Document LgBJG2e5RaeQvmKRwx1O06VJw

rC prr.FlVcO SEP 0 61389 1 MORGENSTEIN & JUBELIRER ELIOT S. JUBELIRER 2 KARLIN GOULD The Federal Reserve Bank Building 3 101 Market Street, Suite 601 San Francisco, California 94105 4 (415) 896-0666 5 Attorneys For Defendants FIBREBOARD CORPORATION, PITTSBURGH-CORNING 6 CORPORATION, OWENS-ILLINOIS, INC. 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF ALAMEDA 10 11 WILLIE COLEMAN, et al., 12 Plaintiffs, 13 v. 14 FIBREBOARD CORP., et al, 15 Defendants. 16 ) No. 650495-3 ) ) ) DEFENDANT, OWENS) ILLINOIS, INC.'S ANSWERS ) TO PLAINTIFF'S FIRST SET ) OF INTERROGATORIES ) ) ) 17 PROPOUNDING PARTY 18 Plaintiffs, WILLIE COLEMAN, et al. , 19 RESPONDING PARTY: Defendant, OWENS-ILLINOIS, INC. 20 SET NUMBER: One (1) - 21 REFERENCE: WILLIE COLEMAN v. OWENS-ILLINOIS, INC., et al. 22 23 OWENS-ILLINOIS, INC. by and through its counsel of 24 record hereby responds in writing under oath to plaintiff's 25 interrogatories. 26 - PRELIMINARY STATEMENT AND GENERAL OBJECTIONS 27 This defendant objects on the basis that it has 28 previously responded to 58 interrogatories propounded in In ASB00-155/06600.0001 -1- = , < CC 1 Re: Complex Asbestos Litigation and In Re: Shipyard and 2 Applicator Asbestos Cases (Consolidated for discovery) Nos. 3 607734-9 and 537868 for this case. Many of these 4 interrogatories are similar, repetitious, burdensom and 5 harassing in light of the earlier responses. 6 Some of the events which may be relevant to the 7 matters inquired about by Plaintiffs' Interrogatories 8 apparently occurred more than thirty-five years ago. In 9 addition, effective April 30, 1958, Owens-Illinois, Inc. 10 disposed of the business involved in this action by way of sale 11 of that business to Owens-Corning Fiberglas Corporation. Since 12 that time, Owens-Illinois, Inc. has not engaged in any such ` 13 business. It does not now and it has not since that sale 14 manufactured, distributed or sold any asbestos-containing 15 products. As a result of the foregoing factors, many of the 16 individuals who might have had personal knowledge of the 17 matters to which plaintiffs' interrogatories relate are 18 deceased, or are otherwise unavailable to Owens-Illinois, Inc., 19 and investigations to date indicate that at least some documents which relate to matters inquired about by these 20 interrogatories may have been transferred to Owens-Corning 21 Fiberglas Corporation with the transfer of the business in 22 question in 1958. Owens-Illinois, Inc. is engaged in a 23 continuing investigation in an attempt to locate, confirm the 24 transfer of, or confirm the absence of, such documents and is 25 - also-engaged in a continuing investigation into the matters 26 inquired about in these interrogatories. Unless otherwise 27 stated in an answer to a specific interrogatory, the answers 28 ASB00-155/06600.0001 -2- CC 1 set out hereinafter are limited to the period during which 2 Owens-Illinois, Inc. manufactured asbestos-containing 3 insulation products and to the facilities related to that 4 business. The following is part of and is incorporated by 5 reference in every answer provided hereinafter: 6 This answer is accurate as of the date made. 7 However, Owens-Illinois, Inc.'s investigation is 8 continuing, and Owens-Illinois, Inc. cannot exclude 9 the possibility that it may be able to obtain more 10 complete information or even information which 11 indicates that the answer being supplied is 12 incorrect. Owens-Illinois, Inc. objects to answering 13 this interrogatory in regard to any period of time 14 other than the period during which it engaged in the 15 business involved in this case which ended in 16 mid-1958 or concerning any facility not related to 17 that business, on the basis that any such answer 18 would be irrelevant to the subject matter"of the 19 pending litigation, would not be reasonably calculated to lead to the discovery of admissible 20 evidence, and would be burdensome and oppressive. 21 Furthermore, Owens-Illinois, Inc. objects to the 22 instructions and definitions supplied by plaintiffs with regard 23 to these interrogatories, on the basis that the definitions are 24 overbroad, vague, and often inconsistent with the normal usage 25 and meaning of such words, and the instructions are overbroad, 26 burdensome and constitute an unreasonable expansion of the 27 28 ASB00-155/06600.0001 -3- rc 1 interrogatories themselves. Owens-Illinois, Inc. therefore 2 gives notice that it does not consider itself bound by the 3 instructions and definitions propounded by plaintiffs, and 4 instead shall answer the interrogatories in a manner consistent 5 with a normal understanding of the language used in the 6 interrogatory and to the extent necessary to fairly and fully 7 answer the interrogatory. Owens-Illinois construes these 8 interrogatories not to call for information protected by the 9 attorney-client privilege, work product doctrine or any other 10 privilege. Since applicable law only requires discovery 11 regarding any matter not privileged, Owens-Illinois is not 12 required by that rule to specify priviledge material where to ` 13 do so would reveal its attorney's work product. Owens-Illinois 14 objects to any request for a specification of privileged 15 materials absent a proper showing of necessity. 16 RESPONSE TO INTERROGATORY NO. 1; 17 Defendant objects to Interrogatory No. 1 on the basis 18 that it is overly broad, vague and ambiguous. The * 19 interrogatory also calls for information that defendant has no reasonable access to and requests information which is not 20 within the personal knowledge or possession or control of 21 Owens-Illinois, its employees or agents and is therefore not 22 reasonably calculated to lead to the discovery of admissible 23 evidence and is burdensome and oppressive. Owens-Illinois 24 objects to any interrogatory in regard to any time other than25 -which it engaged in business involved in this case on the basis 26 such information is irrelevant and is not calculated to lead to 27 the discovery of admissible evidence and as such is burdensom 28 and oppressive. ASB00-155/06600.0001 -4_ C 1 RESPONSE TO INTERROGATORY NO. 2; 2 Owens-Illinois objects to this interrogatory on the 3 grounds that it seeks identification of all persons' 4 knowledgeable of a possible particular fact, and as such is 5 overly broad, unduly burdensome, oppressive and harassing. 