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1 UcCUTCHEN, DOYLE, BROWN & ENERSEN
JOHN W. FOWLER 2 STUART C. WALKER
G01 California Street 3 San Francisco, California 94108
Telephone: (415) 981-3400
4 Attorneys for Defendant
GAF CORPORATION
5
6
7
8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
10 ESMAEL P. VELASQUEZ,
) ')
11 Plaintiff, ) )
12 v.
)
)
13 FIBREBOARD PAPER PRODUCTS CORPORATION, a corporation,
) )
14 et al.,
) ).
15 Defendants.) )
16 )
No. 681-172
RESPONSE OF DEFENDANT GAF CORPORATION TO PLAINTIFF'S FIRST SET OF INTERROGATORIES
17 Defendant GAF CORPORATION (GAF) responds to
18 plaintiff's First Set of Interrogatories as follows:
19 Interrogatory A. Please state the name and 80 official title or position in defendant corporation of 81 the person or persons answering these interrogatories 28 and signing the same.
`3 Response. Counsel for GAF prepared the answers
24 to these interrogatories. Jonathan Berger, Assistant
25 Secretary of GAF, verified the same.
26 ftECEl VD
OCT 16 1975
l.'itn, Rode, Cli/fon), |y |'e j [ fries
1 Interrogatory B. For the period of time running
2 from January 1, 1943 through January 31, 1974 (hereinafter
3 referred to as "the period in question"):
4 1. Did you manufacture any products which con
5 tained asbestos? If so,
6 a) Please identify by name and address
7 each of your facilities, located either in
8 California or elsewhere, which manufactured
9 such products for shipment to points in California.
10 b) Please state the period of time during
11 which each such facility was engaged in the manu 12 facture of such products.
13 c) Please given the name and present address
14 of each individual who was in charge at each such
15 facility during the period in question, and the ap
.16 proximate period of such service for each such in
17 dividual .
18 2. If you manufactured or supplied products con
19 taining any asbestos, for shipment to points in
20 California,
2] a) Were they distributed in California by
Oo L.Cj
you? If so, please identify each such distribu
tion point in California, including the name
24 under which it was operated, its address, and 25 the period during which it was operated. 26 b) Did you supply such products to others
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1 circumstances and considerations which 2 motivated you to use such warnings. 3 4) Please point out and describe 4 any changes you made in such warnings, the 5 dates of such changes and the reasons for 6 such changes. 7 5) Please state the names, present 8 addresses and title of all persons on whose 9 opinions you relied in determining to put 10 such warnings on your products or their 11 containers. 12 d) Did you distribute, publish or otherwise 13 disseminate any warnings of the possible health 14 hazards of asbestos or products containing 15 asbestos, other than by putting such a warning 16 on such products or their containers? If so, 17 1) Please state the precise wording 18 of such warning or warnings. 19 2) Please state the dates and 20 methods used to disseminate each such 21 warning. MOr, 3) Please state the name and address 23 of each person, corporation or entity to whom 24 such distribution, publication or dissemi 25 nation was made. 26
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1 Response. 2 1. Y e s . 3 a) No GAF plant' manufactured industrial 4 insulation products containing asbestos specifically for ship 5 ment to or within California.
6 b) Not applicable.
7 c) Not applicable.
8 2. a) GAF did not distribute, as that term is
9 commonly used, industrial insulation products containing
10 asbestos in California. 11 b) GAF did not have control over others who 12 may have shipped or sold GAF industrial insulation products
13 containing asbestos to or in California. 14 3. a) Subject to its answer toInterrogatory15 B.l.a., GAF states that it manufactured the following in 16 dustrial insulation products containing asbestos. 17 (i) Calsilite - high temperature pipe cover
10 ing and block. The product contained 10% asbestos and the
19 balance consisted of diatamaceous earth and hydrous'lime
20 silicate.
21 (ii) 7M Cement.- this product was composed if
I
O almost entirely of asbestos fibers. (iii) T/NAlOO - Tcdlur nooprine asbestos
24 insulating jacketing. This1-product contained 40% asbestos 25 and the remainder consisted of Tedlar (poly vinyl flouride and 26
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1 neoprene).
