s Knowlton; Bartushak v. American Cvanamid. et a l.. Case N o.: L-2834-81 New Jersey; June 14,1984; 15 E. Unknown. . 16 F. M iddlesex Reporting, 11 River D rive, M arlboro, New Jersey 07746. 17 12. A. 18 ,, B. 19 C. R obert HoUender; . Bartushak V. American Cvanamid. et ah. Case N o.: L-2834-81 New Jersey; 20 D. June 14,1984; 21 1 E. 22 F. 23 12. A. Unknown. ' M iddlesex Reporting, 11 River D rive, M arlboro, New Jersey 07746. Floyd H. Powell; . 24 B. Buechler v. H .W . Potter, et al.. Case N o.: L-28448-80 25 C. New Jersey; 26 D. M arch 8, 1982; 27 E. Unknown. 28 jH nair iuO Mit.nC AuMoM N F. Cittone Associates, 1697 Oak Tree Road, Edison, New Jersey 08820. DOOBUUOS3IAM73J4 6 Desmond B. Pearce; 2 B. H ovanv^A m crican Cvanamid, et a l..Case N o.: L-28448-80 3 C. New Jersey; 4 D. A pril 18,1983; 5 E. Unknown. 6 F . Cittone Associates, 1697 Oak TreeRoad,Edison, New Jersey 08820. 7 INTERROGATORY NO. 13: 8 For each o f the following, please state whether, at any tim e within the time fiarnie or 9 until such tim e as any defendant which had been engaged in MARKETING RAW ASBESTOS 10 o r ASBESTOS-CONTAINING PRODUCTS discontinued the MARKETING o f such products, 11 THIS DEFENDANT was a member o r paid dues for any representative o f TIBS 12 DEFENDANT (excluding faculty members o f educational institutes) to be a member o f the 13 following: 14 A. Am erican Conference o f Governmental Industrial Hygienists; 15 B. American Industrial Hygiene Association; 16 . C . American Petroleum Institute; 17 D. American Railroad Association' . 18 E. Asbestos Cement Producers Association; 19 20 21 F. Asbestos Information Association (ALA) (please answer through date o f your answ ers); G. Asbestos Information Association/North America (AIA/NA) (please answer 22 . through date o f your answers); 23 H . Asbestos Textile Institute (A H ); 24 I. Industrial Hygiene Foundation and/or Industrial Health Foundation (IHF); 25 J. Industrial M ineral Insulation Manufacturers Institute; 26 K. M agnesia Insulation Manufacturers' Association; . 27 L. M agnesia Silica Insulation M anufacturers Association' 28 M . M ineral W ood Institute; (SM IC A M M N fcCAMHUO DCC01AANM .0fcnSt 7 National Insolation Manufacturers Assoc National S afey Council; New York Academy o f Sciences; Qubec Asbestos M ining Association (QAMA); Refractories Institute; Safe Building Alliance (please answer through date o f your answers); Thermal Insulation Manufacturers Association (TIMA); .S. M aritime Commission; - IDENTIFY any other organizations, associations or groups o f manufacturers, m iners, distributors, im porters, labelers, suppliers, and/or sellers o f ASBESTOS- CONTAINING PRODUCTS o f which THIS DEFENDANT was a member; W. IDENTIFY any such representative o f THIS DEFENDANT. ISE: Based upon a reasonable inquiry and diligent search, defendant responds as follows: A. American Conference o f Governmental Industrial Hygienists - No. . American Industrial Hygiene Association - Yes. American Petroleum Institute --No. American Railroad Association --No. . Asbestos Cement Producers Association - No. - Asbestos Inform ation Association (AIA) - No. Asbestos Inform ation Association/North America (AIA/NA) - No. Asbestos Textile Institute (ATI) --No. Industrial Hygiene Foundation and/or Industrial H ealth Foundation (IHF) --No. Industrial M ineral Insulation Manufacturers Institute --No. Magnesia Insulation Manufacturers' Association --No. Magnesia Silica Insulation Manufacturers Association --No. M ineral Wood Institute - No. National Insulation Manufacturers Association (NIM) - No. PCOOtA4M5I.Oft*aM o . National Safety Council --Yes. p . New York Academy o f Sciences - Yes. 3 Q. Quebec Asbestos Mining Association (QAMA) - No. 4 R. Refractories Institute - N o. 5 S. Safe Building Alliance --N o. 6 T. Thermal Insulation M anufacturers Association (TIMA) - No. 7 U . U .S. Maritime Commission --N o. 8 V . Defendant is unaware o f any other such memberships responsive to this 9 category. 10 W . Based upon defendant's understanding o f the term "representative", defendant 11 responds as follows: None. 12 INTERROGATORY NCU4: . - 13 F o r each organization, association o r other entity identified in YOUR respond to 14 Interrogatory N o. 13, please state: 15 A . The dates during which THIS DEFENDANT was a member; 16 B. The name(s) o f any publication^) received by THIS DEFENDANT from such 17 association o r organization; 18 C . The name of any committee o r subcommittee o f which THIS DEFENDANT 19 w as a member, and the dan o f such committee o r subcommittee membership. 20 | RESPONSE: 21 Upon a reasonable and good faith effort to obtain the requested information in order to 22 respond to this interrogatory, defendant states (hat it is unable to respond to the extent that 23 this interrogatory seeks information dating back to 1930. The only information reasonably 24 available to defendant dates back to 1965. 25 Subject to the above limitations and objections, this responding party states as follows: 26 A . National Safety Council 1988-1991 27 American Industrial Hygiene Association from 1965 28 J4CCIOAN*MCmAifOtUONI PC IM A iW M A M B 5t U ffA wemcA New Y ork Academy o f Sciences 1991 B. U pon a reasonable and good faith effort to obtain the requested information, defendant states that it does not maintain any record o f any publications it may have received. Based upon available inform ation, this defendant states as follows: "Recommended Procedures for Sampling and Counting Asbestos Fibers" from the American Industrial Hygiene Association; "Recent Advances in O dor", Annals o f the New York Academy o f Sciences. V 116, Art. 2 , p. 357-746, July 30, 1964; Recombinant DNA Technology 1", Annals o f the New Y ork Academy o f Sciences, V 646, December 2 7 ,1 9 9 1 ; "Macromotecular Structure and Specificity", Annals o f die New Y ork Academy o f Sciences, V 4 3 9 .1 9 8 5 , M issing - not found, "Accident Prevention M anual for Industrial O perations", 2nd ed. 1951, "Supervisors Safety M anual", 3rd ed. 1967, "Accident Prevention Manual for Industrial O perations", 6th ed. 1951, "Company Product Safety and Product Loss Prevention Program - Guidelines o f M anagement". 1967. C. N ot applicable. INTERRQffATOR X H L lS : Had TH IS DEFENDANT prior to 1973 received any DOCUMENTS containing results o r conclusions o f any studies and/or tests conducted by Bonslb for Standard Oil o f New Jersey relating to asbestos exposure in die w ork place o r die human health consequences o f exposure to asbestos? I f so: ' A. E ither (1) attach all DOCUMENTS evidencing the information sought in this Interrogatory and its subparts to your answers to these Interrogatories, o r (2) attach disks containing such data, o r (3) describe such DOCUMENTS w ith sufficient particularity that they may be m ade the subject o f a request for production o f documents. . B. State the date upon which THIS DEFENDANT first received such DOCUMENTS; C . State die IDENTITY of the custodian o f such DOCUMENTS; OOOQOAflMSliXMnM 10 1 *. - ' . * D . This interrogatory docs not apply to DOCUMENTS contained in a library 2 maintained by a DEFENDANT hospital o r a DEFENDANT's library providing access to the 3 general public. 4 RESPONSE: 5 In an effort to respond to this interrogatory, defendant conducted a reasonable and 6 good faith search. Based upon that search, defendant responds as follows: N o, discovery is 7 continuing. 