6 This interrogatory is overly broad in calling for 7 identification of each person with knowledge of the subject; 8 many of the persons who possibly may be knowledgeable are now 9 deceased or cannot be located. Moreover, due to the extensive 10 passage of time that has occurred since the date covered by 11 this interrogatory, those who may have had knowledge of this 12 subject may not be able to recall such knowledge nor the time ' 13 during which it was acquired. It also calls for information 14 that Owens-Illinois has no reasonable access to and requests 15 information which is not in the control of Owens-Illinois, its 16 employees or agents, and as such is not reasonably calculated 17 to lead to the discovery of admissible evidence. 18 Owens-Illinois objects to any interrogatory in regard to any 19 time other than which it engaged in business involved in this case on the basis any such information is irrelevant, not 20 reasonably calculated to lead to the discovery of admissible 21 evidence and is burdensome and oppressive. 22 RESPONSE TO INTERROGATORY NO. 3: 23 Defendant objects to Interrogatory No. 3 on the basis 24 that it is overly broad, vague and ambiguous. The 25 -interrogatory also calls for information that defendant has no 26 reasonable access to and requests information which is not 27 within the personal knowledge or possession or control of 28 ASB00-155/06600.0001 -5- CC 1 Owens-Illinois, its employees or agents and is therefore not 2 reasonably calculated to lead to the discovery of admissible 3 evidence and is burdensome and oppressive. 4 This interrogatory, in addition, covers a period of 5 time before Owens-Illinois engaged in business involved in this 6 case and therefore is not calculated to lead to the discovery 7 of admissible evidence. 8 RESPONSE TO INTERROGATORY NO. 4: 9 Owens-Illinois objects to answering this 10 interrogatory on the basis it is overbroad, vague, irrelevant 11 and not calculated to lead to the discovery of any admissible 12 evidence. Owens-Illinois objects to any interrogatory in 13 regard to any time other than which it engaged in business 14 involved in this case on the basis such information is 15 irrelevant and is not calculated to lead to the discovery of 16 admissible evidence and as such is burdensom and oppressive. 17 RESPONSE TO INTERROGATORY NO. 5: 18 Defendant objects to Interrogatory No. 5 on the basis 19 that it is overly broad, vague and ambiguous. The interrogatory also calls for information that defendant has no 20 reasonable access to and requests information which is not 21 within the personal knowledge or possession or control of 22 Owens-Illinois, its employees or agents and is therefore not 23 reasonably calculated to lead to the discovery of admissible 24 evidence and is burdensome and oppressive. 25 ' -RESPONSE TO INTERROGATORY NO. 6: 26 Owens-Illinois objects to this interrogatory on the 27 grounds that it seeks identification of all persons' 28 ASBOO-155/O66OO.OO01 -6- rc 1 knowledgeable of a possible particular fact, and as such is 2 overly broad, unduly burdensome, oppressive and harassing. 3 This interrogatory is overly broad in calling for 4 identification of each person with knowledge of the subject; 5 many of the persons who possibly may be knowledgeable are now 6 deceased or cannot be located. Moreover, due to the extensive 7 passage of time that has occurred since the date covered by 8 this interrogatory, those who may have had knowledge of this 9 subject may not be able to recall such knowledge nor the time 10 during which it was acquired. It also calls for information 11 that Owens-Illinois has no reasonable access to and requests 12 information which is not in the control of Owens-Illinois, its" 13 employees or agents, and as such is not reasonably calculated 14 to lead to the discovery of admissible evidence. 15 Owens-Illinois objects to any interrogatory in regard to any 16 time other than which it engaged in business involved in this 17 case on the basis such information is irrelevant and is not 18 calculated to lead to the discovery of admissible evidence and 19 as such is burdensom and oppressive. RESPONSE TO INTERROGATORY NO. 7: 20 -- Defendant objects to Interrogatory No. 7 on the basis 21 that it is overly broad, vague and ambiguous. The 22 interrogatory also calls for information that defendant has no 23 reasonable access to and requests information which is not 24 within the personal knowledge or possession or control of 25 . Owens-Illinois, its employees or agents and is therefore not 26 reasonably calculated to lead to the discovery of admissible 27 evidence and is burdensome and oppressive. 28 ASB00-155/06 600.0001 -7- ; I ;| : i ! Cr 1 RESPONSE TO INTERROGATORY NO. 8: 2 Owens-Illinois objects to answering this 3 interrogatory on the basis it is overbroad', vague, irrelevant 4 and not calculated to lead to the discovery of any admissible 5 evidence. Owens-Illinois objects to any interrogatory in 6 regard to any time other than which it engaged in business 7 involved in this case on the basis such information is 8 irrelevant and is not calculated to lead to the discovery of 9 admissible evidence and as such is burdensom and oppressive. 10 RESPONSE TO INTERROGATORY NO. 9: 11 Defendant objects to Interrogatory No. 9 on the basis 12 that it is overly broad, vague and ambiguous. The * 13 interrogatory also calls for information that defendant has no 14 reasonable access to and requests information which is not 15 within the personal knowledge or possession or control of 16 Owens-Illinois, its employees or agents and is therefore not 17 reasonably calculated to lead to the discovery of admissible 18 evidence and is burdensome and oppressive. Owens-Illinois 19 objects to any interrogatory in regard to any time other than which it engaged in business involved in this case on the basis 20 such information is irrelevant and is not calculated to lead to 21 the discovery of admissible evidence and as such is burdensom 22 and oppressive. 23 RESPONSE TO INTERROGATORY NO. 10: 24 Owens-Illinois objects to answering this . 25 - interrogatory on the basis it is overbroad, vague, irrelevant 26 and not calculated to lead to the discovery of any admissible 27 evidence. Owens-Illinois objects to any interrogatory in 28 ASBOO-155/06600.0001 -8- CC I regard to any time other than which it engaged in business 2 involved in this case on the basis such information is 3 irrelevant and is not calculated to lead t'o the discovery of 4 admissible evidence and as such is burdensom and oppressive. 