Document MGaMk4wRKpKRxX2awQ3dnORGy
FILE NAME: Shree Digvijay (SDV) DATE: 1980
DOC#: SDV017
DOCUMENT DESCRIPTION: Legal - Plaintiffs' Interrogatories to Defendant, J-M Sales Corp.
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
IN RE: ASBESTOSIS CASES
t
CIVIL ACTIONS NOS.
) CV479-267, CV479-313 /
) CV479-332, CV479-312 /
)
CV 47 9-362, CV479-327 f
)
CV479-334, CV 480-9 7 ,
)
CV480-131, CY480-130 1
)
CV 48 0-182 , CV480-192
)
CV 480-196 , CV480-197
)
CV 480-204 , CV480-235
) CV 480-236 , CV 480-237
)
CV 480-238 , CV480-243 1
) CV 480-281 ,
PLAINTIFFS' INTERROGATORIES TO DEFENDANT, JOHNS-MANVIDLE SALES CORPORATION
TO: Defendant and its counsel of record
The following interrogatories are herewith served upon you under the provisions of Rule 33, Federal Rules of Civil Procedure, You are required to answers these Inter rogatories separately, fully, in writing under oath, and to setve a copy of your answers upon tne u.:Jersrgned within thirty (30) days from the date of service hereof.
All of the following interrogatories shall be continuing in nature until the date of trial, and you are required to submit supplemental answers, pursuant to Rule 26(e)., Federal Rules of Civil Procedure, as additional information may become available to you. These interroga tories are served upon you this J> tfd- day of ^ " ) c ' 19.8 0 ,
V-
ADDRESS;
P, 0, Bojc 1Q0 06 Savannah, Georgia 31412 (912) 234-1133
Richard H. Middleton, Jr. Attorney for Plaintiffs
1. What percentage of the Shree Divijay Cement Company, located in Ahmedabad, India, is presently or has ever been previously owned in whole or in part by JohnsManville Sales Corporation and/or any subsidiary and/or any related entity thereof?
2. Has Johns-Manvilie Sales Corporation, or any subsidiary and/or related entity thereto,, ever required any interest of any size or type in the assets of the Shree Divijay Cement Company, Ahmedabad, India?
3. If the answer to interrogatory #2 is yes, please state with particularity:
(a) The tvpe of interest :n the three plants presently or previously held by the JohnsManville Sales Corporation;
(b) The amount or percentage of said interest; (c) The date of the acquisition or realization of each and every type of interest, past and/or present; (d) The dates that any interests were either divested and/or sold and the amounts of those interests so divested and/or sold. 4. Has Johns-Manville Sales Corporation ever had an agreement with Shree Divijay to be the selling agent for some or all of its asbestos products exported to Africa and the Middle East? 5. If the answer to interrogatory #4 is affirmative, what are the terms of this agreement, and if this agreement has recently lapsed, state when and under what circumstances this occurred? 6. Did Johns-Manville Sales Corporation provide technical assistance in the design and supervise the con struction of the Shree Divijay Cement Company in Ahmedabad, India in 1962?
7. Does the Shree Divijay Cement Company in Ahmedabad, India have expansion plans?
8. If the answer to interrogatory #7 is in the affirmative, please state with particularity any details of such expansion plans and by whom these decisions were made including, but not limited to, names, addresses, titles and length of employment with Johns-Manville..
9. Has Johns-Manville provided Shree Divijay at any time since Shree Divijay's construction with raw asbestos fiber? If the answer is affirmative, specify the amount of fiber per year in tons and indicate the total price?
10. Has Johns-Manville implemented a policy on the sale of asbestos with regard to ohe documented health hazards?
11. If the answer to interrogatory #10 is affirmative, please state the nature and extent of such a policy, note key persons responsible and their position in the firm and indicate when and from what source these persons responsible for said policy knew the necessity for its implementation.
12. What precautionary measures were and presently are employed to assure that the fibers produced by Shree
will be properly and safely used? Does the policy implemented by Johns-Manville recognize the necessity to take protective measures associated with fiber use?
13. Has Johns-Manville taken any action to halt the sales of asbestos fibers to customers?
14. Has Johns-Manville ever licensed technology to Shree Divijay?
la. Does Johns-Manvr 1 It' comply with Unxted Stares regulations for limiting air pollution and water pollution from its asbestos operations jn the U.S.?
16. Does Johns-Manville comply with federal, state and local laws and regulations governing the proper disposal, isolation and burying of asbestos waste?
17. If the answer to interrogatory #16 is affirmative,
please attach the proper documentation to support your
answer. 10. Has Johns-Manville made it a standard practice
of attaching warning labels on its packages and sacks of
asbestos sold to Shree Divijay? if so, state the design of
the label., what language the warning is printed in and if
pictorial warnings are used.
19.
Has Johns-Manville ever attempted to insure
that asbestos sold to Shree Divijay is properly handled and
disposed of and what documentation exists to support an
affirmative response?
-
20. Describe what actions have been tciken directed
to Johns-Manville and/or Sh;_ee Divijay as a result of Mr.
Barry Castleman's exposure of pictures of the Shree Diguijay
Cement Company to Dr. Paui Kotin.
21. Do products exported by Shree Divijay to
Africa and the Middle East contain warning labels about the
hazards of asbestos?
22. If the answer to interrogatory #21 is affirmative t when was such a warning label introduced, what does it
contain and what language is it in? Are pictorial warnings
used on the products exported?
ADDRESS:
P. 0. Box 100Go Savannah, Georgia 31412 (912) 234-1133
Richard H. Middleton, Jr. Attorney for Plaintiffs
- 3-