Document L6XX6Nbqgx28x0v8b2VXwpR5

J. CARLISLE DEHAY. JR. 11922 - 1991) GARY D. ELLISTON OAVIO W. CROWE , MEL D. BAILEY ERIC D. WEWERS CHRISTOPHER P. MANNING PAUL E. HAMILTON KATHRYN HERMES W. SCOTT BERRY LAURA E. KUGLER TODD J. SUDDLESON MELINDA S. HUFF BRENT M. KARREN WRITER'S DIRECT DIAL (214) 210-2409 DeHay & Elliston, L.L.P. ATTORNEYS AND COUNSELORS 3500 BANK OF AMERICA PLAZA 901 MAIN STREET DALLAS, TEXAS 75202-3736 (214) 210-2400 * FACSIMILE (214) 210-2500 215 ORLEANS ST. BEAUMONT. TEXAS 77701 1409} 833-0900 FACSIMILE 1409) 833-0964 June 29, 2000 -J* ELIZABETH P. ARDANOWSKI . JOHN W. ARNOLD BRIAN P. CHING RUSSELL J. DePALMA CHRIST! J. DICKSON CHARLENE R. ECHOLS WILLIAM A. FYNES S. SHAYNE GARDNER TROY D. HELLING TANDY V. JOURET MELISSA M. LEON JEFFREY M. MAROSZ MISTI D. MOSTELLER TODD D. OGDEN BLAIR M. PARTLOW TODD H. RAMSEY WrfTRACY RICHARDSON, III TINA M. STAMPS ^PLAINTIFF'S i EXHIBIT ST. **. r - ` V-C- GP-311 v v Mr. Ben DuBose Baron & Budd 3102 Oak Lawn Avenue Suite 1100 Dallas, Texas 75219-4281 Re: Georgia Pacific Interrogatories Dear Ben: Pursuant to your recent request, please allow the following to serve as supplementation to Georgia Pacific's Response to Interrogatory Number 21 in the Dallas In Re Interrogatories: 21. Identify by name and location each plant or manufacturing facility in which the products listed in your answers to Interrogatories Nos. 3-6 were manufactured, assembled, or prepared for sale or marketing, specifying which plants produced each item, the dates each plant is or was in operation, and the time span during which each named item was produced or manufactured. ANSWER: The plant in Acme, Texas has been operated by Bestwall Gypsum Company or Georgia-Pacific from 1956 through the present. At various times, and intermittently during the time frames indicated in this response, the plant manufactured Ready Mix (66-p), Joint Compound (56-77), Bedding Compound (57-p), Topping Compound (59 p). All Purpose Joint Compound (56-p), Triple Duty Joint Compound (65-p), Speed Set/One Day (63-p), Central Mix (70-73), Texture (59-p), Patching Plaster (62-75), Spackling Compound (66-71), Lite Acoustic (61-64), or Kalite (56-59), in addition to many products that did not contain asbestos at any time. The above referenced products ceased to contain asbestos at various times, though Georgia-Pacific introduced and continues to sell asbestos free formulations of many of these products. The Akron, New York plant has been operated by Bestwall Gypsum Company or Georgia-Pacific from 1956 through the present. At various times, and intermittently during the time frames indicated in this response, the plant manufactured Ready Mix Ready Mix (64-p), Joint Compound (64-77), Bedding Compound (63-p), Topping Compound (63-75), All Purpose Joint Compound (63-p), Triple Duty Joint Compound (unknown-p), Texture (63-p), Kalite (56-59), Lite Acoustic (59-62), Laminating Compound Ready Mix (69), or Drywall Adhesive (72), in addition to many products Mr. Ben DuBose June 29, 2000 Page 2 ` ' that did not contain asbestos at any time. The above referenced products ceased to contain asbestos at various times, though Georgia-Pacific introduced and continues to sell asbestos free formulations of many of these products. The Blue Rapids, Kansas plant has been operated by Bestwall Gypsum Company or Georgia-Pacific from 1956 through the present. At various times, and intermittently during the time frames indicated in this response, the plant manufactured Joint Compound (63-77), Patching Plaster (59-75), Speed Set/One Day (unknown-p), or Lite Acoustic (60-62), in addition to many products that did not contain asbestos at any time. The above referenced products ceased to contain asbestos at various times, though Georgia-Pacific introduced and continues to sell asbestos free formulations of many of these products. The Fort Dodge, Iowa plant has been operated by Bestwall Gypsum Company or Georgia-Pacific from 1956 through the present. At various times, and intermittently during the time frames indicated in this response, the plant manufactured Ready Mix (65; 81-p) or Lite Acoustic (59-62), in addition to many products that did not contain asbestos at any time. The above referenced products ceased to contain asbestos at various times, though Georgia-Pacific introduced and continues to sell asbestos free formulations of many of these products. The Grand Rapids, Michigan plant has been operated by Bestwall Gypsum Company or Georgia-Pacific from 1956 through the present. At various times, and intermittently during the time frames indicated in this response, the plant manufactured Lite Acoustic (58-62), in addition to many products that did not contain asbestos at any time. The Sigurd, Utah plant has been operated by Bestwall Gypsum Company or GeorgiaPacific from 1956 through the present. At various times, and intermittently during the time frames indicated in this response, the plant manufactured Lite Acoustic (59-62), in addition to many products that did not contain asbestos at any time. The Brunswick, Georgia plant has been operated by Bestwall Gypsum Company or Georgia-Pacific from 1959 through the present. At various times, and intermittently during the time frames indicated in this response, the plant manufactured Ready Mix (65), Patching Plaster (66-75), or Lite Acoustic (61-62), in addition to many products that did not contain asbestos at any time. The Chicago, Illinois plant was operated by Georgia-Pacific from 1967 through 1981. At various times, and intermittently during the time frames indicated in this response, the plant manufactured Ready Mix (67-81), Joint Compound (67-77), Bedding Compound (71-81), Topping Compound (67-76), All Purpose Joint Compound (67 81), Triple Duty Joint Compound (67-81), or Texture (67-81), in addition to many products that did not contain asbestos at any time. Each of the above referenced products ceased to contain asbestos at various times, though Georgia-Pacific introduced and continues to sell asbestos free formulations of many of these products. The Marietta, Georgia plant has been operated by Georgia-Pacific from 1969 through the present. At various times, and intermittently during the time frames indicated in Mr. Ben DuBose June 29, 2000 Page 3 1 this response, the plant manufactured Ready Mix (69-p), Joint Compound (69-77), Bedding Compound (69-p), Topping Compound (69-75), All Purpose Joint Compound (70-p), Triple Duty Joint Compound (69-p), Central Mix (71-73), or Texture (69-p), in addition to many products that did not contain asbestos at any time. The above referenced products ceased to contain-asbestos at various times, though Georgia-Pacific introduced and continues to sell asbestos free formulations of many of these products. The Milford, Virginia plant has been operated by Georgia-Pacific from 1973 through the present. At various times, and intermittently during the time frames indicated in this response, the plant manufactured Ready Mix (73-p), in addition to many products that did not contain asbestos at any time. Each ofthe above referenced products ceased to contain asbestos at various times, though Georgia-Pacific introduced and continues to sell asbestos free formulations of many of these products. Should you have any questions, please do not hesitate to contact me. LEK/kt cc: Sheryl Ortman F:\USERS\KKT\GP\CORRESVDUBOSE\DUBOSE.LET