5 RESPONSE TO INTERROGATORY NO. 11: 6 Defendant objects to Interrogatory No. 11 on the 7 basis that it is overly broad, vague and ambiguous. The 8 interrogatory also calls for information that defendant has no 9 reasonable access to and requests information which is not 10 within the personal knowledge or possession or control of 11 Owens-Illinois, its employees or agents and is therefore not 12 reasonably calculated to lead to the discovery of admissible ` 13 evidence and is burdensome and oppressive. Owens-Illinois 14 objects to any interrogatory in regard to any time other than 15 which it engaged in business involved in this case on the basis 16 such information is irrelevant and is not calculated to lead to 17 the discovery of admissible evidence and as such is burdensom 18 and oppressive. * 19 RESPONSE TO INTERROGATORY NO. 12: Owens-Illinois objects to this interrogatory on the 20 grounds that it seeks identification of all persons' 21 knowledgeable of a possible particular fact, and as such is 22 overly broad, unduly burdensome, oppressive and harassing. 23 This interrogatory is overly broad in calling for 24 identification of each person with knowledge of the subject; 25 -many of the persons who possibly may be knowledgeable are now 76 deceased or cannot be located. Moreover, due to the extensive 27 passage of time that has occurred since the date covered by 28 ASB00-155/06600.0001 -9- CC 1 this interrogatory, those who may have had knowledge of this 2 subject may not be able to recall such knowledge nor the time 3 during which it was acquired. It also calls for information 4 that Owens-Illinois has no reasonable access to and requests 5 information which is not in the control of Owens-Illinois, its 6 employees or agents, and as such is not reasonably calculated 7 to lead to the discovery of admissible evidence. 8 Owens-Illinois objects to any interrogatory in regard to any 9 time other than which it engaged in business involved in this 10 case on the basis such information is irrelevant and is not 11 calculated to lead to the discovery of admissible evidence and 12 as such is burdensom and oppressive. " 13 RESPONSE TO INTERROGATORY NO. 13: 14 Defendant objects to Interrogatory No. 13 on the 15 basis that it is overly broad, vague and ambiguous. The 16 interrogatory also calls for information that defendant has no 17 reasonable access to and requests information which is not 18 within the personal knowledge or possession or control of 19 Owens-Illinois, its employees or agents and is therefore not reasonably calculated to lead to the discovery of admissible 20 evidence and is burdensome and oppressive. 21 RESPONSE TO INTERROGATORY NO. 14: 22 Owens-Illinois objects to this interrogatory on the 23 grounds that it seeks identification of all persons' 24 knowledgeable of a possible particular fact, and as such is ' 25 overly broad, unduly burdensome, oppressive and harassing. 26 This interrogatory is overly broad in calling for 27 identification of each person with knowledge of the subject; 28 .. ASBO0-155/06600.0001 -10- i ; i t .: i I C( 1 many of the persons who possibly may be knowledgeable are now 2 deceased or cannot be located. Moreover, due to the extensive 3 passage of time that has occurred since ttfe date covered by 4 this interrogatory, those who may have had knowledge of this 5 subject may not be able to recall such knowledge nor the time 6 during which it was acquired. It also calls for information 7 that Owens-Illinois has no reasonable access to and requests 8 information which is not in the control of Owens-Illinois, its 9 employees or agents, and as such is not reasonably calculated 10 to lead to the discovery of admissible evidence. 11 Owens-Illinois objects to any interrogatory in regard to any 12 time other than which it engaged in business involved in this ' 13 case on the basis such information is irrelevant and is not 14 calculated to lead to the discovery of admissible evidence and 15 as such is burdensom and oppressive. 16 RESPONSE TO INTERROGATORY NO. 15: 17 Defendant objects to Interrogatory No. 15 on the 18 basis that it is overly broad, vague and ambiguous.' The 19 interrogatory also calls for information that defendant has no reasonable access to and requests information which is not 20 within the personal knowledge or possession or control of 21 Owens-Illinois, its employees or agents and is therefore not 22 reasonably calculated to lead to the discovery of admissible 23 evidence and is burdensome and oppressive. Owens-Illinois 24 objects to any interrogatory in regard to any time other than' 25 -which it engaged in business involved in this case on the basis 26 such information is irrelevant and is not calculated to lead to 27 the discovery of admissible evidence and as such is burdensom 28 and oppressive. ASB00-155/06600.0001 -11- i CC 1 RESPONSE TO INTERROGATORY NO. 16: 2 Owens-Illinois objects to this interrogatory on the 3 grounds that it seeks identification of all persons' 4 knowledgeable of a possible particular fact, and as such is 5 overly broad, unduly burdensome, oppressive and harassing. 6 This interrogatory is overly broad in calling for 7 identification of each person with knowledge of the subject; 8 many of the persons who possibly may be knowledgeable are now 9 deceased or cannot be located. Moreover, due to the extensive 10 passage of time that has occurred since the date covered by 11 this interrogatory, those who may have had knowledge of this 12 subject may not be able to recall such knowledge nor the time * 13 during which it was acquired. It also calls for information 14 that Owens-Illinois has no reasonable access to and requests information which is not in the control of Owens-Illinois, its 15 16 employees or agents, and as such is not reasonably calculated 17 to lead to the discovery of admissible evidence. 18 Owens-Illinois objects to any interrogatory in regard to any 19 time other than which it engaged in the relevant business on the basis any such answer is irrelevant," not reasonably 20 calculated to lead to the discovery of admissible evidence and 21 is burdensome and oppressive. 22 RESPONSE TO INTERROGATORY NO. 17: 23 Defendant objects to Interrogatory No. 17 on the 24 basis that it is overly broad, vague and ambiguous. The 25 ' - interrogatory also calls for information that defendant has no 26 reasonable access to and requests information which is not 27 within the personal knowledge or possession or control of 28 ASB00-155/06600.0001 -12- cf 1 Owens-Illinois, its employees or agents and is therefore not 2 reasonably calculated to lead to the discovery of admissible 3 evidence and is burdensome and oppressive.' Owens-Illinois 4 objects to any interrogatory in regard to any time other than 5 which it engaged in business involved in this case on the basis 6 such information is irrelevant and is not calculated to lead to 7 the discovery of admissible evidence and as such is burdensom 8 and oppressive. 