Document MMb4vDr4bqMN0rGxmqz71Ee3V

CAUSE NUMBER IN RE: ASBESTOS LITIGATION BARON & BUDD IN THE DISTRICT COURT OF BEXAR COUNTY, TEXAS __ _____ JUDICIAL DISTRICT DEFENDANT NORTH AMERICAN REFRACTORIES COMPANY'S RESPONSES TO INTERROGATORIES AND REQUESTS FOR PRODUCTION Pursuant to the Texas Rules of Civil Procedure, Defendant North American Refractories Company files the attached resonses to Interrogatories and Requests for Production. Respectfully submitted, POWERS & FROST, L.L.P. James H. Powers 17 State Bar No. 16217400 Sharia J. Frost ' State Bar No. 07491100 24 Greenway Plaza, Suite 2020 Houston, Texas 77046 Telephone: (713)961-2800 Telecopier: (713)961-5090 ATTORNEYS FOR DEFENDANT NORTH AMERICAN REFRACTORIES COMPANY CERTIFICATE OF SERVICE This is to certify that a true and correct copy of Defendant North American Refractories Company's Responses to Interrogatories and Request for Production has been forwarded to ail counsel of record, certified mail, return receipt requested, this Afi day of fhj- , 1994. Sharia J. Frost CAUSE NO. BARON & BUDD IN THE DISTRICT COURT OF IN RE: ASBESTOS LITIGATION BEXAR COUNTY, TEXAS JUDICIAL DISTRICT INTERROGATORIES INTERROGATORY NCL 1: State the name, address, job title, length of time employed by Defendant, and a yearby-year list of all other positions, titles, or lobs held when working for Defendant of each person who has supplied any information used in answering these interrogatories. ANSWER: 1. Anthony Rosa Vice President of Human Resources 1228 Euclid Avenue, 5th Floor The Halle Building Cleveland, Ohio 44115 2. Don Abrino Human Relations and Safety Coordinator North American Refractories Company 3127 Research Drive State College, Pennsylvania 16801 3. Richard Landy (Former) Vice President of Technology North American Refractories Company 3127 Research Drive State College, Pennsylvania 16801 4. Curtis Horton (Former) Industrial Hygienist North American Refractories Company 3127 Research Drive State College, Pennsylvania 16801 5. George Spahlinger (Former) Manager of Account Representatives Sales Marketing Department North American Refractories Company 1228 Euclid Avenue, 5th Floor The Halle Building Cleveland, Ohio 44115 6. Jay Ehle General Counsel and Secretary North American Refractories Company 1228 Euclid Avenue, 5th Floor The Halle Building Cleveland, Ohio 44115 Further information regarding the length of employment and other titles, positions or jobs held by the aforementioned people is being compiled and will be made available for inspection upon reasonable notice. INTERROGATORY NO. 2: State whether or not you are a corporation. If so, state your correct corporate name, the state of your incorporation, the address of your principal place of business, the name and address of the person or entity authorized to accept service of process on your behalf, and whether or not you have ever held a Certificate of Authority to do business in the State of Texas. ANSWER: Yes, North American Refractories Company is incorporated in the State of Ohio. It has a principal place of business in Ohio at 1228 Euclid Avenue, 5th Floor, The Halle Building, Cleveland, Ohio 44115, and has conducted business in the state of Texas. CT Coip. ^authorized to accept service on our behalf. INTERROGATORY NO. 3: Has Defendant or any of its predecessor or subsidiary companies at any time engaged in the mining and subsequent sale of material containing asbestos fibers? If so, identify the location of the mine(s), the years of its operation, the type of asbestos mined and whether you sold any asbestos to any Defendants in the Bexar County asbestos litigation. ANSWER: No. ,_ INTERROGATORY NO. 4: Identify by name each product containing asbestos fibers that Defendant or any of its predecessor or subsidiary companies at any time manufactured or sold. ANSWER: See Exhibit "A" and North American Refractories Company's Product Catalog which is available for inspection and copying upon reasonable notice. 2 INTERROGATORY NO. 5: Identify by name each product containing asbestos fibers that Defendant or any of its predecessor or subsidiary companies at any time marketed or sold. ANSWER: See Exhibit "A" and North American Refractories Company's Product Catalog which is available for inspection and copying upon reasonable notice. INTERROGATORY NO. 6: If the answer to one or more of the last three interrogatories is in the affirmative or lists any products, state as to each named product the following: (a) As to each product, state whether such product was mined, manufactured, marketed, and/or sold. (b) The names of the companies mining, manufacturing, marketing, and/or selling each product mined, manufactured, marketed, and/or sold. (c) The trade or brand name of each of those products mined, manufactured, marketed and/or sold. (d) The date each of the named products was placed on the market. (e) A description of the physical (chemical) composition of each of the named products, including the type of asbestos contained in the product and the percentage of asbestos put in each product. (f) The date each of the products was removed from the market and no longer sold or distributed and the reason or reasons therefor. (g) The date asbestos was removed from such products, if ever, and the reasons therefor. (h) A description of the physical appearance of each of the named products. (i) A detailed description of the intended uses of the named products. (j) Identify the last year that you sold each asbestos-containing product. ANSWER: See Exhibit "A" and North American Refractories Company's Product Catalog which is available for inspection and copying upon reasonable notice. 