2 (iv) Asbestos paper and millboard. The asbestos
3 content of these products varied from time to time.
4 b) (i) Amosite
5 (ii), (iii) and (iv) Crysotile
6 c) Yes
7
(1), (2)
In approximately 1965 defendant GAF began
8 placing warning notices on the packaging of its industrial
9 products which contained asbestos. Such notices employed
10 the following language:
11 "CAUTION"
12 "CONTAINS ASBESTOS FIBER. INHALATION IN
EXCESSIVE QUANTITIES OVER LONG PERIODS OF 13 TIME MAY BE HARMFUL. AVOID BREATHING DUST.
14 IF ADEQUATE VENTILATION IS NOT POSSIBLE, WEAR RESPIRATORS APPROVED BY THE U.S.
15 BUREAU OF MINES.FOR PNEUMOCONIOSIS PRO DUCING DUST."
.16
17 "CAUTION. This product contains asbestos
10 fiber. Inhalation of asbestos in excessive quantities over long periods of time may be
19 harmful. If dust is created when this pro duct is handled, avoid breathing the dust.
20 If adequate ventilation control is not pos
sible, wear respirators approved by the U.S. 81 Bureau of Mines for pneumoconiosis producing
dust." O `1
(3), (5) In using these warnings, GAF was following
83 other manufacturers in the industry, who used sucli cautionary
24 notices after some opinions were expressed by members of the
25 medical profession that there might be a health risk to some
26 persons who installed industrial insulation products contain-
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1 asbestos from the inhalation of excessive quantities of
2 asbestos fibers over prolonged periods of t. i me under certain
3 conditions.
4 (4) Commencing in 1972, pursuant to the re
5 quirements of the Occupational Safety and Health Act of
6 1970, defendant GAF placed a notice employing the follow
7 ing warning on the packaging of its industrial insulation
8 products containing asbestos which were required to be labeled
9 pursuant to such Act:
10 "CAUTION"
11 "CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
12 BREATHING ASBESTOS DUST MAY CAUSE
SERIOUS BODILY HARM" 13
d) No. 14
Interrogatory C. Do you. presently manufacture or 15
supply products which contain any asbestos for shipment to 16
points in California? If so, 17
1. Please identify each such product by
10
stating its trade name and by describing it and 19
its contents with particularity.
20
2. Please indicate whether each such 21
product contains either amosite or chrysotile
22
asbestos, or both.
j <t
3. Do you put on such products or their 24
containers any warning of their hazards to health 25
by virtue of the asbestos content of such 26
products? If so.
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1 a) Please describe each such warn
2 ing with particularity, with regard to size,
3 nature and content. If possible, please en 4 close a photograph thereof. 5 b) Please state when you began using
6 such warnings.
7 c) Please state all of the facts, cir
8 cumstances and considerations which motivated
9 you to use such warnings.
10 d) Please point out and describe any 11 changes you have made in such warnings, the 12 dates of such changes, and the reasons therefor.
13 e) Please state the names, present ad 14 dresses and titles of all persons on whose 15 opinions you relied in determining to put such 16 warnings on your products or their containers. 17 Response. GAF does not presently manufacture or 18 supply any industrial insulation products containing asbestos. 19 Interrogatory D. Have you ever "recalled" or sought
20 the return to you of any of your asbestos-containing products
21 from those to whom such products were supplied? If so, O > 1. Please state the dates of each such recall.
'/ 2. rleasc state the trade names of the products 24 which were recalled. 25 3. Please state the facts, circumstances and 26 considerations for each such recall.
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1 Response. No. p Interrogatory E. Have you ever discontinued the
3 production of any asbestos-containing product which you
4 had previously manufactured? If so,
5 1. Please state the trade names of the products
6 discontinued.
7 2. Please state the dates on which said production
8 was discontinued.
9 3. Please state all of the facts, circumstances
10 and considerations for such discontinuances.