8 INTERRQOATQRYNOL16: 9 Had THIS DEFENDANT prior to 1973 received a copy or any portion o f any studies 10 and/or tests conducted by any insurance company, including but not limited to M etropolitan . II lif e Insurance Company and Aetna Insurance relating to asbestos exposure in fee work place 12 o r the human health consequences o f exposure to asbestos? If so: w 13 14 A . Either (1) attach all DOCUMENTS evidencing fee information sought in this Interrogatory and its subparts to your answers to these Interrogatories, o r (2) attach disks 15 containing such data, o r (3) describe such DOCUMENTS with sufficient particularity that 16 they may be made the subject o f a request for production o f documents; 17 B. State fee date upon which THIS DEFENDANT first received such 18 DOCUMENTS; 19 C . State tire IDENTITY o f fee custodian o f such DOCUMENTS; 20 D. This interrogatory does not apply to DOCUMENTS contained in a library 21 maintained by a DEFENDANT hospital or a DEFENDANT'S library providing access to the 22 general public. 23 RESPONSE: 24 In an effort to respond to tills interrogatory, defendant conducted a reasonable and 25 goqd faith search. Based upon the search conducted to date, defendant responds as follows: 26 N o, discovery is continuing. 27 INTERROGATORY NO. 17: 28 Had THIS DEFENDANT prior to 1973 received any DOCUM ENTS containing <tCtOAKMCHAUfOtUON OCCmAdM SI.0fe973 1111 UwtAMBUm restdtt o r cooclosions o f any studies and/or testa conducted by any laboratory, including but not lim ited to , the Saranac Laboratory relating to asbestos exposure in the work place o r die Iranian health consequences o f exposure to asbestos? I f so: A. Either (1) attach all DOCUMENTS evidencing the information sought in this Interrogatory and its subparts to your answers to these Interrogatories, o r (2) attach disks containing such data, o r (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject o f a request for production o f documents; B. State the date upon which THIS DEFENDANT first received such DOCUMENTS; C . State die IDENTITY o f the custodian o f such DOCUMENTS. D. This interrogatory does not apply to DOCUMENTS contained in a library maintained by a DEFENDANT hospital or a DEFENDANT'S library providing access to die general public RESRPHSE: In an effort to respond to this interrogatory, defendant conducted a reasonable, and good faith search. Based upon die search conducted to date, defendant responds as follows: Unknown. Discovery is continuing. is iia i QQATQRYm 19: Had THIS DEFENDANT (except for a defendant that is an educational institution) prior to 1973 ever maintained a library (or libraries) which contained books, articles, periodicals, journals, and/or reference materials that related to the subjects o f asbestos, industrial hygiene, m edicine, safety and/or occupational disease. I f so, state: A. The date each such library was established; B. The location o f each sudi library; C. The IDENTITY o f each librarian o r other person in charge of sudi library. occoMOMSiofcanM 12 2 D efendant responds as follows: Yes. Defendant has maintained libraries. However, 3 die precise m aterials contained therein and whether they relate to die above-referenced 4 subjects are unknown. 5 ' A . Various dates; 6 B. Pearl R ivet, New York; Stamford, Connecticut; W ayne, New Jersey; New 7 Y ork, New York; Princeton, New Jersey; Bound Brook, New Jersey. 8 C . D r. Layne Johnson (Pearl River, New Y ork); M s. M artha Reiter (Stamford, 9 Connecticut); M s. M arie Sparks (last librarian at W ayne, New Jersey); Unknown (New 10 Y ork); D r. D avid Saari (Princeton, New Jersey); M s. Joan Gallagher (through 1982 at Bound 11 Brook, New Jersey). 12 INTERROGATORY NO. 19: 13 W ith the exception o f OSHA compliance, had THIS DEFENDANT (except for a 14 defendant that is an educational institution) prior to 1980 exchanged DOCUMENTS or 15 I communicated w ith any person or other COMPANY expressly regarding die results o f tests 16 and/or studies relating to asbestos exposure in die work place o r die human health 17 consequences o f exposure to asbestos? If so, state: 18 A . Each person o r COMPANY with whom the inform ation was exchanged o r to 19 I whom it was communicated; 20 B. The date(s) o f any such exchanges o r communications; 21 C . The IDENTITY o f the custodian o f such DOCUMENTS. 22 11 RESPONSE: 23 No. 24 BRQPATQRY..MQJQ: . 25 Has any em ployee o r designee o f THIS DEFENDANT testified as a representative o f 26 THIS DEFENDANT before die Occupational Safety and H ealth Administration, the National 27 Institute o f Occupational Safety and Health, or any committee o r subcommittee o f die United 28 4CMIfeiU toCG0tlAd0M&tJQM735& 13 vmummcA X Cbogrss relating to asbestos exposure in the work place o r the human health 2 consequences o f exposure to asbestos? If so, please state: 3 A. The entity before whom such testimony was .given; 4 B. The date(s) and locations) o f such testimony; 5 C. The IDENTITY o f the individual(s) who so testified; 6 D. W hether any DOCUMENTS were presented to the entity before w hich 7 testimony was given; 8 E. W hether copies o f DOCUMENTS presented were retained by THIS 9 DEFENDANT and, if so, state the IDENTITY o f the custodian o f such DOCUMENTS. 10 RESPONSE: 11 No. 12 SRQOAXQRY NO. 21: 13 Has THIS DEFENDANT (except for a defendant that is an educational institution) 14 conducted, o r caused to be conducted, tests, and/or studies o f ambient asbestos dust created 15 during the manufacture, processing and/or assembling for sale o f ASBESTOS-CONTAINING 16 PRODUCTS? If so, state: 17 A. Each manufacturing facility, including location and address, at w hich any such 18 test and/or study was conducted; 19 B. The date o f each such test and/or study; 20 C. The individual^) o r entity conducting each such test and/or study; 21 D . W hether THIS DEFENDANT has any DOCUMENTS containing the results 22 and/or conclusions o f each such study; ' 23 E. The IDENTITY o f the custodian o f such DOCUMENTS. 24 RESPONSE: 25 No. 26 icii aafi. AXQR Y m J tt. 27 Has THIS DEFENDANT (exceptfor a defendant that is an educational institution) ` 28 wwtmcnw CKSOM. CAIt*J*OH ACAMMU0 conducted, o r caused to be conducted, any tests and/or studies on ambient asbestos dust levels DcaaA*B6SiJcnms6 14  ------------ w ' ' X . a t U 9 location o r job site where ASBESTOS-CONTAINING PRODUCTS were installed, . 2 . utilized o r removed? I f so, for the first S tests and/or studies, state: 3 A. The location, including name and address, at which each such test and/or study 4 was conducted; 5 B. The individual(s) o r entity conducting each such test and/or study; 6i C . The date o f each such test and/or study. . ' 7 D. W hether THIS DEFENDANT has any DOCUMENTS containing die results 8 and/or conclusions o f each such test and/or study; 9 E . The IDENTITY o f die custodian o f such DOCUMENTS. RESPONSE: 10 11 Based upon a diligent search and reasonable inquiry, including inquiry to other 12 persons, in an effort to respond to this interrogatory, defendant responds as follows: - 13 14 15 16 17 18 (a) Havre de Grace, Maryland; (b) Fred W. Farwell, D .W . Davis, B. W ilcox, John A . Refiner, and C . Garland; (c) Farwell, 8/23/72; D avis; 4/25/74; W ilcox, 7/27/78, JAR, 5/18/79; Garland, 7/15/80 (d) Yes, to some extent (e) Dickson, Carlson & Campillo. 19 INTERROGATORY .M O ,.: 20 | Did THIS DEFENDANT (except for a defendant that Is an educational institution) 21 have any laboratory o r other sim ilar type o f facility anywhere in die United States at which 22 it conducted, or caused to be conducted, any tests and/or studies o f ASBESTOS- 23 CONTAINING PRODUCTS o r RAW ASBESTOS relating to the health consequences of 24 asbestos or die dust generated by any use o f asbestos o r ASBESTOS-CONTAINING 25 PRODUCTS. If so, state: 26 A. The location. Including name and address, at which each test and/or study was 27 conducted; 28 U ****** 0 CU4COAMMLCMAUII0UON ***** MP--CA B. The individual^) o r entity conducting each such test and/or study; DCC02A83631.00.97336 15 ' . ;. ** 1 '> C .. H ie date o f each such test and/or study; 2 b . W hether THIS DOCUMENT has any DOCUMENTS .containing the results 3 and/or conclusions o f each such test and/or study; 4 E. The IDENTITY o f the custodian o f such DOCUMENTS. 