9 RESPONSE TO INTERROGATORY NO. 18: 10 Owens-Illinois objects to answering this 11 interrogatory on the basis it is overbroad, vague, irrelevant 12 and not calculated to lead to the discovery of any admissible ` 13 evidence. Owens-Illinois objects to any interrogatory in 14 regard to any time other than which it engaged in business 15 involved in this case on the basis such information is 16 irrelevant and is not calculated to lead to the discovery of 17 admissible evidence and as such is burdensom and oppressive. RESPONSE TO INTERROGATORY NO. 19; 18 * 19 Owens-Illinois objects to answering this interrogatory on the basis it is overbroad, vague, irrelevant 20 and not calculated to lead to the discovery of any admissible 21 evidence. Owens-Illinois objects to any interrogatory in 22 regard to any time other than which it engaged in business 23 involved in this case on the basis such information is 24 irrelevant and is not calculated to lead to the discovery of ' 25 - admissible evidence and as such is burdensom and oppressive. 26 RESPONSE TO INTERROflATORY NO. 20; 27 Owens-Illinois objects to answering this 28 ASB00-155/06600.0001 -13- cc 1 interrogatory on the basis it is overbroad, vague, irrelevant 2 and not calculated to lead to the discovery of any admissible 3 evidence. Owens-Illinois objects to any interrogatory in 4 regard to any time other than which it engaged in business 5 involved in this case on the basis such information is 6 irrelevant and is not calculated to lead to the discovery of 7 admissible evidence and as such is burdensom and oppressive. 8 RESPONSE TO INTERROGATORY NO. 21: 9 Defendant objects to Interrogatory No. 21 on the 10 basis that it is overly broad, vague and ambiguous. The 11 interrogatory also calls for information that defendant has no .* 12 reasonable access to and requests information which is not 13 within the personal knowledge or possession or control of 14 Owens-Illinois, its employees or agents and is therefore not 15 reasonably calculated to lead to the discovery of admissible 16 evidence and is burdensome and oppressive. Owens-Illinois objects to any interrogatory in regard to any time other than 17 << . 18 which it engaged in business involved in this case on the basis 19 such information is irrelevant and is not calculated to lead to the discovery of admissible evidence and as such is burdensom 20 and oppressive. 21 RESPONSE TO INTERROGATORY NO. 22: 22 Owens-Illinois objects to answering this 23 interrogatory on the basis it is overbroad, vague, irrelevant 24 and not calculated to lead to the discovery of any admissible 25 evidence. Owens-Illinois objects to any interrogatory in 26 regard to any time other than which it engaged in business 27 involved in this case on the basis such information is 28 ASB00-155/06600.0001 -14- y ; t -j j jI I j i ; ! i iI j ! j 1 j | Cc 1 irrelevant and is not calculated to lead to the discovery of admissible evidence and as such is burdensom and oppressive. 2 3 RESPONSE TO INTERROGATORY NO. 23: ' 4 Owens-Illinois objects to answering this 5 interrogatory on the basis it is overbroad, vague, irrelevant 6 and not calculated to lead to the discovery of any admissible 7 evidence and is also burdensome and oppresive. Owens-Illinois 8 objects to any interrogatory in regard to any time other than 9 which it engaged in business involved in this case on the basis 10 such information is irrelevant and is not calculated to lead to 11 the discovery of admissible evidence and as such is burdensom 12 and oppressive. 13 RESPONSE TO INTERROGATORY NO. 24: 14 Owens-Illinois objects to answering this 15 interrogatory on the basis it is overbroad, vague, irrelevant 16 and not calculated to lead to the discovery of any admissible 17 evidence. Owens-Illinois objects to any interrogatory in regard to any time other than which it engaged in business 18 involved in this case on the basis such information is 19 irrelevant and is not calculated to lead to the discovery of 20 admissible evidence and as such is burdensom and oppressive. 21 RESPONSE TO INTERROGATORY NO. 25: 22 Defendant objects to Interrogatory No. 25 on the 23 basis that it is overly broad, vague and ambiguous. The 24 interrogatory also calls for information that defendant has no 25 reasonable access to and requests information which is not 26 within the personal knowledge or possession or control of 27 Owens-Illinois, its employees or agents and is therefore not 28 ASBOO-155/06600.0001 -15- j ! ! . i i 'i f j j j !i ; i j ' C 1 reasonably calculated to lead to the discovery of admissible 2 evidence and is burdensome and oppressive. 3 Owens-Illinois objects to any interrogatory in regard 4 to any time other than which it engaged in business involved in 5 this case on the basis such information is irrelevant and is 6 not calculated to lead to the discovery of admissible evidence 7 and as such is burdensom and oppressive. 8 RESPONSE TO INTERROGATORY NO. 26: 9 Owens-Illinois objects to answering this 10 interrogatory on the basis it is overbroad, vague, irrelevant 11 and not calculated to lead to the discovery of any admissible 12 evidence. Owens-Illinois objects to any interrogatory in 13 regard to any time other than which it engaged in business 14 involved in this case on the basis such information is 15 irrelevant and is not calculated to lead to the discovery of 16 admissible evidence and as such is burdensom and oppressive. RESPONSE TO INTERROGATORY NO. 27: 17 Defendant objects to Interrogatory No. 27.on the 18 19 basis that it is overly broad, vague and ambiguous. The interrogatory also calls for information that defendant has no 20 reasonable access to and requests information which is not 21 within the personal knowledge or possession or control of 22 Owens-Illinois, its employees or agents and is therefore not 23 reasonably calculated to lead to the discovery of admissible 24 evidence and is burdensome and oppressive. 25 . - Owens-Illinois objects to any interrogatory in regard 26 to any time other than which it engaged in business involved in 27 this case on the basis such information is irrelevant and is 28 ASB00-155/06600.0001 -16- C< 1 not calculated to lead to the discovery of admissible evidence 2 and as such is burdensom and oppressive. 3 RESPONSE TO INTERROGATORY NO. 28: ' 4 Defendant objects to Interrogatory No. 28 on the 5 basis that it is overly broad, vague and ambiguous. The 6 interrogatory also calls for information that defendant has no 7 reasonable access to and requests information which is not 8 within the personal knowledge or possession or control of 9 Owens-Illinois, its employees or agents and is therefore not 10 reasonably calculated to lead to the discovery of admissible 11 evidence and is burdensome and oppressive. 