11 Response. All products listed in GAF1s answer to
12 Interrogatory B.3.a have been discontinued. Manufacture
13 of such products was discontinued because they were not 14 profitable.
15 //
16 //
17 //
10 //
19 //
20 //
21 //
>o . . t,
> i' /
, ..
// //
24 //
25 //
26 //
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1 Interrogatory F. Have you received any complaints
2 of hazard or potential injury to human beings from the use or
3 exposure to your products containing asbestos from any: 4 a) Person 5 1. If so, please state the name and
6 address and phone number of said person making
7 said complaint.
8 2. Please state if said complaint was
9 reduced to writing.
10 3. If the complaint was in writing, please 11 state if you will voluntarily attach a copy of 12 the same to these interrogatories.
13 b) Corporation 14 1. If so, please state the name and 15 address and phone number of said person making 16 said complaint. 17 2. Please state if said complaint was 18 reduced to writing. 19 3. If the complaint was in writing, please
20 state if you will voluntarily attach a copy of
21 the same to these interrogatories. c) Partnership or other entity 1. if so, please state the name and
24 address and phone number of said person making 25 said complaint. 26 2. Please state if said complaint was
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1 reduced to writing.
2 3. If the complaint was in writing, please
3 state if you will voluntarily attach a copy of
4 the same to these interrogatories,
5 d) Governmental body, either federal, state or
6 local.
'
7 1. If so, please state the name and address
8 and phone number of said person making said complaint.
9 2. Please state if said complaint was re
10 duced to writing.
11 3. If the complaint was in writing, please
12 state if you will voluntarily attach a copy of the
13 same to these interrogatories.
14 Response. GAF has had knowledge of deaths or lung
15 diseases among its employees which have been attributed to 16 the inhalation of asbestos dust or fibers over long periods 17 of time under certain environmental conditions that existed 18 prior to GAF's acquisition <f facilities utilizing asbestos.
19 To the best of GAF1s knowledge, claims related to these deaths
20 or diseases, which arose in ,the states of Vermont, Missouri
21 and New Jersey, were all filed with appropriate workmen's com
iO * 1
..y .
pensation agencies, which tiles are a matter of public record
23 and equally available to plaintiff and GAF. Such files would
24 normally contain the information requested by this interrogatory.
25 GAF has been or is a defendant in the lawsuits listed
26 in Exhibit A attached hereto which allege damages as a result
i
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i
1 of injury to plaintiff's or plaintiff's decedent's pulmonary
2 system. The court files in these cases are a matter of public
3 record and are equally available to plaintiff and GAF. Such
4 files would normally contain the information requested by this
5 interrogatory.
6
b) , c)
No.
7 d) The following GAF plants have received medi
8 cal citations pursuant to the Occupational Safety and Health
9 Act of 1970, 29 C.F.R. 1910.93a(j), for failure to provide
10 medical examinations for employees exposed to asbestos:
11 1) St. Louis, Missouri
12 2) VJhitehall, Pennsylvania
13 3) Kansas City, Missouri
14 The files relating to these citations are a matter of public
15 record and are equally available to plaintiff and GAF. Such
16 files would normally contain the information requested by this
17 interrogatory.
18 Interrogatory' G. Have you distributed within house
19 or to any of your distributors any reports from doctors,
20 members of the healing arts or physical or biological
21 scientists concerning hazards or dangers to humans by
22 virtue of exposure to asbestos materials?
23 1. If so, please state the date and general
24 content of each such report. 25 2. The present custodians thereof.
26 3. The author of said report.