5 RESPONSE: 6 Based upon a diligent search and reasonable inquiry, defendant responds that it is 7 unaware o f any such studies relating to fee health consequences o f asbestos. a PflEBRQgATQRY NO, 24: 9 Has THIS DEFENDANT made available to its employees a medical examination 10 program to determ ine die absence or presence o f asbestos-related disease? I f so, state: 11 A . W hether chest x-rays o r pulmonary function tests were part of such program(s); 12 B. W hether participation in any such program was a mandatory condition o f . 13 employment o r w as voluntary; t . . v 14 C . W hether THIS DEFENDANT has DOCUMENTS o f such program(s); 15 D . The IDENTITY o f the custodian o f such DOCUMENTS. 16 RESPONSE: 17 N o. However, defendant's corporate policy required physical examinations for pre- 18 cmploymcnt. A lso, annual and bi-annual physical examinations and chest x-rays were 19 recommended. Defendant's policy is set forth in a Cyanamid general order dated March 5, 20 1969, an copy o f which is maintained by Cyanatnid's counsel. 21 ntTERBOffATQSY.NQ, 25: 22 Prior to 1973, did any person file a W orkers' Compensation claim for asbestos-related 23 injury against THIS DEFENDANT o r against any Workers* Compensation insurance carrier 24 which provided coverage fo r THIS DEFENDANT? If so, state fee total number o f such 25 claims and, for the first 20 such claims state: 26 A. The date o f such claim; 27 B. The name o f the claimant; . 28 C . The case number; UVfff)CiCf ftCAUMUA vccsajdaoeaimsnx 16 ANTA MOHICA  ./V*-s . X The co u it in w hich the claim was filed; B. The IDENTITY o f THIS DEFENDANT'S custodian o f DOCUMENTS evidencing such claim s. . RESPONSE: Upon a diligent search and reasonable inquiry, defendant states that it has no records o f any such claim prior to 1973. INTERROGATORY NO. 26: Does THIS DEFENDANT have insurance available to cover judgm ents) entered against it in asbestos-related personal injury lawsuits? I f so* state: A . The name and principal place o f business o f any insurance carrier who has issued such policy o f insurance; . B. The number and effective date o f each policy; C . The am ounts) o f coverage o f each policy; D. SflMCl The applicable dates o f coverage.' Defendant has previously produced a voluminous and detailed summary o f its insurance coverage from 1955 to 1986. Defendant further states that based upon a diligent search and reasonable inquiry, in an effort to respond to this interrogatory, defendant determined that records no longer exist wife respect to American Cyanamid's insurance . coverage from 1930 to 1954, and therefore defendant has no information feat would enable defendant to respond. * Kill KRQGATORY NO. 27: State whether YOU have controlled, purchased, o r in any way acquired any controlling interest in any corporation o r business entity which has mined, manufactured, produced, processed, compounded, sold, supplied, distributed and/or otherwise placed RAW ASBESTOS o r ASBESTOS-CONTAINING PRODUCTS in fee stream o f commerce. I f so, state: A . The name and address o f said corporation o r business entity; B. The dates YOU controlled, purchased o r acquired any interest; and DCCttA.'OMSIwQfcroS* 17 -rz-- &. -- C . ' The oatuic o f (be business as it pertains to asbestos. tSE- A. Bloomingdale Rubber Company, Havre de Grace, Maryland; BASF plant, Anaheim, California B. M ay 17, 1963; July 9, 1993; C . Aerospace industry. INTERROGATORY NO. 28: State whether THIS DEFENDANT, between 1930 and 1985, has ever engaged in the following activities with regard to RAW ASBESTOS, and if so, state the inclusive dates o f 10 8 such activity; 11 A. Mining; 12 B. Milling; 13 C. Supply; 14 D. Importing; 15 E. Processing; 16 F. Distribution; 17 6 . M attering; 18 H * Sale; 19 L Brokering. 20 BESEPHSE: 21 No. 22 INTERROGATORY N Q .2 9 : 23 If YOUR.answer to any o f subparts o f Interrogatory 28 regarding RAW ASBESTOS is 24 in the affirmative, state: 25 A. The trade, brand nam e, and/or generic name o f such RAW ASBESTOS milled 26 I o r MARKETED in any form o r quantity between 1930 and 1985; 27 B. The date(s) such RAW ASBESTOS was first placed on the m arket, including 28 the date(s) such RAW ASBESTOS was first marketed: COON. CAKISCN eoeoujwnMMM 18 O n an experimental basis; On a test basis; 3 For sale; 4 C . The datc(s) such RAW ASBESTOS: 5 1. Ceased to be produced; or 6 2 . Was recalled from die market, if ever. 7 D. A description o f the chemical composition o f such RAW ASBESTOS, including 8 the type and/or grade o f asbestos; 9 E. A description o f the physical appearance and nature o f such RAW ASBESTOS, 10 including any color coding, distinctive marking and/or logo on the packaging o r container; 11 F. A detailed description o f the intended use o f such RAW ASBESTOS, including 12 any tem perature lim its for each such use; , 13 14 . G. W hether such RAW ASBESTOS was on die U .S . Government's "Qualified Products L ist," and if so, the inclusive dates it was on such list; 15 H. IDENTIFY to whom such RAW ASBESTOS has, at any time, b eat sold . As 16 to each such, state: 17 I. W hether any o f THIS DEFENDANT'S RAW ASBESTOS has, at any time, 18 been sold, shipped, o r otherwise distributed, used on instalied to o r at any COMPANY 19 (including power company or utility), governmental agency o r entity, shipyard, distributor, 20 refinery, contractor, supplier, PREMISE owner o r occupant, ship owner, or other PREMISE 21 o r site in the GEOGRAPHIC AREA and whether any o f THIS DEFENDANT'S RAW 22 ASBESTOS has at any tim e, been sold to any m anufacturer, o r manufacturing facility, of 23 ASBESTOS-CONTAINING PRODUCTS. I f so, state: 24 : i . The names o f each such COMPANY, governmental agency o r entity, 25 shipyard, distributor, supplier, manufacturer o r refinery; 26 2 . The inclusive dates o f each such sale, and the amount (quantity) and the 27 trade brand name o f such RAW ASBESTOS sold; 28 uttflmcaof ; k* 9 n, c a a is o n | 6 AMMUO tAWTAttOOKA 3. BccnAAUSiJtio^nM The manner o f shipment (e.g ., boat, rail, etc.); 19 1 ' . .. 4. W hether you have any records indicating any such sale o r shipn 2 if so, tile nam e, address and jo b classification o f each person who currently has possession o f 3 such records; 4 || 5. E ither (1) attach all DOCUMENTS evidencing the information sought in 5 0 this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach 6 | containing such data, o r (3) describe such DOCUMENTS with,sufficient particularity that 7 | they may be made die subject o f a request for production o f documents. 8ISE& QHSB: 9 y Not applicable. 1 0 li INTERROGATORY N O , 3 Q : 11 | Between 1930 and 1985, did YOU ever engage in any o f the activities listed below .12 B with regard to ASBESTOS-CONTAINING PRODUCTS? I f so, state the inclusive dates of 13 | such activity: 14 A* Supply; 15 B Importing; c . D istribution; 16 17 D . M arketing; 18 E Sale; 19 P . Labeling; 20 G - M anufacturing; 21 H ' Brokering. 22 B E S K P K S E : 23 A ' Yes; beginning in 1963. 24 B* No. 25 Yes; beginning in 1963. C* 26 D. Yes; beginning in 1963. 27 E. Yes; beginning in 1963. 28 F. Yes; beginning in 1963. ICCSOR CAftttON 4 CAMNLL6 D eCX O iLO M tliX M nSft 20 m m otiCA 1 . ./ & ' Yes; beginning in 1963. 2 H. No. 3 KRQQATPRY NO. 31: 4 I f your answer to any subpart o f Interrogatory No. 31 regarding "ASBESTOS- 5 CONTAINING PRODUCTS* is in the affirm ative, state: 6 A . The trade, brand name, and/or generic name o f each such ASBESTOS- 7 CONTAINING PRODUCT MARKETED in any form or quantity between 1930 and 1983; 8 B. The date(s) each such ASBESTOS-CONTAINING PRODUCT was first placed 9 on the m arket, including the datc(s) each such ASBESTOS-CONTAINING PRODUCT was 10 first MARKETED: 11 1. On an experimental basis; 12 2. On a test basis; or . 