12 Owens-Illinois objects to any interrogatory in regard 13 to any time other than which it engaged in business involved in 14 this case on the basis such information is irrelevant and is 15 not calculated to lead to the discovery of admissible evidence 16 and as such is burdensom and oppressive. 17 RESPONSE TO INTERROGATORY NO. 29; 18 Defendant objects to Interrogatory No. 29 on the 19 basis that it is overly broad, vague and ambiguous. The interrogatory also calls for information that defendant has no 20 reasonable access to and requests information which is not 21 within the personal knowledge or possession or control of 22 Owens-Illinois, its employees or agents and is therefore not 23 reasonably calculated to lead to the discovery of admissible 24 evidence and is burdensome and oppressive. 25 ' Owens-Illinois objects to any interrogatory in regard 26 to any time other than which it engaged in business involved in 27 this case on the basis such information is irrelevant and is 28 ASB00-155/06600.0001 -17- CC 1 not calculated to lead to the discovery of admissible evidence 2 and as such is burdensom and oppressive. 3 RESPONSE TO INTERROGATORY NO. 30: ' 4 Only a small portion of Owens-Illinois' business or 5 corporate history relates to the subject matter of this 6 litigation which is alleged exposure to asbestos-containing 7 insulation products. Owens-Illinois objects to this 8 interrogatory on the basis that it is vague, overly broad, 9 irrelevant, immaterial and not reasonably calculated to lead to 10 the discovery of admissible evidence. In addition it is 11 burdensome and harassing. RESPONSE TO INTERROGATORY NO. 31: 12 ' 13 Owens-Illinois objects to this interrogatory on the 14 basis that it is vague, overly broad, irrelevant, immaterial 15 and not reasonably calculated to lead to the discovery of 16 admissible evidence. It is also burdensome, oppressive and 17 harassing. Owens-Illinois objects to any interrogatory in 18 regard to any time other than which it engaged in business 19 involved in this case on the basis such information is irrelevant and is not calculated to lead to the discovery of 20 admissible evidence and as such is burdensom and oppressive. 21 RESPONSE TO INTERROGATORY NO. 32: 22 Owens-Illinois objects to this interrogatory on the 23 basis that it is vague, overly broad, irrelevant, immaterial 24 and not reasonably calculated to lead to the discovery of 25 ' admissible evidence. It is also burdensome and oppressive. 26 RESPONSE TO INTERROGATORY NO. 33: 27 Only a small portion of Owens-Illinois' business or 28 ASB00-155/06600.0001 -18- cc 1 corporate history relates to the subject matter of this 2 litigation, alleged exposure to asbestos-containing insulation 3 products. Owens-Illinois objects to this'interrogatory on the 4 basis that it is vague, overly broad, irrelevant, immaterial 5 and not reasonably calculated to lead to the discovery of 6 admissible evidence. Also, please see response to 7 Interrogatory No. 32. 8 RESPONSE TO INTERROGATORY NO. 34: 9 Owens-Illinois objects to this interrogatory on the 10 grounds that it seeks identification of all persons' 11 knowledgeable of a possible particular fact, and as such is 12 overly broad, unduly burdensome, oppressive and harassing. This interrogatory is overly broad in calling for 13 14 identification of each person with knowledge of the subject; 15 many of the persons who possibly may be knowledgeable are now 16 deceased or cannot be located. Moreover, due to the extensive 17 passage of time that has occurred since the date covered by this interrogatory, those who may have had knowledge of this 18 19 subject may not be able to recall such knowledge nor the time during which it was acquired. It also calls for information 20 that Owens-Illinois has no reasonable access to and requests 21 information which is not in the control of Owens-Illinois, its 22 employees or agents, and as such is not reasonably calculated 23 to lead to the discovery of admissible evidence. 24 Owens-Illinois objects to any interrogatory in regard to any 25 time other than which it engaged in business involved in this 26 case on the basis such information is irrelevant and is not 27 calculated to lead to the discovery of admissible evidence and 28 as such is burdensom and oppressive. ASB00-155/06600.0001 -19- rc 1 RESPONSE TO INTERROGATORY NO. 35: 2 Only a small portion of Owens-Illinois' business or 3 corporate history relates to the subject Matter of this 4 litigation, alleged exposure to asbestos-containing insulation 5 products. Owens-Illinois objects to this interrogatory on the 6 basis that it is vague, overly broad, irrelevant, immaterial 7 and not reasonably calculated to lead to the discovery of 8 admissible evidence. It is, in addition, burdensome, 9 oppressive and harassing. 10 RESPONSE TO INTERROGATORY NO. 36: 11 Not applicable. 12 Please see response to Interrogatory No. 35. 13 RESPONSE TO INTERROGATORY NO. 37: ` 14 Owens-Illinois objects to this interrogatory on the 15 basis that it is vague, overly broad, irrelevant, immaterial 16 and not reasonably calculated to lead to the discovery of 17 admissible evidence. It is burdensome, oppressive and 18 harassing. Owens-Illinois objects to any interrogatory in 19 regard to any time other than which it engaged in business involved in this case on the basis such'information is 20 irrelevant and is not calculated to lead to the discovery of 21 admissible evidence and as such is burdensom and oppressive. 22 RESPONSE TO INTERROGATORY NO. 38: 23 Owens-Illinois objects to this interrogatory on the 24 basis that it is vague, overly broad, irrelevant, immaterial 25 - and not reasonably calculated to lead to the discovery of 26 admissible evidence. Owens-Illinois objects to any 27 interrogatory in regard to any time other than which it engaged 28 ASB00-155/06600.0001 -20- M i .i rc 1 in business involved in this case on the basis such information 2 is irrelevant and is not calculated to lead to the discovery of 3 admissible evidence and as such is burdensom and oppressive. 4 RESPONSE TO INTERROGATORY NO. 39: 5 Owens-Illinois objects to answering this 6 interrogatory on the basis it is overbroad, vague, irrelevant 7 and not calculated to lead to the discovery of any admissible 8 evidence. Owens-Illinois objects to any interrogatory in 9 regard to any time other than which it engaged in business 10 involved in this case on the basis such information is 11 irrelevant and is not calculated to lead to the discovery of 12 admissible evidence and as such is burdensom and oppressive. 