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1 4. The name, address, phone number and job 2 title of the custodian of said report and of 3 the author of said report. 4 5. To whom said report or reports were 5 distributed. 6 6. If you will do so without a motion to 7 produce, please attach a copy of each said 8 report to your answers to these interrogatories. 9 Response. Ho such reports have been submitted to
10 GAF from doctors, members of the healing arts or physical 11 or biological scientists. GAF has obtained reports pro 12 vided by consulting physicians in particular lawsuits in
13 volving GAF, which reports are protected by the attorney14 client privilege and the work-product privilege. 15 Interrogatory H. What efforts have been made by 16 you to reduce the danger or hazard from the materials 17 manufactured by you which contain asbestos? 18 1. Please state in detail all materials which you 19 have substituted for asbestos, if this is the method which
20 you have followed. 2] 2. If the product has simply been modified, please
n o state all ingredients that have either been removed or the 23 names of all ingredients which have been added by way of sub 24 stitution. 25 Response. Not applicable. GAF does not presently 26 manufacture industrial insulation products containing asbestos
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1 fibers. 2 Interrogatory 1. Did any of your directors, 3 officers, employees, agents, attorneys or paid consultants 4 appear and/or testify as witnesses in a lawsuit captioned 5 United States of America vs. Reserve Mining Company, et al.
6 found in 5-72 Civil 19 in the U.S. District Court for the
7 District of Minnesota and reported in 380 F. Supp. 11 (1974)?
8 1. If so, please state the following: 9 a) The name and present address of each 10 individual. 11 b) The capacity in which each such in
12 dividual appeared and testified in said proceed 13 ing . 14 c) Please describe with particularity the 15 subject matter of each such individual's testi 16 mony and if he testified as an expert, the basis 17 for his expertise. 18 Response. No. 19 Interrogatory J. Do you or your attorneys possess
20 copies of pleadings, exhibits and/or transcripts of testimony
2] from said lawsuit? If so, aro you willing to make said docu 22 ments available to plaintiff for copying at plaintiff's expense? 23 Response. lie . 24 Interrogatory K. Have you ever been named as a party 25 defendant in a lawsuit other than this one which alleged that 26 the plaintiff or a decedent had been harmed by asbestos con-
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1 taineu in your products?
2 1. Please state the caption and case number
3 of each lawsuit and the court in which each such 4 lawsuit was brought. 5 2. If any such lawsuit was tried in a court
6 other than the one in which it was brought, please
7 state the caption, case number and court in which
8 each such lav/suit was tried.
9 3. Was judgment rendered against you in any
10 such lawsuit? If so, please state, with regard to 11 each: 12 a) The amount of such judgment.
13 b) Whether such judgment was affirmed n 14 appeal. 15 c) Whether such judgment was reversed on 16 appeal. 1 7 4. Please state the caption and citation of 10 each reported decision in each such lawsuit. 19 Response. See Exhibit A attached hereto. The only
20 case in which judgment was' rendered was Borel v. Fibreboard et al.
21 Judgment in that case was affirmed on appeal.
22 Dated: October '/
23 24
25
1975
McCUTCHEN, DOYLE, BROWN & ENERSEN JOHN W. FOWLER STUART C. WALKER
26 By
1 STATE OF NEW YORK \
2 COUNTY OF NEW YORK
) : SS . : )
3
4
JONATHAN BERGER, being duly sworn according to 5
iaw, deposes and says that he is Assistant Secretary of 6
defendant GAF Corporation; that he is duly authorized to 7
make this affidavit on behalf of said corporation; and that
8
all of the statements set forth in the foregoing Response 9
to Plaintiff's First Set of Interrogatories are true and
10
correct to the best of his knowledge, information and belief.
11
12
13
14
15 Sworn to and subscribed 16 before me this 7rk
17 day of October, 1975.
Notary Public 20
My Commission Expires:
2-1 IMANK EAWRKVCE NOTAk* kuBUC. State ol New York
.... No. 41-4603279 - Qoalihed in Queenj County
Cerlikcote lilod in New York County ...Corn:iii>aion t.pirsj Merck 30, 1977.