13 14 3. For sale. C . The date(s) each such ASBESTOS-CONTAINING PRODUCT: 15 1. Ceased to be produced; or 16 2. Was recalled from the m arket, if ever. 17 D . A detailed description o f the chemical composition o f each such ASBESTOS- 18 CONTAINING PRODUCT, including the type and/or grade o f asbestos and/or asbestos fiber 19 contained in each such product and the quantitative percentage o f asbestos o r asbestos fiber in 20 each such product, and all non-asbestos components o f the ASBESTOS-CONTAINING 21 PRODUCT, and if the chemical composition changed over time, the inclusive dates o f each 22 formulation; 23 . E . A description o f the physical appearance and nature o f each such 24 ASBESTOS-CONTAINING PRODUCT, including any color coding, distinctive marking 25 and/or logo, either on the product or on the packaging; 26 F . A detailed description o f the intended use o f each such ASBESTOS- 27 CONTAINING PRODUCT, including arqr temperature lim its for each such use; 28 .M r m e n 0 -K tO *. CARISON CAMMU0 M niM M U G . W hether any such ASBESTOS-CONTAINING PRODUCT was on the U.S. D CC UAM 3IJXfcf733A 21 Government's "Qualified Products List" and if so, the inclusive dates it was on such list; 2 H . The name and address o f the supplier o f die RAW ASBESTOS used in each 3 such product and the time period o f such supply;. 4 I. W hether any o f THIS DEFENDANT'S RAW ASBESTOS OR ASBESTOS- 5 CONTAINING PRODUCTS have, at any tim e, been sold, shipped, or otherwise distributed 6 to any COMPANY (including power company o r utility), governmental agency or entity, 7 shipyard, distributor, refinery, contractor, supplier, manufacturer, PREMISE owner o r 8 occupant, ship owner, o r other PREMISE o r site in the GEOGRAPHIC AREA. If so, state: 9 1. The names o f each such COMPANY, governmental agency or entity, 10 shipyard, distributor, supplier, manufacturer, refinery, contractor, PREMISE owner o r 11 occupant, ship owner, PREMISE or site; . 12 RESPONSE: . * 13 A . Defendant states that it has conducted an exhaustive search in an effort to 14 respond to this interrogatory, however, should documents evidencing additional asbestos- 13 containing products be located, defendant reserves die right to update this response. Please 16 see Exhibit "A" attached hereto. 17 B. 1. Based upon defendant's understanding o f the term "experimental basis," 18 . defendant states as follows: Only upon customer request, defendant would 19 distribute certain of its products on a trial basis. Such products are identifiable 20 by the "x" in their designation. Upon a diligent search and reasonable inquiry, 21 this defendant has determined that with respect to the defined geographical area 22 and during the tim e period in question, defendant distributed 2 quarts o f BXR- 23 34B-53, and 40 square feet o f FXM-34. 24 2. Based upon defendant's understanding o f the term `test basis," defendant 25 states as follows: Only upon customer request, defendant would distribute 26 . certain o f its products on a trial basis. Such products are identifiable by the 27 "x" in their designation. Upon a diligent search and reasonable inquiry, tills 28 defendant has determined that w ith respect to the defined geographical area and uiwmw 22 c*iCsoAm.icmmuhsm n || D C anA 4M 3l.095!33ft MUMIKt H 1 during the time period in question, defendant distributed 2 quarts o f BXR-34B- 2 S3, and 40 square feet o f FXM-34. 3 3. Please see Exhibit "A" attached hereto. 4 C . Please see Exhibit "A" attached hereto. 5 D . Please see Exhibit "A" attached hereto. 6 E. Please see Exhibit "A" attached hereto. 7 F . Please see Exhibit *A" attached hereto. 8 G . 1. BR 92; Since October 1991. 9 H . Based upon a diligent search and reasonable inquiry in an effort to comply with 10 this interrogatory, defendant has located die following information: Asbestos 11 Corporation lim ited , Thetford M ines, Quebec, Canada; Carey Canadian Mines 12 L td ., P.O . Box 190 East Broughton Station P ., Quebec, Canada GON 1HO; 13 Johns - Manvilie Corp. and Subsidiaries, P.O . Box 5108, D enver, Colorado 14 80217; Union Carbide Corporation On and about September 1976) 4625 Royal is Avenue, Niagara Fails, New York 14302; Calidria Asbestos, 500 Sugar M ill 16 Road, Suite 180A, A tlanta, Georgia 30338; Avibest Department FMC 17 Corporation (in and about A pril, 1969) Box 8, Princeton, New Jersey 08540. 18 I. The sales records o f American Cyanamid Company have previously been 19 produced to Brayton, Harley, Curtis and copies of the records were made at that tim er 20 Consequently, plaintiff is already in possession o f all existing documents that would be 21 responsive to this interrogatory. Defendant represents that all o f the documents were 22 retrieved as a result o f an exhaustive search, however, should additional documents be 23 located, defendant reserves the right to update this response. 24 INTERROGATORY NO. 32 (PREMISES DEFENDANTS ONLY): 25 Did YOU install, remove, o r handle o r contract to have others install, remove, or 26 handle RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS at any PREMISES in 27 the GEOGRAPHIC AREA which PREMISES is at issue as to YOU in San Francisco Superior 28 umv O ffices o r -t*On.CA*XSOM &CAMHUO tM U IM W C A Court asbestos litigation as o f fee date o f your answers to fedfce interrogatories? I f so: DCCUA--aMSUX>*KS6 23 A . IDENTIFY the PREMISES. B. For each o f the PREMISES: 1. State dte nature o f your ownership o r possessory interest; 2. State the inclusive date o f that interest; 3. IDENTIFY the party from whom that interest was acquired; 4. IDENTIFY the party, if any, to whom that interest was transferred. C. IDENTIFY every contract to which YOU were a party or o f which you have knowledge wherein die performance o f such contract involved the installation, removal, disturbing o r handling o f any RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS at YOUR PREMISES. F or each contract: . . 1. IDENTIFY die parties to the contract; 2. Provide a general description and specific location o f the work to be performed by each party to the contract; - 3. IDENTIFY and describe the NATURE o f the RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS Installed, disturbed o r handled in the performance o f the contract; . 17 4. State the dates o f die contract and the dates o f performance; 18 D. Except as provided in response to subpart (c), has any work over than routine 19 maintenance b en t done on or to die PREMISES that involved die installation, removal, 20 disturbing o r handling o f RAW ASBESTOS .or ASBESTOS-CONTAINING PRODUCTS? I f so, for each such instance: 21 22 I 1. State the inclusive dates o f die work; ' 23 ! 2. Provide a general description and specific location o f the work; 24 3. State whether the w ork was done by YOU and/or YOUR employees; 25 4. IDENTIFY and describe the NATURE o f the RAW ASBESTOS or 26 ASBESTOS-CONTAINING PRODUCTS installed, removal, handled or disturbed; 27 5. IDENTIFY from w hkh the RAW ASBESTOS or ASBESTOS- 28 CONTAINING PRODUCTS were acquired. uw om cnw KSOtt* CAHUON 8 CAMHUO m w I--MCA DCcasAHoutao^nstt 24 * H is any asbestos abatement effort been made at the Premises? If so, for each 2 3 1. IDENTIFY who did the work; 4 2 . State the inclusive dates thereof; 5 3. State whether samples were taken, and, if the same still exist, 6 . IDENTIFY the custodian o f the samples; 7 4 . State whether any material was tested, and, if so, what were the results 8 o f each test; 9 5. IDENTIFY each test result with sufficient particularity for purposes o f a 10 I request for production o f documents, or, in the alternative, attach a copy to YOUR answers to 11 I these interrogatories. . 