3 INTERROGATORY NO. 7: Do any documents, including but not limited to written memoranda, specifications, recommendations, blueprints, or other written materials of any kind or character, relating to the design, preparation, or introduction into the market of the products listed in Interrogatory No. 6 still exist? If so, state: (a) A description of each such document. (b) ANSWER: The name, address, and job title of each person who currently has possession of each document, and where the documents are currently located. Some documents, such as Material Safety Data Sheets (MSDS) and what are referred to as "mix sheets", may contain information related to the design, preparation and specifications of the products listed in response to Interrogatory No. 6. Any such documents which still exist are in tne custody of Donald Abrino, Human Relations and Safety Coordinator, North America an Refractories Company, 3127 Research Drive, State College, Pennsylvania 16801. INTERROGATORY NO. 8: Before distributing, selling, or placing the products listed in your responses to Interrogatory Nos. 3-6 into the streams of commerce, were any tests conducted to determine potential health hazards involved in the use of, or exposure to, the materials such as asbestos, contained in those products? If the answer is affirmative, state: (a) The names of the products tested and the date of each test. <b) The name, address, and job title of each person conducting the tests or involved with conducting the tests. (c) The results of the tests. ANSWER: This defendant had no reason to believe that there were potential health hazards associated with its few asbestos containing products due to their small asbestos component, their use primarily in wet or encapsulated forms, and their use by industrial customers who were aware of safety precautions; therefore, it had no reason to believe such tests were required and none were done. 4 INTERROGATORY NO. 9: Do any documents, including but not limited to written memoranda, specifications, recommendations, blueprints, or other written materials of any kind or character, relating to the testing of the products referred to in Interrogatory No. 6 now exist? If so, state: (a) A description of each such document. (b The name, address, and job title of each person who currently has possession of each document, and where it is presently located. ANSWER: This defendant had no reason to believe that there were potential health hazards associated with its few asbestos containing products due to their small asbestos component, their use primarily in wet or encapsulated forms, and their use by industrial customers who were aware of safety precautions; therefore, it had no reason to believe such tests were required and none were done. INTERROGATORY NO, 10: Did Defendant or any of its predecessor or subsidiary companies make any design changes or modifications as a result of those tests described in responses to Interrogatory No. 8? If the answer is affirmative, state: (a) The trade names of the products changed. (b) The nature of the changes made and the date of such changes of modifications. (c) The name, address, and job title of each person responsible for having caused a change to be made, or having made a change or modification. ANSWER: This defendant had no reason to believe that there were potential health hazards associated with its few asbestos containing products due to their small asbestos component, their use primarily in wet or encapsulated forms, and their use by industrial customers who were aware of safety precautions; therefore, it had no reason to believe such tests were required and none were done. INTERROGATORYNO.il: After releasing the products listed in Interrogatory No. 6 to the public, were any tests conducted on them to determine potential health hazards resulting from the use of or exposure to the materials, such as asbestos, contained in those products? If the answer is affirmative, state: (a) The names of the products tested and the dates of such tests. (b) The name, address, and job title of each person who conducted those tests. (c) The results of those tests. (d) Whether, as a result of the tests, any products were removed from the market. 