24
25
26
1 Antholz vs. Fibreboard Paper Products, et al. United States District Court for District of Minnesota -
2 Fifth Division
Case No. 5-70 Civ. 105
3 Barrett vs. Johns-Manville Products Corporation, et al.
4 Circuit Court of Missouri, Sixteenth Judicial Circuit Case No. 784937
5 Bell vs. Fibreboard Paper Products Corp., et al.
6 United States District Court for Eastern District of Texas
Case No. B-74-CA-50
7 Bellot vs. Fibreboard Corp., e't al.
8 United States District Court for the Eastern District of
Texas - Beaumont Division
9 Case No. B-74-253-CA
10 Borel vs. Fibreboard Paper Products Corporation, et al.
United States District Court foj: the Eastern District of
11 Texas - Beaumont Division Case No. 6449
12
Breedlove vs. Combustion Engineering, Inc., et al.
13 United States District Court - Northern District of Ohio Eastern Division
14 Case No. C-74-1130
15 Broussard vs. Fibreboard Papers Products Corporation, et al. United States District Court for the Eastern District of
16 Texas - Beaumont Division Case,No. B-73-CA-300
17 Burke vs. Combustion Engineering, Inc., et al.
18 United States District Court for the Northern District of Ohio - Eastern Division
19 Case No. C73-239
20 Buscaino vs. Fibreboard Paper Products Corporation, et al.
Superior Court of the State of California in and for the City
21 and County of San Francisco
Case No. 687-191
/
22
Chaddock vs. Combustion Engineering, Inc., et al.
23 United States District Court for the Northern District of Ohio - Eastern Division
24 Case No. C-75-102
25 Crawford vs. Fibreboard Paper Products Corporation, et al. United States District Court for the Eastern District of
26 Texas - Beaumont Division Case No. 6492
1 Dunn vs. Johns-Manville International Corporation, et al. United States District Court for the Southern District of
2 Texas - Houston Division
Case No. 73-H-1072 3
Foster vs. Fibreboard Paper Products Corporation, et al. 4 United States District Court for the Eastern District of
Texas - Beaumont Division 5 Case No. B-74-204-CA
6 Frith vs. Johns-Manville International Corporation, et al.
United States District Court for the Western District of 7 Louisiana - Shreveport Division
Case No. 73-H-1072
8
Gibson vs. Johns-Manville Products Corporation, et al. 9 District Court in and for the County of Boulder, Colorado
Case No. 74-12-6-2
10
Gustafson vs. Fibreboard Paper Products Corporation, et al. 11 United States District Court for the Fifth Division - District
of Minnesota
12 Case No. 5-71-40
13 Hallinan vs. Combustion Engineering, Inc., et al. United States District Court for the Southern District of
14 Indiana - Evansville Division Case No. 75-25-C
15 Hamilton vs. Johns-Manville Products Corporation, et al.
16 In the Circuit Court of Jackson County, Missouri at Kansas City Case No. 784,986
17 Hartwell vs. Johns-Manville Products Corporation, et al.
18 United States District Court for the Eastern District of Texas - Beaumont Division
19 Case No. 7513
20 Jeane vs. Fibreboard Corporation, et al.
United States District Court for the Eastern District of
21 Texas - Beaumont Division
Case No. B-74-337-CA
22
Johnson vs. Fibreboard Paper Products Corporation, et al. 23 United States District Court for the Eastern District of
Texas - Beaumont Division 24 Case No. B-74-124-CA
25 Karjala vs. Fibreboard Paper Products Corporation, et al. United States District Court for the District of Minnesota -
26 Fifth Division Case No. 5-71-18
1 Kearns vs. Combustion Engineering, Inc., et al. United States District Court, for the Northern District of
2 Ohio - Eastern Division Case No. C73-70
3
La Grappe vs. Fibreboard Corporation, et al. 4 United States District Court for the Eastern District of
Texas - Beaumont Divison 5 Case No. B-74-66-CA
6 McDaniel vs. Johns-Manville Products Corporation, et al. United States District Court for the Eastern District of
7 Texas - Beaumont Division Case No. 6967
8
McGinnis vs. Combustion Engineering, Inc., et al. 9 United States District Court for the Northern District of
Ohio - Eastern Division 10 Case No. C-74-1077
11 McLaughlin vs. Combustion Engineering, Inc., et al. United States District Court for the Northern District of
12 Ohio - Eastern Division Case No. C-74-923
13' McNeeley vs. Combustion Engineering, Inc., et al.