12 I F . Except for insurance coverage litigation, have yon filed suit against, or 13 i otherwise sought to recover from , any perron o r entity for some o r all o f the cost o f asbestos 14 I abatement o r fo r the property damage allegedly caused by the presence o f RAW ASBESTOS IS o r ASBESTOS-CONTAINING PRODUCTS on the PREMISES identified in response to 16 subpart (A) above? I f so: 17 1. IDENTIFY tiie person o r entity against whom YOU have filed suit or 18 otherwise sought to recover; 19 2. I f YOU have filed suit, -state the court in which the action was filed, 20 tiie date on which it was filed, IDENTIFY all Plaintiffs and Defendants and their counsel o f 21 record; 22 3 . State whether or not the case has been resolved, and, if so, what was 23 die status o r disposition. 24 G . Either (1) attach all DOCUMENTS evidencing the information sought in this 25 Interrogatory and its subparts to your answers to these Interrogatories, o r (2) attach disks 26 containing such data, o r (3) describe such DOCUMENTS w ith sufficient particularity that 27 they may be made the subject o f a request for production o f documents. . 28 iMUMCHOf I II :ftSON,CAHUOM | &CAMJ*UO MnuUMCA H . IDENTIFY D cattfeC B ttM ifcm s* the persons) presently 25 most knowledgeable about the inform ation P sought Id this interrogatory o r its subparts. . RESPONSE: Defendant is not a premises defendant for any premises in the "Geographic Area." INTERROGATORY NO. 33 (CONTRACTOR DEFENDANTS ONLY): 5 At any tim e between 1930 and 1983, did YOU hold a contractor's license in the State 6 o f California? I f so, 7 A . ID EN TIFY each license by type, date and number; 8 B. I f on the date o f your answers YOU are a defendant in four or more asbestos actions in San Francisco Superior Court, IDENTIFY each jo b o r contract that YOU performed (directly o r through one o r more subcontractors) during this time period for work in any PREMISES w hich is a issue as to YOU on such date, and in any PREMISES o f 30,000 square feet o r m ore in the.GEOGRAPHIC AREA which jo b o r contract involved installation, rem oval, disturbing o r handling RAW ASBESTOS o r ASBESTOS- CONTAINING PRODUCTS. (Alternatively, at your option, you m ay IDENTIFY each job or contract YOU perform ed (directly o r through one or m ore subcontractors) during this tim e frame for ail w ork, o r fo r all work in PREMISES o f 30,000 square feet o r more, in the GEOGRAPHIC A REA .) As to each job or contract: - 1. IDENTIFY the location (including name o f ship, if applicable) where the job or work w as performed; 2. State the date o f die contract o r die inclusive dates o f die work; 3. IDENTIFY die person or entity with whom you contracted; 4. State your job o r contract number. C. I f on the date o f your answers you are not a defendant in four o r more asbestos actions in San Francisco Superior Court, IDENTIFY c a d i job o r contract that YOU performed (directly o r through one o r more subcontractors) during this time period for work in any PREMISES which is a t issue as to YOU on such date. A s to each such job or contract: 1. IDENTIFY the location (including name o f ship, if applicable) where DCaOA365IJX>:*M 26 1 foe jo b o* Work was performed; 2. State the date o f the contract or the inclusive dates o f the work; 3 3. IDENTIFY the person o r entity w ith whom you contracted; 4 4. State your jo b o r contract number. 5 RESPONSE: 6 Defendant is not a Contractor D efendant 7 1WISRR0QATQRY.NCL34: 8 Did any o f foe distributors identified in your Answer to Interrogatory Nos. 29 and 31 9 above an exclusive distributorship? I f so, state foe relevant time period. 10 RESPONSE-' 11 Not applicable. 12 miERRQQATQRY.NQ, ??: 13 If THIS DEFENDANT entered into any agreements for foe rebranding o f any 14 ASBESTOS-CONTAINING PRODUCTS by THIS DEFENDANT for. resale o r distribution 15 by another person o r entity, describe each agreement's terms and foe parties to said 16 agreement, foe duration o f foe agreement, and name o f each produces) and/or m aterials) 17 covered by each such agreement. 18 BKEQNSE: 19 Defendant did not enter into any agreements for rebranding o f any asbestos-containing 20 products. 21 INTERROGATORY NO. 3fr 22 If THIS DEFENDANT entered into any agreements for foe rebranding o f 23 ASBESTOS-CONTAINING PRODUCTS manufactured, sold, supplied o r distributed by 24 another person or entity for resale o r distribution by YOU, describe each o f foe agreements 25 and the parties to said agreement, the term s, foe duration, and foe names o f each produces) 26 and/or material(s) covered by each such agreement. . 27 RESEONSE: 28 Not applicable. wan CMOM, CAMISON tC A M m io B oaaA M en ja o # a s6 27 KS-' ATOMCNQ.37: As to RAW ASBESTOS and to each such ASBESTOS-CONTAINING PRODUCT listed in YOUR responses to Interrogatories Nos. 29 and 31 did DEFENDANT warn o f die health hazards o f asbestos? I f so, state for each such warning: A. The content, size, color, and location; whether the warning appeared on the m aterial and/or on the container, and/or was placed on a tag; whether the warning was included in contracts; whether the warning was included in advertising or other promotional m aterials; B. State whether you have any photographs thereof; C . The inclusive dates on which you used each such warning; D . State all changes you made in such warnings and die dates of such changes; and E. Identify the person most knowledgeable about your warnings and warning 13 policy. 14 RESPONSE: 15 Based upon a diligent search and reasonable inquiry and pursuant to CCP $ 2030(f)(2), 16 defendant states that it previously produced documents responsive to this request and therefore 17 this information is already available to plaintiff. 18 foQGATQB E K C U fr W ith respect to each o f YOUR ASBESTOS-CONTAINING PRODUCTS, state 19 I 20 whether THIS DEFENDANT'S nam e, a trademark, logos, color coding, or other identifying 21 markings ever appeared on the actual product itself. I f so, IDENTIFY each such product, 22 state when the practice to place such identifying markings upon the product was begun and 23 w hen it ended, if applicable, and describe in detail the pertinent marking(s) and the purpose, 24 if any, o f such markings. 25 RESPONSE: 26 All o f defendant's products are labeled to include the following information: Product 27 nam e, company name, date o f manufacture, batch and warnings. The films have a label on 28 U W I9M M O I CftSOtt, ftfftSON 69A M TIU 9 UffAftMWe* tire core on which the film is wound and on the bag containing the adhesive and on the box in BeecoA.-aun.M;mM 28 which tbcbaggod adhesive is shipped. The foams are packaged in boxes in which 25 to 40 sheets are placed; the sheets are sealed in a vapor barrier bag w ithin the box and labels are placed pn each sheet, on the vapor barrier bag and on the box. INTERROGATORY NO. 39: Between die years 1930 and 1985, did THIS DEFENDANT purchase o r otherwise acquire any ASBESTOS-CONTAINING PRODUCT lines from another person or entity? If so, state for each such purpose: A . Date o f purchase o r acquisition; B. Term s o f purchase o r acquisition agreement; C . Either (1) attach all DOCUMENTS evidencing said acquisition; o r (2) attach disks containing such data, or (3) describe such DOCUMENTS w ith sufficient particularity that they may be made the subject o f a request for production o f documents; D . Trade, brand, and/or generic name o f each such product line so acquired; E . Name o f the person o r entity from which YOU purchased o r acquired each such ASBESTOS-CONTAINING PRODUCT line; and F. Location o f any manufacturing facilities so acquired, and the type o f ASBESTOS-CONTAINING PRODUCTS manufactured therein RESPONSE: Yes. A. May 17, 1963; . . B. Cyanamid acquired all o f Bloomingdale's assets, property, business and good will based upon Bloomingdale's representation and warranties respecting the entity. C. BR 34, BR 92 Adhesive, and BR-34B-18. D . Bloomingdale Rubber Company E. Havre de Grace, M aryland KROGATORY NO. 40: Between the years 1930 and 1985, did THIS DEFENDANT sell any ASBESTOS- CONTAINING PRODUCT line to another person or entity? I f so, state fo r each such sale: DCC02AB U I.00:97336 29 4 1 A /''" D ate o f sale; 2 B. Term s o f sales agreement; 3 C . Either (1) attach all DOCUMENTS evidencing said sale, or (2) attach disks 4 containing such data, o r (3) describe such DOCUMENTS with sufficient particularity that 5 they may be made the subject o f a request for production o f documents. 