13 RESPONSE TO INTERROGATORY NO. 40: 14 Owens-Illinois objects to this interrogatory on the 15 grounds that it seeks identification of all persons' 16 knowledgeable of a possible particular fact, and as such is 17 overly broad, unduly burdensome, oppressive and harassing. 18 This interrogatory is overly broad in calling for 19 identification of each person with knowledge of the subject; many of the persons who possibly may be knowledgeable are now 20 deceased or cannot be located. Moreover, due to the extensive 21 passage of time that has occurred since the date covered by 22 this interrogatory, those who may have had knowledge of this 23 subject may not be able to recall such knowledge nor the time 24 during which it was acquired. It also calls for information 25 that Owens-Illinois has no reasonable access to and requests 26 information which is not in the control of Owens-Illinois, its 27 employees or agents, and as such is not reasonably calculated 28 ASBOO-155/06600.0001 -21- j ; j 4 cc 1 to lead to the discovery of admissible evidence. 2 Owens-Illinois objects to any interrogatory in regard to any 3 time other than which it engaged in busine'ss involved in this 4 case on the basis such information is irrelevant and is not 5 calculated to lead to the discovery of admissible evidence and 6 as such is burdensom and oppressive. 7 RESPONSE TO INTERROGATORY NO. 41: 8 Owens-Illinois objects to this interrogatory on the 9 grounds that it seeks identification of all persons' 10 knowledgeable of a possible particular fact, and as such is 11 overly broad, unduly burdensome, oppressive and harassing. This interrogatory is overly broad in calling for 12 identification of each person with knowledge of the subject; 13 14 many of the persons who possibly may be knowledgeable are now deceased or cannot be located. Moreover, due to the extensive 15 passage of time that has occurred since the date covered by 16 17 this interrogatory, those who may have had knowledge of this subject may not be able to recall such knowledge nor the time 18 19 during which it was acquired. It also calls for information that Owens-Illinois has no reasonable access to and requests 20 information which is not in the control of Owens-Illinois, its 21 employees or agents, and as such is not reasonably calculated 22 to lead to the discovery of admissible evidence. 23 Owens-Illinois objects to any interrogatory in regard to any 24 time other than which it engaged in business involved in this 25 case-on the basis such information is irrelevant and is not 26 calculated to lead to the discovery of admissible evidence and 27 as such is burdensom and oppressive. 28 ASB00-155/06600.0001 -22- Cc 1 RESPONSE TO INTERROGATORY NO. 42: 2 Owens-Illinois objects to this interrogatory on the 3 grounds that it seeks identification of all persons' 4 knowledgeable of a possible particular fact, and as such is 5 overly broad, unduly burdensome, oppressive and harassing. 6 This interrogatory is overly broad in calling for 7 identification of each person with possible knowledge of the 8 subject; many of the persons who possibly may be knowledgeable 9 are now deceased or cannot be located. Moreover, due to the 10 extensive passage of time that has occurred since the date 11 covered by this interrogatory, those who may have had knowledge 12 of this subject may not be able to recall such knowledge nor 13 the time during which it was acquired. It also calls for 14 information that Owens-Illinois has no reasonable access to and 15 requests information which is not in the control of 16 Owens-Illinois, its employees or agents, and as such is not 17 reasonably calculated to lead to the discovery of admissible 18 evidence. Owens-Illinois objects to any interrogatory in 19 regard to any time other than which it engaged in business 20 involved in this case on the basis such information is irrelevant and is not calculated to lead to the discovery of 21 admissible evidence and as such is burdensom and oppressive. 22 RESPONSE TO INTERROGATORY NO. 43: 23 Owens-Illinois objects to answering this 24 interrogatory on the basis it is overbroad, vague, irrelevant 25 and not calculated to lead to the discovery of any admissible 26 evidence. Owens-Illinois objects to any interrogatory in 27 28 regard to any time other than which it engaged in business ASBOO-155/06600.0001 -23- CC I involved in this case on the basis such information is 2 irrelevant and is not calculated to lead to the discovery of 3 admissible evidence and as such is burdenSom and oppressive. 4 RESPONSE TQ INTERROGATORY NO. 44: 5 Owens-Illinois objects to answering this 6 interrogatory on the basis it is overbroad, vague, irrelevant 7 and not calculated to lead to the discovery of any admissible 8 evidence. Owens-Illinois objects to any interrogatory in 9 regard to any time other than which it engaged in business 10 involved in this case on the basis such information is 11 irrelevant and is not calculated to lead to the discovery of 12 admissible evidence and as such is burdensom and oppressive. ' RESPONSE TO INTERROGATORY NO. 45: 13 14 Owens-Illinois objects to this interrogatory on the 15 grounds that it seeks identification of all persons' 16 knowledgeable of a possible particular fact, and as such is 17 overly broad, unduly burdensome, oppressive and harassing. This interrogatory is overly broad in calling for 18 identification of each person with knowledge of the subject; 19 many of the persons who possibly may be~knowledgeable are now 20 deceased or cannot be located. Moreover, due to the extensive 21 passage of time that has occurred since the date covered by 22 this interrogatory, those who may have had knowledge of this 23 subject may not be able to recall such knowledge nor the time 24 during which it was acquired. It also calls for information 25 that Owens-Illinois has no reasonable access to and requests 26 information which is not in the control of Owens-Illinois, its 27 employees or agents, and as such is not reasonably calculated 28 ASB00-155/06600.0001 -24- CC 1 to lead to the discovery of admissible evidence. 2 Owens-Illinois objects to any interrogatory in regard to any 3 time other than which it engaged in business involved in this 4 case on the basis such information is irrelevant and is not 5 calculated to lead to the discovery of admissible evidence and 6 as such is burdensom and oppressive. 