14 United States District Court for the Northern District of Ohio - Eastern Division
15 Case No. C-74-74
16 Matthews vs. Fibreboard Paper Products Corporation, et al.
United States District Court for the Eastern District of 17 Texas - Beaumont Division
Case No. B-73-CA-309
18 Measor vs. Combustion Engineering, Inc., et al.
19 United States District Court for the Northern District of Ohio - Eastern Division
20 Case No. C73-238
21 Mitchell vs. United Asbestos Corporation, et al. State of Illinois - Circuit Court of the Third Judicial Circuit
22 Madison County Case No. 74-L-676
23 Moran vs. G. & W. H. Corson Inc., et al.
24 Court of Common Pleas of Delaware County, Pennsylvania Case No. 1699
25 Muntean vs. Combustion Engineering, Inc., et al.
26 United States District Court for the Northern District of Ohio - Eastern Division
Case No. C73-199
1 Potter vs. Fibreboard Paper Products Corporation, et al. United States District Court for the Eastern District of
2 Texas - Beaumont Division
Case No. 6329
3
Ricci vs. Combustion Engineering, Inc., et al.
4 United States District Court for the Northern District of
Ohio - Eastern Division S Case No. C72-507
6 Roderman vs. Combustion Engineering, Inc., et al.
United States District Court for the Northern District of
7 Ohio - Eastern Division
Case No. C72-390
8
Sedlock vs. Combustion Engineering, Inc., et al. 9 United States District Court for the Northern District of
Ohio - Eastern Division
10 Case No. C72-395
11 Spell vs. Fibreboard Corp., et al.
United States District Court for the Eastern District of
12 Texas - Beaumont Division
Case No. E-74-81-CA
13
Strickland vs. Johns-Manville International Corporation, et al.
14 United States District Court for the Southern Division of
Texas - Houston Division
15 Case No. 75-H-492
16 Velasquez vs. Fibreboard Paper Products Corporation, et al.
Superior Court of California, County of San Francisco
17 Case No. 681 172
18 Wimberly vs. Fibreboard Corporation, et al.
United States District Court for the Eastern District of
19 Texas - Beaumont Division
Case No. B-74-224-CA
20
Jacomino vs. Johns-Manville Corporation, et al.
21 Court of Common Pleas, Philadelphia County
Case No. 1507
22
Baumann vs. Fibreboard Paper Products Corporation, et al.
23 Superior Court of the State of California in and for the
City and County of San Francisco
24 Case No. 688-553
25 Steele vs. Combustion Engineering, Inc., et al.
United States District Court for the Northern District of
26 Ohio, Eastern Division
Case No. C-75-359
1 McLaughlin (Harry) vs. Combustion Engineering, Inc., et al. United States District Court for the Northern District or
2 Ohio, Eastern Division
3
Sandoval vs. Fibreboard Paper Products Corporation, et al.
4 Superior Court of' California, County of San Francisco
Case No. 689-959
5
Murphy vs. Combustion Engineering, Inc., et al. 6 United States District Court for the Northern District of
Ohio, Eastern Division
7 Case No. C-75 453
0 Harter vs. Combustion Engineering, Inc., et al.
United States District Court for the Northern District of
9 Ohio, Eastern Division
Case No. C-75 452
10
Farrar vs. Standard Asbestos Manufacturing & Insulating Co.,
11 et_al.
United States District Court for the Southern District of 12 Texas, Houston Division
Case No. 75-H-862
13
Kyburz, Jr. vs. Standard Asbestos Manufacturing and Insulating
14 Company, et al.
United States District Court for the Southern District of
15 Texas, Houston Division
Case No. 75-H-863
16
Dickey vs. Standard Asbestos Manufacturing and Insulating 17 Company, et al.
United States District Court for the Southern District of
18 Texas, Houston Division
Case No. 75-H-864
Wesberrv vs. Standard Asbestos Manufacturing and Insulating 20 Company, et al.