6 D . Trade, brand, and/or generic name o f each such product line sold; 7 E . Name o f person or entity to whom you sold each such ASBESTOS- 8 CONTAINING PRODUCTS line; 9 F . Location o f any manufacturing facilities so sold, and the type o f ASBESTOS- 10 CONTAINING PRODUCTS manufactured therein. 11 RESPONSE: 12 No. 13 INTERROGATORY NO. 41: 14 IDENTIFY all brochures, pamphlets, catalogs o r other advertising relating to . 15 ASBESTOS-CONTAINING PRODUCTS and/or RAW ASBESTOS which THIS 16 *DEFENDANT manufactured, sold, distributed, o r supplied from the year 1930 to 1985. For 7 each such document, state: 18 A . A description o f tire document; 19 B. The year it was printed; . 20 C . The period o f tim e inw hich h was used; 21 D . The purpose o f such document; 22 E . W hether tire documents or copies o f said documents presently exist; 23 F . I f said documents o r copies still exist, where they are located; and 24 G . The IDENTITY o f the custodian o f such documents. . 25 RESPONSE: 26 Based upon a diligent search and reasonable inquiry and pursuant to CCP 2030(f)(2). 27 defendant states that it previously produced documents responsive to this request and therefore , 28 this inform ation is already available to plaintiff. CKSO*. CAHUONl 8CAIIM UO DCC02A--CB5I.0fefn* 30 AMAMMKA l iBSfeodATORY NO. 42: 2 State if YOU have or had within YOUR corporate o r other business structure any 3 CONTRACT UNITS. 4 BESRQNSg: 5 No. 6 INTERROGATORY NO. 43: 7 State w hether o r not any o f YOUR CONTRACT UNITS installed and/or removed 8 RAW ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS in the GEOGRAPHIC 9 AREA at any tim e between 1930 and 1985. I f so: 10 A . State the business addresses and name o f the CONTRACT UNIT; 11 B. State the inclusive periods o f tim e the CONTRACT UNITS were working in 12 the GEOGRAPHIC AREA; 3 C. State the name and address o f each jo b site w ithin the GEOGRAPHIC AREA 14 and the dates the CONTRACT UNIT worked at those job sites, and, IDENTIFY die RAW 15 ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS installed o r removed oh each 16 occasion; 17 D . E ither (1) attach all DOCUMENTS evidencing die inform ation sought in this 18 Interrogatory and its subpaxts to your answers to these Interrogatories, o r (2) attach disks 19 containing such data, o r (3) describe such DOCUMENTS w ith sufficient particularity that 20 they may be made the subject of a request for production o f documents. 21 BJESEQNSfr 22 I Not applicable. 23 IN TERROGATORY NO. 44: 24 W hen do YOU contend that THIS DEFENDANT first became aware that there is an 25 association between asbestos exposure and disease in human beings? 26 RESPONSE. 27 Based upon a reasonable and good frith effort to obtain Information in order to 28 Of tUOM Jt , respond to this interrogatory, defendant states that it is unable to respond. vccaiAtfxsi.aa& nst 31 Due to the 1 historical itttu ie o f this interrogatory, neither the documents nor the individuals, upon 2 which/wbom defendant would rely in order to respond, are still available. 3 INTERROGATORY NO. 45: 4 How do YOU contend that THIS DEFENDANT first became aw ait that there is an 5 association between asbestos exposure and disease in human beings. 6 RESPONSE: 7 Based upon a reasonable and good faith effort to obtain information in order to 8 respond to this interrogatory, defendant states that it is unable to respond. Due to the 9 historical nature o f this interrogatory, neither the documents nor the individuals, upon 10 which/whom defendant would rely in order to respond, are still available. - U INTERROGATORY NO. 46: 12 Either (1) attach all DOCUMENTS evidencing the Information upon which YOUR 13 contentions in YOUR answers to Interrogatories No. 44 and 45 are based, o r (2) attach disks 14 containing such data, o r (3) describe such DOCUMENTS w ith sufficient particularity that 15 they may be m ade the subject o f a request for production o f documents. 16 RESPONSE: 17 No documents were identified. Therefore, this interrogatory is not applicable. 18 &QGATQR3LNQ.-4Z: 19 W hen did THIS DEFENDANT first warn its employees that exposure to asbestos 20 could be hazardous to human health? State: . 21 A . W hether the first such warning was w ritten o r oral; 22 B. W hether copies o f DOCUMENTS containing such warning exist; 23 . C . The IDENTITY of foe custodian o f such DOCUMENTS; 24 D . The content o f foe warning. . 25 RESPONSE: 26 Upon a reasonable and good faith effort to obtain information in order to respond to 27 this interrogatory, defendant states that it is unable to folly respond as to the "first instance" 28 as any documents which may be responsive td fois request no longer exist. DOGOZAAMttJI&fnSS 32 1 Based upon information currently available, defendant responds as follows: 2 A. Unknown. 3 B. No. 4 C. Not applicable. 5 D. Defendant is unable to respond to this interrogatory. As set forth above, any 6 documents which may be responsive to this request no longer exist. 7 ROGATORY NO. 48: 8 Did IM S DEFENDANT ever issue a w ritten COMPANY policy discontinuing. 9 warning its employees that exposure to asbestos could be hazardous to human health? I f so: 10 A. Provide the date; 11 B. Describe the circumstances; and 12 C. Either (1) attach all DOCUMENTS evidencing die information sought in this 13 interrogatory and its subpans to your answers to these Interrogatories, o r (2) attach disks 14 containing such data, o r (3) describe such DOCUMENTS with sufficient particularity that 15 they may be made die subject o f a request for production o f documents. 16 RESPONSE: 17 Based upon a diligent search and reasonable inquiry in an effort to respond to this 18 | interrogatory, defendant states that it never issued such a "written company policy." t i l l KRQGATORY NO. 49: 19 20 I Did THIS DEFENDANT provide any Independent Contractor o r Subcontractor w ithin 21 | the GEOGRAPHIC AREA with a w ritten warning that exposure to asbestos could be 22 hazardous to human health. 23 RESPONSE: 24 After a diligent search, defendant has not located any records o f providing such 25 warning within the Geographic Area for the subject time period. 26 INTERROGATORY NO. 50; 27 Has THIS DEFENDANT been cited fo r o r otherwise charged by a public agency with 28 a violation in the GEOGRAPHIC AREA o f any statute, ordinance, safety order, regulation, DOCttA36SljOfc936 33 o r law fteittfciitg to asbestos exposure? For each occasion, IDENTIFY: A. The code section, safety order, statute, or regulation for which THIS DEFENDANT had been cited or otherwise charged; B. The date(s) thereof; . C . The agency or other governmental unit which issued the citatum or otherwise charged YOU; D . A ll persons known to YOU with information relevant to the incident; E . W hat was the ultimate resolution. . BESPQNSE: No. SRQQATQRY NO, I f THIS DEFENDANT has ever owned o r operated a railroad, state: A . The IDENTITY o f cadi such railroad, including die name(s) o f such railroad during the time period o f YOUR ownership and/or operation, the principal place o f business o f such railroad and the dates o f YOUR ownership and/or operation; B . The geographic area o f operation o f such railroad; C . The namc{s) o f such railroad prior to YOUR ownership and/or operation; . D . The IDENTITY o f the person o r entity from whom YOU purchased your ownership o r operating interest,, and the date o f such purchase; E. The IDENTITY o f the person o r entity to whom YOU sold your ownership or operating interest, and the date o f such sale; F . W hether copies o f DOCUMENT evidencing your ownership/operation and/or sale exist; . G . The IDENTITY o f the Custodian o f such DOCUMENTS; H . To the extent that information has not been given in answers to Interrogatory N os. 32 and 33, the inform ation requested in Interrogatory N os. 32 and 33, for each | railroad owned or operated by YOU. D CO BA K S14fc9nS 34 1 SSSE: 2 N ot applicable. 