7 RESPONSE TO INTERROGATORY NO. 46: 8 Owens-Illinois objects to answering this 9 interrogatory on the basis it is overbroad, vague, irrelevant 10 and not calculated to lead to the discovery of any admissible 11 evidence. Owens-Illinois objects to any interrogatory in 12 regard to any time other than which it engaged in business 13 involved in this case on the basis such information is 14 irrelevant and is not calculated to lead to the discovery of 15 admissible evidence and as such is burdensom and oppressive. 16 RESPONSE TO INTERROGATORY NO. 47: 17 Owens-Illinois objects to answering this interrogatory on the basis it is overbroad, vague, irrelevant 18 19 and not calculated to lead to the discovery of any admissible evidence. Owens-Illinois objects to any interrogatory in 20 regard to any time other than which it engaged in business 21 involved in this case on the basis such information is 22 irrelevant and is not calculated to lead to the discovery of 23 admissible evidence and as such is burdensom and oppressive. 24 RESPONSE TO INTERROGATORY NO. 48: 25 - Owens-Illinois objects to answering this 26 interrogatory on the basis it is overbroad, vague, irrelevant 27 and not calculated to lead to the discovery of any admissible 28 ASBOO-155/06600.0001 -25- Cc 1 evidence. Owens-Illinois objects to any interrogatory in 2 regard to any time other than which it engaged in business 3 involved in this case on the basis such information is 4 irrelevant and is not calculated to lead to the discovery of 5 admissible evidence and as such is burdensom and oppressive. 6 RESPONSE TO INTERROGATORY NO. 49: 7 Defendant objects to Interrogatory No. 49 on the 8 basis that it is overly broad, vague and ambiguous. The 9 interrogatory also calls for information that defendant has no 10 reasonable access to and requests information which is not 11 within the personal knowledge or possession or control of 12 Owens-Illinois, its employees or agents and is therefore not 13 reasonably calculated to lead to the discovery of admissible 14 evidence and is burdensome and oppressive. Owens-Illinois 15 objects to any interrogatory in regard to any time other than 16 which it engaged in business involved in this case on the basis 17 such information is irrelevant and is not calculated to lead to 18 the discovery of admissible evidence and as such is burdensom 19 and oppressive. RESPONSE TO INTERROGATORY NO. 50; 20 ~ Owens-Illinois objects to this interrogatory on the 21 grounds that it seeks identification of all persons' 22 knowledgeable of a possible particular fact, and as such is 23 overly broad, unduly burdensome, oppressive and harassing. 24 This interrogatory is overly broad in calling for 25 identification of each person with knowledge of the subject; 26 many of the persons who possibly may be knowledgeable are now 27 deceased or cannot be located. Moreover, due to the extensive 28 ASB00-155/06600.0001 -26- cc 1 passage of time that has occurred since the date covered by 2 this interrogatory, those who may have had knowledge of this 3 subject may not be able to recall such knowledge nor the time 4 during which it was acquired. It also calls for information 5 that Owens-Illinois has no reasonable access to and requests 6 information which is not in the control of Owens-Illinois, its 7 employees or agents, and as such is not reasonably calculated 8 to lead to the discovery of admissible evidence. 9 Owens-Illinois objects to any interrogatory in regard to any 10 time other than which it engaged in business involved in this 11 case on the basis such information is irrelevant and is not 12 calculated to lead to the discovery of admissible evidence and 13 as such is burdensom and oppressive. 14 RESPONSE TO INTERROGATORY NO. 51; 15 Defendant objects to Interrogatory No. 51 on the 16 basis that it is overly broad, vague and ambiguous. The 17 interrogatory also calls for information that defendant has no 18 reasonable access to and requests information which'is not 19 within the personal knowledge or possession or control of 20 Owens-Illinois, its employees or agents and is therefore not reasonably calculated to lead to the discovery of admissible 21 22 evidence and is burdensome and oppressive. 23 Owens-Illinois objects to any interrogatory in regard 24 to any time other than which it engaged in business involved in this case on the basis such information is irrelevant and is 25 26 ' not calculated to lead to the discovery of admissible evidence 27 and as such is burdensom and oppressive. 28 ASB00-155/06600.0001 -27- rc 1 RESPONSE TO INTERROGATORY NO. 52: 2 Owens-Illinois objects to this interrogatory on the 3 grounds that it seeks identification of all persons' 4 knowledgeable of a possible particular fact, and as such is c overly broad, unduly burdensome, oppressive and harassing. 6 This interrogatory is overly broad in calling for 7 identification of each person with knowledge of the subject; 8 many of the persons who possibly may be knowledgeable are now 9 deceased or cannot be located. Moreover, due to the extensive 10 passage of time that has occurred since the date covered by 11 this interrogatory, those who may have had knowledge of this 12 subject may not be able to recall such knowledge nor the time 13 during which it was acquired. It also calls for information 14 that Owens-Illinois has no reasonable access to and requests 15 information which is not in the control of Owens-Illinois, its 16 employees or agents, and as such is not reasonably calculated 17 to lead to the discovery of admissible evidence. 18 Owens-Illinois objects to any interrogatory in regard to any 19 time other than which it engaged in business involved in this 20 case on the basis such information is irrelevant and is not 21 calculated to lead to the discovery of admissible evidence and 22 as such is burdensom and oppressive. 23 24 25 26 27 28 ASB00-155/06600.0001 Attorneys for Defendants FIBREBOARD CORPORATION, PITTSBURGH-CORNING CORPORATION, OWENS-ILLINOIS INC. -28- rc PROOF OF SERVICE I, Julie Galdieri, do hereby declare and state: I am employed in the City and County of San Francisco, California. I am over the age of 18 years and not a party to the within action. My business address is The Federal Reserve Bank building , 101 Market Street, Suite 601, San Francisco, California, 94105. On September 1, 1989, 1989, I served the within: DEFENDANT <3X *3 ANSWERS TO INTERROGATORIES on the parties in this action, by placing a true copy thereof in a sealed envelope, and each envelope addressed as follows: SEE ATTACHED LIST X_______ (By Mail) I caused each such envelope, with postage thereon fully prepaid, to be placed in the United States mail at San Francisco, California. (By Personal Service) I caused each such envelope to be delivered by hand to the offices of each addressee above. ____________ (By Telecopier) I caused each such document to be Telefaxed by telecopier to the offices of each addressee above. I declare under penalty of perjury that the foregoing is true and correct. Executed this 1st of September. 