5 (e) The names of all products removed from the market as a result of these tests. ANSWER: This defendant had no reason to believe that there were potential health hazards associated with its few asbestos containing products due to their small asbestos component, their use primarily in wet or encapsulated forms, and their use by industrial customers who were aware of safety precautions; therefore, it had no reason to believe such tests were required and none were done. INTERROGATORY NO. 12: Do any documents, including written memoranda, specifications, recommendations, blueprints, or other written materials of any kind or character, relating to the potential health hazards of the products listed in Interrogatory No. 6 now exist? If so, state: (a) The name of each product. (b) A description of each document and how it relates to each product. (c) ANSWER: The name, address, and job title of each person who currently has possession of each document, and where it is presently located. North American Refractories Company does not have any documents which relate to any health hazards associated with the specific products it manufactured. The few asbestos containing products which North American Refractories Company manufactured had a small asbestos content, were used primarily in wet or encapsulated forms, and were used by industrial customers who were aware of safety precautions; therefore, this defendant had no reason to believe any potential health hazards existed. INTERROGATORY NO. 13: Did Defendant or any of its subsidiary companies make any design changes as a result of the tests discussed in your response to interrogatories No. iO or 13? If the answer is affirmative, state: (a) The names of the products changed or modified. (b) The name, address, and job title of each person responsible for having made a change or modification. (c) The nature of the hazard or defect which resulted in such change or modification. ANSWER: This defendant had no reason to believe that there were potential health hazards associated with its few asbestos containing products due to their small asbestos component, their use primarily in wet or encapsulated forms, and their use by industrial customers who were aware of safety precautions; therefore, it had no reason to believe such tests were required and none were done. 6 INTERROGATORY NO. 14: Has Defendant or any of its predecessor or subsidiary companies at any time published or distributed any printed material, including brochures, pamphlets, catalogs, packaging or other written material or any kind or character containing any warnings concerning the possibility of injury resulting from the use of the asbestos-containing products listed in Interrogatory No. 6/ If so, state: (a) The names of each relevant product. (b) The exact wording of each warning, statement on each printed material. (c) A description of the printed material other than the warning statement. (d) The method used to distribute the warning to persons likely to use the product. (e) The date each warning was first issued, distributed, or placed on packaging. (f) The name, address, and job title of each person responsible for having drafted or issued die warning. (g) The current location of any such printed material and the custodian thereof. (h) ANSWER: The form in which such literature or printed material can be accessed, i.e.. the manner in which such literature is indexed or stored. North American Refractories Company disseminated printed material concerning the general use and application of its refractory products to its customers. No brochures or other printed material were distributed concerning the alleged "possibility of injury" from the use of any North American Refractories Company products because there was no reason to believe that health hazards were associated with products that had such a small percentage asbestos component and were designed for use in a wet or encapsulated form. Further, the characteristics of all or the products were known by our customers, who were usually large industrial concerns with sophisticated purchasing abilities and an opportunity to provide a safe work place for their employees. 7 INTERROGATORY NO. 15: Before 1970, had you received notice that any individual or individuals, other than those Plaintiffs who have filed personal injury actions in Texas State Courts is or are claiming or has or have claimed an injury as a result of using asbestos products manufactured and/or sold by your company or any of its predecessors or subsidiaries before 1970? If so, state: (a) The name and address of each claimant. (b) The date of notice of each claim. (c) A description of the claim. (d) The type of injuries allegedly sustained. (e) The name and. address of each attorney who represents each individual making a claim. (f) The style and court number of each claim. (g) ANSWER: The disposition of each claim that has been settled or taken to judgment. No. INTERROGATORY