3 IMlERBQQA.TQRY.N0t.g2: 4 I f DEFENDANT has ever owned or operated a shipyard, state: 5 A . The IDENTITY o f each such shipyard, including the name(s) o f such shipyard 6 during the tim e period o f YOUR ownership and/or operation, the place o f business o f such 7 shipyard and the dates o f YOUR owners.hip and/or operation; 8 B. .T he name{s) o f such shipyard prior to YOUR ownership and/or operation; 9 C . The IDENTITY o f the person o r entity to whom YOU sold your ownership o r 10 operating interest, and the date o f such sale; il D . W hether copies o f DOCUMENTS evidencing your ownership/operation and/or 12 sale exist; 13 E. W hether any representative o f THIS DEFENDANT attended the M aritime 14 Commission Conference in December 1942 in Chicago, Illinois? I f so, IDENTIFY any such 15 representative o f THIS DEFENDANT. 16 F. The IDENTITY o f the Custodian o f such DOCUMENTS. 17 G. To the extent that information has not been given in answers to Interrogatory 18 N o. 32, the inform ation requested in Interrogatory No. 32, for each shipyard owned or 19 operated by YOU 20 RESPONSE: 21 N ot applicable. 22 INTERROGATORY NO. 53: 23 A t any tim e between 1930 and 1985, did you im port, export, ship, transship or 24 otherwise transport RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS into, out 25 o f o r through any port in the GEOGRAPHIC AREA? I f so, for each occasion: 26 A. IDENTIFY and describe the NATURE and amount o f RAW ASBESTOS 27 and/or ASBESTOS-CONTAINING PRODUCTS; 28 B. IDENTIFY the ship o f ships (including the owners and operators thereof) onto OOCOSAAMSlXlkmM 35 1 o r ffinafcfcJdi the RAW ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS were I 2 loaded, unloaded; o r transshipped; 3 C. State the dates, port and pier involved for each occasion; 4 D. . Either (1) attach all DOCUMENTS evidencing the Information sought in this 5 Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks 6 containing such data, or (3) describe such DOCUMENTS with sufficient particularity that 7 they may be made the subject o f a request for production o f documents. 8 RESPONSE: 9 No. 10 DATED: December [!g, 1997 11 12 M ark S. Geraghty 13 M im iM . Lee Attorneys for Defendant, 14 AMERICAN CYANAMID COMPANY 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I Of DCOIBASD65!.flD.-9nS6 36 ^ ^ TO INTERROGATORY NO. 10(b) THROUGH if) Product M arket In tro . M l 34B-18 Paste Adhesive FM34B-18 Adhesive Film / FM 37 Adhesive FOam FM 39 Adhesive Foam In or about 1964 In or about 1964 In or about 1965 In or about 19__ FM 40 Adhesive Foam In or about 1966 FM 41 Adhesive Foam In or about 1969 FM 43 Extendable Paste/Foam In or about 1972 BR 92 Paste Adhesive (MU Spec. MMMA132) In or about 1976 D ate Discon tinued hi or about 1994 In or about 1994 Active In. or about 1988 Active Active Active In or about 1994 C hem ical D escription Physical D escription Poiyamic- Olive drab colored ester solution paste Poiyamicester solution Olive colored film, approx. 0.015 in thick Epoxy % Ep*y Light brown sheet 0.25 to 0.05 in. thtrir Light gray beet. 0.05 to 0.1 in. thick, between release pqper Epoxy Light brown sheet 0.25 to 0.05 in. thick, between release paper . Epoxy Light gray sheet, 0.05 to 0.1 in. thick, between idease paper Epoxy Silver-gray paste Epoxy Light green paste Use/Service Tem perature Priming o f metal substrates; -67 to 550F Bonding o f aluminum and titanium; -67 to 550*F Bonding or filling o f . aluminum honeycomb. core; -67 to 350*F Bonding o r filling of lhnwliwm tiivfiiyftrtffifr cote; -67 to 350*F Spiking o f aluminum honeycomb cote; -67 to 350*F Splicing o f aluminum honeycomb core; -67 to 35 0 'F Edge filling and splicing o f aluminum honeycomb core; -67 to 250*F General purpose paste adhesive for metal or composites; -67 to 300F i *X X 0lA i*J45^ft320W 1 V ^ h J o ^ b -fi 1 Product FM 150-2 Adhesive Film/BD150-2F FM 350 Adhesive Film FM 400 Adhesive Film FM 404 Adhesive Foam Aluminum . Honeycomb core with Asbestoscontaining core splice AS401 A & B M arket In tro . In or about 1969 In or about 1982 In or about 1969 ha or about 1971 In or about 1986 * In or ' about 1970 D ate Discon tinued Active Chemical D escription Epoxy In or about 1989 . Epoxy Active Epoxy In or . about 1989 Epoxy In or about 1991 D ior about 1978 Chromium treated fnmttmm foil bonded w ith a mod. epoxy into a ceOular matrix adhesive Epoxy Physical D escription Off-white film, 0.009 in thick, between release paper and polyethylene film Gray film , 0.008 to 0.012 in thick with nylon carrier and sandwiched between release paper and polyethylene Gray film , 0.008 to 0.012 in thick with nylon carrier and sandwiched between release paper and polyethylene Light gray sheet, 0.05 to 0.1 in. thick, between release paper Metallic honeycomb Brownish red paste Use/Service Tem perature Adhesive bonding o f aluminum substrates 1 Adhesive bonding o f flhimimmi and/or . composite substrates i * Adhesive bonding of aluminum or titanium substrates Splicing o f aluminum honeycomb core Structural component of aircraft Unavailable 'X ctB A anttO feaoM 2 I Product BD 5200 BD 8000 BR34 FM 166 7 H 175 FM 33 f FM 34 SU nU R SO M M arket Io tro . ln or tbout 1969 In or tbout 1970 lo o r tbout 1965 Unknown a ttb is tme. Unknown t t this tme. Inor tbout 1971 lo o r tbout 1965 D ate Discon tinued Inactive Date unknown t t this tme. D ior tbout 1978 Inor about 1978 InactiveDate unknown at tiia tm e. InactiveD ate unknown t t tilia, tim e. InactiveDate unknown at tilia tim e. In o r about 1978 C hem ical D escription Unavailable Adhesive Adhesive Unavailable Unavailable Sw Polyimize adhesive Physical D escription Unavailable Non-tacky solid Olive Drab Unavailable Unavailable Light grey unsupported sheet form - protected by eatOy ttripible release paper sizes ranging between 0.6nxm-6'35mm Olive drab on a 112 glass cloth U se/S errice Tem perature Unavailable Unavailable Unavailable ' Unavailable Unavailable Splicing bonding o f aluminum or noil- metallic honeycomb Bonding metal-to-metal and sandwich composite structures requiring long time exposures up to 600*F (315*C) and short time exposures to 800"F (425*0 3 | Produci FM 400-6 Adhesive Film FM 401 FM 405 FM 42 Foam FM 44 HT430 M arket In tro . In or about 1979 in or about 1909 hr about 1978 hr about 1972 hm about 1973 hr about 1963 D ate Discolitinned hor about 1971 Inactive Date unknown at this time. hor about 1971 hor about 1987 hor about 1989 hor about 1964 C hem ical D escription Epoxy Adhsive film Adhesive film Unavailable Unavailable Epoay phenolic Physical D escription Gny-moderately . tacky unsupported film Tacky film U se/S ervice Tem perature ______________ j Engine sound abatement work Unavailable Grey Film Unavailable Unavailable Unavailable As a stmetura] . thermosetting adhesive foam for splicing , honeycomb core Unavailable Unavailable Load bearing for sandwich "'xafcO M iafcaO M 4 V E R IFIC A T IO N STATE OF NEW JERSEY COUNTY OF morris ) ) ss. ) I am an Assistant Secretary o f American Cyanamid Company and am authorized to make this verification fo ra n d on its behalf and I make this verification for that reason. The foregoing DEFENDANT A M ERICAN CYANAMID COM PANY'S RESPO NSE TO STANDARD INTERROGATORIES T O A LL DEFENDANTS was compiled by authorized representatives and counsel for American CyanamidCompany upon whom I have relied entirely for their completeness, truth and accuracy. On that ground I am informed and believe that the m atters stated herein are true. I declare under penalty o fperjury under the laws o f the State o f California that the foregoing is true and correct Executed on the ay o f December, 1997 at M adison, New Jersey. STATE O F CALIFORNIA 3 COUNTY O F SAN FRANCISCO 4 ) ) ss.: ) 5 I am em ployed in die County o f Los Angeles, State o f C alifornia. I am over the age o f 18 and not a party to the w ithin acdon; my business address is 120 Broadway, 6 Suite 300, Santa M onica, California 90407-2122. 