1989 at San Francisco, California. 1649p H in*-* NHH H a vx U3 H OH nv o*- Oic M ** Ol (M O r H 3-- CM 01 CM tthl a> O Uuh U o Cf*> MO cH BHH Z 4t Q 3 UVJOV <0 S'--' C 3*r M H C *Ohvjo> V) <0 lD M*0 1 3 * o*4 l-co l4 )r U !v o U . 4*H*0 JZ c KH4 UM UCDOC BCM 4 0^0 M1C Sou *a*u H U Jd Jo e HUM 4 KHK) e* *44 UTJM <o Z -H Bo c O^f 9 Ooicq I111 111 o O o O o CD o <n ID CHM 1 CD r> at ID OM HH oo OOl cd i H MaT>H M 3~ o M c* r i rr OCD CMC* O c M H 3 V) CD tO ID CM o\ CM 4* A C M ID ^4 f*Hr 03) CM CM 11 GO 00 00 0% r- CD ,,* HD ID U^M H iu Mi H *4 M M> *--* MOl > - MOO HSOV O-- CM Ntf) o r*w >D CMO OH Brno U H iiA uo 3#H Cm'-' Im z^ UH 0*G*m (0 CH hoi inoqq o HV> 3l 03 4 iW< HCD C 4 WC4 +U 4 M 4 TJ SlHJ3c QH< HOW COBCm Huu Cd 4 U SO(m zou 02Cm ou 04U toaw jfifc. gsu* fcjZtM ud M z3e Dcd n KH C JD c C c So e 3cm e fflcD e c t4UHJ< QO O do 4 <cm 4 pea UO 4 |M<M 4 OO 4 rtCM 4 f<Hr4 0H*4 UhV) BiDCO tOVDV) BrV) mr-to OCMC/1 K(/1iHO III --i r t ^ 'i SNS N I I I1 t:i< J DO 14 Uk . U4 oo a o o 03pS 3:r k m o-n 03 C CC. 4 W `H Go-^ 0 4 KBO MU oo Z `CTM* &o V SH Ur*H (JcD 4 C0CM> Zw c H C m O__.*< M 4 ZOU 4 M wSi! zru. ? O ? k3iD O O 0 C W*H M OC C 4 ZCMCO flOW H I- )3 ; hon 1 CM MM <H >cj 4m iS*03i :uV 2E ) 4< Ml M DCM Z O Uivp hlM^ Zt/IOi p a vi 4 aia\ carj o *H o< O ViU MTJ ^ 4O uou Z 4J-3S P O VC Om< 03 COO O J 4 v C0-H o co > o WiP H (A(Jmcm <41J atoi OlB u uM< >* COO 0H iHCM CD 1 Ct ID MM> H 3-- WCD H Cl fl'-- U 4rMM> OTO O aot M *T c* On D4 1U fi dn ID 3 0^-4 HlAJ HV 9<p n *H > 34 vjr-Q o MO 4 Ol O ID MI r-cri VOCD 43 M> HI/1 Odh tntDDu-- 3 >r JHUH U3OC0VD O o VO Cl MCD -40 3*H Ol * M< Otoo V 0> JC %u Xu v* > GCLu'O 0- .t- JT2__Ort.0. < cOci cm QQ 0 c dm hi < ^>. r< n *-Qo *i<-* o QidrO ficvOlDQcj*4 h 4 CCC5U.4 />.; Vn <. nos* hQ'' Ct'jL.- uPdo c MARVIN D. MORGENSTEIN* EXJOT S. JUBELIRER LEE ANN HUNTINGTON JEAN L BERTRAND JEFFREY R. WILLIAMS JAMES R. BAUCH ROCKY N. UNRUH LAURIE K. ANGER ROBERTA NICOL DEMPSTER DENNIS M. FARIAS KARUN GOULD KIRSTEN HOWE LARRY C LOWE james l McGinnis ELIZABETH MEYER ROBERT B. MULLEN ROBERT O'BRIEN JOHN J. PETRY KERRY R. STOEBNER DAVID E 5TUMBOS CYRIAN B.TABUENA A PROFESSIONAL CORPORATION c MORGENSTEIN & JUBELIRER THE FEDERAL RESERVE BANK BUILDING 101 MARKET STREET, SIXTH FLOOR SAN FRANCISCO, CALIFORNIA 94105 (415) 896-0666 FAX (415) 896-5592 RECEIVED AUG 0 4 1389 August 4, 1989 HAND DELIVERED Ms. Jackie Goldsley Kazan & McClain 171 - 12th Street, Suite 300 Oakland, California 94607 Re: Willie Coleman. #650495-3 IN RE: COMPELX ASBESTOS LITIGATION NO. 607734-9 IN RE SHIPYARD AND APPLICATOR ASBESTOS CASES (Consolidated for Discovery No. 537868-7) Dear Ms. Goldsley: Enclosed are the responses for Owens-Illinois Inc. As we have discussed before, the verification is a copy. If there are questions concerning this matter, please feel free to call me. Very truly yours, Karlin Gould KG/gg:WPMAG-691:06600.00001 Enclosure cc: Sally Tay Howe MARVIN IX M0RCENSTE1N* euot&jvrilireii LXZ AW HUNTINGTON JEAN t BERTRAND icmrcv R. VILL1AMS JAMES R. BAUCH ROCKY N. UNAUH lacrie k. anger HOSLRTA NICOL PEMPSTtM DENNIS M. FARIAS KAJUJN OUUID KIRSTEN MOVE LARRY C LOVE JAMES L M<INNM ELIZAAFTH MEYER ROBERT R MLXLEN ROBERT 01A1EN JOHN J. PETKY KERRY R.RTOUNCR CMVID L STUMBOS CYRIANB. TABUENA a rnorasiONAL corporation FAX # (415) 835-4913 MORGENSTEIN & JUBELIRER THE FEDERAL RESERVE BANK BUILDING 101 MARKET STREET. SIXTH FLOOR SAN FRANCISCO. CALIFORNIA 94105 (415)896*0666 FAX (415) 896-5592 July 28, 1989 Ms. Jackie Goldsky Kazan & McClain, P.C. 171 - 12th Street 3rd Floor Oakland, CA 94607 Re: Extension of Time for Owens-Illinois Response to interrogatous (Willie Coleman) Dear Ms. Goldsky, This letter is to confirm that I informed you of an extension of time for responses on behalf of Owens-Illinois that Mr. Kazan and Ms. Jean Bertram agreed upon today. Mr. Kazan agreed to extend the response time to August 4, 1989. If you have any further questions, please feel free to call me. Very truly yours. KG/kc WPTEMP-117/06600-90867 Karlin Gould r c KtUtlVtU JUL 2 7 1389 MARVIN D. M0RGENSTE1N* ELIOT S. JUBEL1RER LEE ANN HUNTINGTON JEAN L BERTRAND JEFFREY R. WILLIAMS JAMES R. BAL1CH ROCKY N. UNRUH LAURIE K. ANCER MARGARET P. BAKER ROBERTA NICOL DEMPSTER KARLIN GOULD JENNIFER D. HOLT KIRSTEN HOWE LARRY C. LOWE JAMES L MeCINNIS ELIZABETH MEYER ROBERT B. MULLEN ROBERT O'BRIEN JONATHAN M. PEREZOUS KERRY R. STOEBNER DAVID E STUMBOS A PROFESSIONAL CORPORATION BY FACSIMILE MORGENSTEIN & JUBELIRER THE FEDERAL RESERVE BANK BUILDING 101 MARKET STREET, SIXTH FLOOR SAN FRANCISCO, CALIFORNIA 94105 (415) 896-0666 FAX (415)896-5592 July 26, 1989 Ms. Jackie Goldsby Kazan & McClain 171 - 12th Street, Suite 300 Oakland, CA 94607 Re: ALAMEDA COUNTY (SHIPYARD AND APPLICATOR ASBESTOS CASES) INTERROGATORIES Dear Jackie: ' Pursuant to our conversation, Owens-Illinois is sending the answers to the interrogatories immediately to me. You have agreed to an extension to those answers to July 28, 1989. As soon as I receive the answers from Owens-Illinois, I will have those answers personally messengered to you on or before July 28, 1989. Very truly your, KG/ya:WPYXA-118 6600.0001 Karlin Gould cc: Federal Expressed to Jennifer Jones - Owen-Illinois MAAVlr* D MUMCCNSTEIN* ELiOf * JU0WRER thi, ann iiunttw;tx>n ltL\N L Burnt*** ICmtCY R WILLIAMS JAMKS R BALICII rocky n. unsuh MUURIC It anck* argaret fimker KOHCRTA NIOOL DEMPSTER KARUN COULD JENNTIT,* o HOLT KIMRTCN HOWE UBRY CLOWE JaMM L MtiCINNIS EUZABTTH MEYER ROBERT B MULLEN fcODKRT CBRIKN JONATHAN M. fERWOUS KERRY R STOntNKM DAVIT) L STUMBOS A PROFES5IONAI. (XIRW5RAT10N MORGENSTEIN & JUBELIRER THE FEDERAL RF.SF.RVE BANK BUILDING 101 MARKET STREET, SIXTH FLOOR SAN FRANCISCO, CALIFORNIA 94105 (415) 896-0666 FAX (415) 896-55*12 July 26, 1989 BY.FACSIMILE Ms. Jackie Goldsby Kazan & McClain 171 - 12th Street, Suite 300 Oakland, CA 94607 Re: ALAMEDA COUNTY (SHIPYARD AND APPLICATOR ASBESTOS CASES) INTERROGATORIES Dear Jackie: Pursuant to our conversation, Owens-Illinois is sending the answers to the interrogatories immediately to me. You have agreed to an extension to those answers to July 28, 1989. As soon as I receive the answers from Owens-Illinois, I will have those answers personally messengered to you on or before July 28, 1989. Very tr ly your. Karlin Gould KG/ya:WPYXA-118 6600.0001 cc: Federal Expressed to Jennifer Jones - Owen-Illinois *+ TOTAL PAGE . 02 m