NO. 16: Were your asbestos products distributed, marketed, packaged, labeled and/or sold by companies other than your own? If the answer is affirmative, list the names and addresses of each of those companies, and the products in question. ANSWER: North American Refractories Company had distributors responsible for the sale of its products throughout the United States. The distributors have naturally changed from time to time over a substantial number of years. Because of the enormous task required to answer this interrogatory (i.e. a complete search of records for all distributors throughout the country and each product sold by them), this list is still being compiled and will be made available for inspection upon reasonable notice. * 8 INTERROGATORY NO. 17: Did you or any of your predecessors, successors, or subsidiaries have any distributors or sales representatives of asbestos products in the States of Alabama, Florida, Mississippi, Oregon, Washington, Georgia, Tennessee, Arkansas, Texas and Virginia? If so, state: (a) The name and address of each such distributor or sales representatives. (b) The years in which such company or person distributed, marketed, or sold your products. (c) ANSWER: What products were distributed, marketed, or sold and in what years. North American Refractories Company had distributors and/or sales representatives responsible for the sale of its products in the states referenced. The distributors and/or sales representatives nave naturally changed from time to time over a substantial number of years. Because of the enormous task required to answer this interrogatory (i.e. a complete search of records for all distributors and sales representatives in the above-named states and a yearly account of each product sold or distributed by each distributor and sales representative), this list is still being compiled and will be made available for inspection upon reasonable notice. INTERROGATORY NO. 18: List each employee (including only physicians and/or hygienists) who has acted in a medical advisory-capacity to your company at any time during the past 40 years, including, but not limited to, physicians and industrial hygienists, and the current address, telephone number and job title of each of those individuals and who has, had or may have had any knowledge regarding the hazards of asbestos. ANSWER: North American Refractories Company never had a medical department. During the time period relevant to the instant actions, Curtis Horton, Curwensville, Pennsylvania was responsible for developing and implementing industrial hygiene and safety programs. Kim Nelson, Curwensville, Pennsylvania is the current Manager ofHealth and Safety. 9 INTERROGATORY NO. 19: Does Defendant have in its possession any books, pamphlets, memoranda, or written materials of any kind or character that would indicate that asbestos fibers, when inhaled, can be hazardous to the health of human beings? If so, state: (a) The name of each such publication. (b) The date of publication and the names of the author and publisher (if any). (c) The date received by Defendant, if known. (d) ANSWER: The name, job title, and address of each person who currently has possession of each publication and its present location. Information regarding the potential health hazards of asbestos exposure has been learned from tne news media and other sources available to the general public including OSHA and NIOSH. North American Refractories Company is unable to specify precisely when or from where it learned of potential hazards; however, this knowledge has been gained gradually over the past several years. INTERROGATORY NO. 20: Has Defendant or any of its subsidiary or predecessor companies at any time been a member of any trade organization or association that published or disseminated any documents or information relating to the hazards of asbestos comprised of other manufacturers, miners, marketers, and/or*sellers of asbestos products If so, state: (a) The name and address of each such association or organization. (b) The dates during which Defendant or any of its subsidiaries or predecessors were members. (c) The names and dates of any publications, minutes, or reports published, written, or disseminated by any of the named associations or organizations. (d) Whether any of those publications are still in your possession, and if so: (i) A description of the publications, including the date. (ii) The current location of such publications. (iii) The custodian of such publications. (iv) The method or manner in which sueh publications are maintained. ANSWER: No, North American Refractories Company is not aware of any trade organization or association specifically comprised of "manufacturers, miners, marketers, and/or sellers** of asbestos containing products. 10 INTERROGATORY NO. 2h Identify by name and location each plant or manufacturing facility in which the products listed in your answers to Interrogate!