7 O n Decem ber 1 6 ,1 9 9 7 ,1 served on interested parties in said action the within: 8 DEFENDANT AMERICAN CYANAMID COM PANY'S RESPONSE TO STANDARD INTERROGATORIES TO ALL DEFENDANTS 9 10 by placing a true copy thereof enclosed in sealed envelope(s) addressed as follows: 11 12 . 13 Francine S. C urtis, Esq. Brayton H arley Curtis 222 Rush Landing Road P.O . Box 2109 Novato, CA 94948 14 15 and depositing such enve!ope(s) in this firm 's pick-up box for collection and m ailing by placing them in a postal box in my work area. 16 I am "readily familiar* w ith this firm 's practice o f collection and processing 17 correspondence, pleadings and other documents for mailing. Under that practice such papers are deposited in die U .S. postal sendee on that same day I place diem in the postal box in my 18 w ork area in the ordinary course o f business. I am aware mat on m otion o f party served, service is presum ed invalid if the postal cancellation date o r postage m eter date is more than 1 19 day after the stated date o f deposit for mailing set forth in an affidavit for proof o f service. 20 I declare under penalty o f perjury under the laws o f the State o f California that the above is true and correct. 21 Executed on the 16th day o f December, 1997, at Santa M onica, California. 22 23 24 Teri French 25 I 26 I 27 28 u w im c ito s ! tHCKCtOAKWCnAuMoWWI 1 MMAMMK* I .2 3 . 4 5 AAMttoErnReIyCsAfoNr CDYefAenNdAanMt,ID COMPANY 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 10 11 CASE NO. 967546 12 IN RE: COMPLEX ASBESTOS 13 LITIGATION 14 DEFENDANT AMERICAN CYANAMID COMPANY'S FURTHER RESPONSE TO CERTAIN STANDARD INTERROGATORIES TO ALL DEFENDANTS 15 16 American Cyanamid Company ("Cyuuumd") hereby ftirther responds to certain Standard 17 Interrogatories to all Defendants pursuant to San Francisco Revised General Order No. 129. 18 PRELIMINARY STATEMENT 19 After a reasonable search and diligent inquiry, defendant has made a good faith effort to 20 respond to these interrogatories based on information presently available. Defondant reserves the 21 right to amend'these interrogatory answers at any time additional information may become 22 available in the future. 23 FURTHER RESPONSE TO INTERROGATORY NO. 1.: 24 Timothy T. Slater, Esq., American Home Products Corporation, Five Giralda Farm, 25 Madison, New Jersey 07940. 26 FURTHER RESPONSE TO INTERROGATORY NO. 9: 27 Timothy T. Slater, Esq., American Home Products Corporation, liv e Giralda Farm, Madison, New Jersey 07940. 28 DOCSLLA /IOtm i -1-  2 A. Robert Stevens, Cytec Engineered M aterials, Inc., 1300 Revolution Street, Havre 3 de Grace, Maryland 20178 . 4 B. Robert Stevens, Cytec Engineered M aterials, Inc., 1300 Revolution Street, Havre 5 de Grace, Maryland 20178 6 FURTHER RESPONSE TO INTERROGATORY NO. 11: 7 Richard J. Leswing, former Medical Director, Nine Village Road, Southington, 8 Connecticut 06489; . 9 Desmond B. Pearce, former Safety Manager, 106 Hickory Circle, Hampstead, North 10 Carolina 28443; 11 Joseph C. Caporossi, Director o f Safety, H ealth and Product Regulatory Compliance, Five 12 Garret Mountain Plaza, West Paterson, New Jersey 07424; 13 Willard R. Kam, form er physician, 12411 C arlton Oaks. Timbali, Texas 77375; . 14 Michael Utidjian, former Medical Director, Seven Butternut Drive, Wayne, New Jersey 15 07470; 16 Nick Yin, former Industrial Hygienist, Four Bryce Way, Morris Plains, New Jersey 17 07950; 18 Lisa Westenberger-Page, former Industrial Hygienist, 315 Kensington Drive, Ridgewood, 19 New Jersey. .20 FURTHER RESPONSE TO INTERROGATORY N 0 O 3 : 21 Based upon a diligent search and reasonable inquiry, defondants responds as follows: 22 None. ~ 23 FURTHER RESPONSE TO INTERROGATORY NO. 18: 24 A. Bound Brook, New Jersey --1916 25 A. Pearl River, New York -- 1930 26 A. Stamford, Connecticut --1936 27 A. New York, New YOric - 1937 . 28 '-n u tib * W T L L P M M M n/w iA * A. Princeton, New Jersey - 1947 d o c s L A /io sm i - 2- A. Wayne, N ew Jersey -- 1951 A. Milton, Florid - 1958; Based on a diligent search and reasonable inquiry, the 3 identity o f any librarian(s) is unkflotfh. 4 FURTHER RESPONSE TO INTERROGATORY NO. 30: 5 A. 1963.1985. 6 B. No. 7 C. 1963-1985 8 D. 1963-1985 9 E. 1963-1985 10 F 1963-1985 11 G. 1963-1985 12. a No. 13 FURTHER RESPONSE TO INTERROGATORY NO. 31: . 14 Please see Exhibit "A" attached hereto. 15 16 DATED: October 8,1998 17 18 19 20 21 22 23 24 25 26 27 28 IM M U D * OOCS LA/IOSmi j nAi ittor* 3 - PERCENTAGES o fA SB E STO S FT9FM ______ f a R tA sbertos L itigation A S B eS fQ S -C O fifA iN D fC ' * .m t P& tC EN TAG M C & kttM & tO S i. ' BR-34B-1 Paste Adhesive 3.0% FM -34B-! t Adhesive Film 4.1% FM -37 Adhesive Foam FM -39 Adhetiv Foam 1.60% 1.9% FM -40 Adhesive Foam. 8.93'. FM-41 Adhesive Foam 2.5% FM -43 Exvudabte Faste/Fovn B R-92 Paste Adhesive 1.95% 4.1% PM*1502 Adhesive FUm (B D -150-2F) <2.0% FM -350A dhesive Fihn 1.0% FM -400 Adhesive Film <1.0% FM -404 Adhesive Poem A lum inum Honeycomb Core * if sbestos'cootaudni ooie s p ik e 1.5% 0.1% -to-2.27% AS-401 A4tB 1.0% B D -3200 0.9% B D -8000 <10.0% BR-34 3.0% . FM -I66 0.7% FX M -175 FM -33 4.9% 4.61% FM -401 FM -403_____________ FM -42 Foam _________ FM44 ___________ HT-430 T y p e! (P u t B) HT-430 Type I (P u t A) HT-430 M ixed HT-430 TypeU (06/29#8)fljb <3.0% 3.0% 2.0% 2.9% 261% 0.7% 1% 14.7% t V K K trzcm tH STATE OF NEM JERSEY COUNTY OF MORRIS >**. X, T im o th y T . S l u t e r , am A s s i s t a n t S e c r e ta r y o f A m erican Cyanam id Company, a p a r t y t o t h i s a c tio n , and am a u th o r iz e d t o make t h i s v e r i f i c a t i o n f o r an d on i t s b e h a l f , a n d I make t h i s v e r i f i c a t i o n f o r t h a t r e a s o n , DEFENDANT AMERICAN CYAMAMXD COMPANY'S FURTHER RESPONSE TO CERTAIN STANDARD INTERROGATORIES TO ALL DEFENDANTS i n t h e m a tte r e n t i t l e d A s b e s t o s D e fe n d a n ts (BBT) h a v e b e e n p r e p a r e d b y o t h e r s upon whom X h a v e r e l i e d e n tir e ly fo r th e ir tru th fu ln e ss, accu racy and eeep laten ass. Tbaaa response* a re lim ite d by th e records and inform ation s t i l l in ex isten cs, p re se n tly re c o lle c te d and th u s f a r discovered in th e course o f the p rep aratio n o f those responses. `A m e ric a n Cyanam id Ccopany r e s e r v e s t h e r i g h t t o ch a n g e o r su p p le m e n t s a i d re sp o n ses, o r to apply fo r r e lie f to p e rm it in se rtio n o f u n in te n tio n a lly om itted m atter. X d e c l a r e u n d e r p e n a l t y o f p e r j u r y u n d e r t h e law s o f t h e S t a t e o f New J e r s e y t h a t t h e f o r e g o in g l a t r u e ai>d c o r r e c t . ' - E x e c u te d o n t h e k i ^ a y o f S e p te s f e e r , 1996, a t M adison, New J e r s e y . Sw orn t o and su b sc rib e d b e fo re me - N o ta r y N U T & , Now J e r s e y MAUREENA. STEARN ___ NOTARYPUBLICOF NSWJERSEY My c o m m issio n e x p i r e s : tayrm erttilon Expose Nov. . 1996