United States District Court for the Southern District of
21 Texas, Houston Division
Case No. 75-H-865
Byerly vs. Standard Asbestos Manufacturing and Insulating
23 Company, et al.
United States District Court for the Southern District of
24 Texas, Houston Division
Case No. 75-H-866
25
Viator vs. Standard Asbestos Manufacturing and Insulating 25 Company, et al.
United States District Court for the Southern District of Texas, Houston Division
Case No. 75-H-867
1 Gaspard vs. Standard Asbestos Manufacturing and Insulating Company, et al.
2 United States District Court for the Southern District of Texas, Houston Division
3 Case No. 75-H-868
4 Freeman vs. Standard Asbestos Manufacturing and Insulating Company, et al.
5 United States District Court for the Southern District of Texas, Houston Division
6 Case No. 75-H-369
7 Burke v. Standard Asbestos Manufacturing and Insulating Company, et al.
8 United States District Court for the Southern District of Texas, Houston Division
9 Case No. 75-H-870
10 Plitt vs. Standard Asbestos Manufacturing and Insulating Company, et al.
11 United States District Court for the Southern District of
Texas, Houston Division 12 Case No. 75-H-906
13 Trahan vs. Standard Asbestos Manufacturing and Insulating
Company, et al. 14 United States District Court for the Southern District of
Texas, Houston Division
15 Case No. 75-H-905
16 Curtin vs. Johns-Manville Products Corporation, et al. Circuit Court of the Third Judicial Circuit, Madison County-
17 Case No. 75-L-146
18 Luker vs. Johns-Manville International Corporation, et al. United States District Court for the Southern District of
19 Texas, Houston Division
Case No. 75-H-342
20
Palermo vs. Fibreboard Paper Products Corporation, et al. 21 United States District Court for the Eastern District of
Texas, Beaumont Division 22 Case No. B-75-192-CA
23 Dolce vs. Fibreboard Paper Products Corporation, et al. United States District Court for the Eastern District of
24 Texas, Beaumont Division Case No. B-75-191-CA
25 Nolan vs. Johns-Manville Asbestos & Magnesia Materials
26 Company, et al. Circuit Court of Cook County, Illinois Case No. 75 L 8672
1 Howard vs. Owens-Corning Fiberglass Corporation, et al. United States District Court for the Eastern District of
2 Texas, Sherman Division Case No. S-75-58-CA
3 Hutson vs. Arms iron'| Cork Company, o'- n.l .
4 United States District T.'ourt tor the Southern District of Florida, Miami Division
5 (fuse No. 7 5- L .h'5-Civ .-JLK
6 Daniels vs. GAF Corporation, et al. United States District Court for the Eastern Division of
7 Tennessee, Northern Division Case No. 3-75-188
8 Featherstone vs. Johns-Manville Sales Corporation, et a1.
9 United States District Court, Eastern District of TcxasT Marshall Division
10 Case No. M-74-44-CA
11 McKee vs. Johns-Kanville Corporation, et al.
Supreme Court of the State of New York, County of Erie
12 Index No.
.
13 Estepp vs. Combustion Engineering, et al.
State of Tennessee, Circuit Court of Knox County
14 Case No. 2-474-75
15 Nave vs. Combustion Engineering, Inc, et al. State of Tennessee, Circuit Court of Knox County,
16 Division III Case No. 3-491-75
17 Daniels vs. Combustion Engineering, Inc., et al.
IQ State of Tennessee, Circuit Court of Knox County, Division I
19 Case No. 1-492-75
20 Starnes vs. Combustion Engineering, Inc., et al.
United States District Court for the Eastern District
21 of Tennessee, Northeastern Division
Case No. 2-75-12
22
\
Holton vs. Standard Asbestos Manf. & Insulating Co., et al.
23 United States District Court for the Southern District of
Texas, Houston Division
24 Case No. 75-11-1635
25 Kirchner vs. Standard Asbestos Manf. & Insulating Co., et al. United States District Court for the Southern District of
26 Texas, Houston Division Case No. 75-11-1634
7.
4