^ 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: See Exhibit A INTERROGATORY NO. 22: Have printed sales materials been prepared by Defendant or any of its subsidiary or predecessor companies or their agents for purposes of marketing or advertising products containing asbestos? If so, state: (a) The name, address, and job title of each person or entity who prepared such materials. (b) The name, address, and job title of each person who currently has possession of such materials and their present location. (c) The date the materials were prepared. (d) The media used to disseminate the sales materials. ANSWER: Yes, North American Refractories Company, like most companies, has from time to time advertised the products it manufactured. Complete records have not-been kept of such advertisements; however, defendant generally advertised its refractory products in the following magazines and/or trade publications: 1. Foundry 2. Rock Products 3. Industrial Heating 4. Iron Age 5. Iron and Steel Engineers 6. Iron and Steelmaking 7. Pit and Quany 8. "33" 9. Electric-Light and Power 10. Journal of Metals 11. Modem Castings 12. Blast Furnace and Steel Plant 13. Ceramic Industry 14. Brick and Clay Records r. Records reflecting the name, address and job title of each person who played a role in the preparation of each advertisement and specific dates of preparation have not been kept. However, Randy Lund, Market Manager, international, of Iron and Steel, played a role in the preparation of such materials. If any such materials still exist, they would be in the custody of Jay Ehle, Secretary of North American Refractories Company, 1228 Euclid Avenue, 5th Floor, The Halle Building, Cleveland, Ohio 44115. 11 INTERROGATORY NO. 23; Have any written or printed materials or instructions of any kind or character been prepared by Defendant or any of its subsidiary or predecessor companies or their agents indicating how asbestos products should be used and maintained. If so, state: (a) The name, address, and job title of each person who prepared such materials or instructions or assisted in their preparation. (b) The name, address and job title of each person who currently has possession of such materials or instructions and their present location. (c) The dates of distribution or use and the manner in which such materials or instructions were distributed to purchasers of Defendant's products or those of its subsidiaries or predecessors. (d) The year each such written material or instruction was prepared and disclosed to potential consumers. ANSWER: As a general business practice, North American Refractories Company would provide instructions to large industrial customers on the uses and applications of refractory products. However, no records were kept with regard to specific instructions given, persons giving instructions, job titles of instructors and specific dates instructions were given. INTERROGATORY NO. 24: Does Defendant have insurance policies that might cover the claims made by Plaintiffs in these cases. If so, list the name of each insurance carrier, the amount of initial coverage, amount of coverage remaining at the present time, and the effective dates of each policy. (If properly answered, this Interrogatory need not be supplemented as to the remaining amount of coverage). ANSWER: Yes, North American Refractories Company has such policies, but objects to this interrogatory because it calls for information regarding confidential agreements among its insurance carriers. Without waiving this objection, defendants states that it is adequately insured with respect to plaintiffs' claims. 12 INTERROGATORY NO. 25: As to the disease asbestosis, state: (a) The date on which Defendant or its subsidiary or predecessor first learned that such disease was caused by inhalation of asbestos fibers by humans. (b) How Defendant became aware of the existence of the disease. (c) Who within the company first discovered, recognized or understood the adverse consequences or effects of the disease and/or of asbestos exposure. (d) What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. (e) Whether any such information is still maintained by Defendant or its subsidiary or predecessor in any written form. (f) Who is the custodian of such information. (g) The date on which you first received knowledge or information that asbestosis was caused by inhalation of asbestos fibers. ANSWER: North American Refractories Company has no information evidencing precisely when the potential health hazards from certain types of exposures to asbestos were first learned; however, this knowledge has been gained gradually over the past several years. This defendant learned of various potential health hazards associated with exposure to asbestos from the news media and other sources available to the general public, including OSHA and NIOSH publications. Further, North American Refractories Company has no information evidencing precisely who within the company first "discovered, recognized or understood" the potential adverse effects of asbestos exposure and cannot presently speculate as to whether or not its employees once had certain information or understanding on this issue. Any information associated with this defendant's gradual accumulation of knowledge on this topic which still exists would be possessed by Kim Nelson, Manager of Health and Safety, 3127 Research Drive, State College, Pennsylvania 16801. 13 INTERROGATORY NO. 26: As to the disease lung cancer, state: (a) The date on which Defendant or its subsidiary or predecessor first learned that such disease was caused by inhalation of asbestos fibers by humans. (b) How Defendant or its subsidiary or predecessor became aware of the disease and its relationship to asbestos exposure. (c) Who within the company or its subsidiary or predecessor first discovered or recognized the adverse consequences or effects of asbestos exposure. (d) What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. (e) Whether any such information is still maintained by Defendants or its subsidiaries or predecessors in a written form. (f) Who is the custodian of such information. (g) The date on which you first received knowledge or information that lung cancer was caused by inhalation of asbestos dust and fibers. ANSWER: North American Refractories Company has no information evidencing precisely when the potential health hazards from certain types of exposures to asbestos were first learned; however, this knowledge has been gained gradually over the past several years. This defendant learned of various potential health hazards associated with exposure to asbestos from the news media and other sources available to the general public, including OSHA and NIOSH publications. Further, North American Refractories Company has no information evidencing precisely who within the company first "discovered, recognized or understood" the potential adverse effects of asbestos exposure and cannot presently speculate as to whether or not its employees once had certain information or understanding on this issue. Any information associated with this defendant's gradual accumulation of knowledge on this topic which still exists would be possessed by Kim Nelson, Manager of Health and Safety, 3127 Research Drive, State College, Pennsylvania 16801. 14 i INTERROGATORY NO. 27: As to pleural disease, pleural thickening or pleural plaques, state: (a) The date on which Defendant or its subsidiary or predecessor learned such disease was caused by inhalation of asbestos fibers by humans. (b) How Defendant or its subsidiary or predecessor became aware of the disease and that it was caused by exposure to asbestos. (c) Who within the company or its -subsidiary or predecessor first discovered or recognized the adverse consequences or effects of asbestos exposure. (d) What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. (e) Whether any such information is still maintained by Defendant or its subsidiary or predecessor in a written form. (f) Who is the custodian of such information. ANSWER: North American Refractories Company has no information evidencing precisely when the potential health hazards from certain types of exposures to asbestos were first learned; however, this knowledge has been gained gradually over the past several years. This defendant learned of various potential health hazards associated with exposure to asbestos from the news media and other sources available to the general public, including OSHA and NIOSH publications. Further, North American Refractories Company has no information evidencing precisely who within the company first "discovered, recognized or understood" the potential adverse effects of asbestos exposure and cannot presently speculate as to whether or not its employees once had certain information or understanding on this issue. Any information associated with this defendant's gradual accumulation of knowledge on this topic which still exists would be possessed by Kim Nelson, Manager of Health and Safety, 3127 Research Drive, State College, Pennsylvania 16801. 15 INTERROGATORY NO. 28: As to the disease mesothelioma, state: (a) The date on which Defendant or its subsidiary or predecessor first learned such disease was caused by inhalation of asbestos fibers by humans. (b) The date on which Defendant first suspected that mesothelioma was caused by inhalation of asbestos dust and fibers. (c) How Defendant or its subsidiary x>r predecessor became aware of the disease and that it was caused by exposure to asbestos. (d) Who within the company or its subsidiary or predecessor first discovered or recognized the adverse consequences or effects of asbestos exposure. (e) What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. (f) Whether any such information is still maintained by Defendants or its subsidiary or predecessor in a written form. (g) Who is the custodian of such information. (h) Whether Defendant agrees that there is no known medical cure for mesothelioma. ANSWER: North American Refractories Company has no information evidencing precisely when the potential health hazards from certain types of exposures to asbestos were first learned; however, this knowledge has been gained gradually over the past several years. This defendant learned of various potential health hazards associated with exposure to asbestos from the news media and other sources available to the general public, including OSHA and NIOSH publications. Further, North American Refractories Company has no information evidencing precisely who within the company first "discovered, recognized or understood" the potential adverse effects or asbestos exposure and cannot presently speculate as to whether or not its employees once had certain information or understanding on this issue. Any information associated with this defendant's gradual accumulation of knowledge on this topic which still exists would be possessed by Kim Nelson, Manager of Health and Safety, 312? Research Drive, State College, Pennsylvania 16801. 16 IfflERROGATORY NQ. 29' As to gastro-intestinal cancer, laryngeal cancer, pharyngeal cancer or lymphatic cancer, state: (a) The type of cancer and the date on which Defendant or its subsidiary or predecessor first learned that such diseases were caused by inhalation of asbestos fibers by humans. (b) What cancers has the Defendant or its subsidiary or predecessor become aware can be caused by exposure to asbestos fibers? (c) The date on which Defendant first suspected other cancers were caused by asbestos inhalation. (d) Who within the company or its subsidiary or predecessor first discovered the adverse consequences or effects of asbestos exposure. (e) What information was disseminated with Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. (f) Whether any such information is still'maintained by Defendant or its subsidiary or predecessor in a written form. (g) Who is the custodian of such information. ANSWER: North American Refractories Company has no information evidencing precisely when the potential health hazards from certain types of exposures to asbestos were first learned; however, this knowledge has been gained gradually over the past several years. This defendant learned of various potential health hazards associated with exposure to asbestos from the news media and other sources available to the general public, including OSHA and NIOSH publications. Further, North American Refractories Company has no information evidencing precisely who within the company first "discovered, recognized or understood" the potential adverse effects or asbestos exposure and cannot presently speculate as to whether or not its employees once had certain information or understanding on this issue. Any information associated with this defendant's gradual accumulation of knowledge on this topic which still exists would be possessed by Kim Nelson, Manager of Health and Safety, 3127 Research Drive, State College, Pennsylvania 16801. 17 INTERROGATORY NO. 30: Does Defendant contend that asbestos products can be manufactured or designed so as to eliminate all potential health hazards to persons working with or exposed to them? If the answer is affirmative, explain in detail, and attach any studies or surveys on which this answer is based. ANSWER: Yes, Defendant contends that its asbestos containing products were designed and manufactured in such a manner because .its products had a small asbestos component, were used primarily in wet or encapsulated forms, and were used in and around high heat areas which changed their asbestos content into nonasbestos forsterite. INTERROGATORY NO. 31: Describe in detail the types of packages or packaging which Defendant or any of its subsidiary or predecessor companies used for asbestos matenal or products, listing the dates each type of package was used, a physical description of each type of package, and providing a description of any printed material or trademarks that appeared thereon. ANSWER: See North American Refractories Company's product catalog which is available for inspection or copying upon reasonable notice. INTERROGATORY NO. 32: Has Defendant or any of its subsidiary or predecessor companies at any time entered into a "rebranding" agreement with any other company, either as buyer or seller, concerning asbestos materials or asbestos products? If so, state, as to each such agreement. (a) The name of the company manufacturing the asbestos products. (b) The trade name affixed to those products. (c) The periods of time covered by each such agreement. (d) The volume, in dollar amount, of each transaction. (e) The initial purchaser of the products. ANSWER: See Exhibit "A". INTERROGATORY NO. 33: . List the name and address of each company from which Defendant or its subsidiary or predecessor purchased materials or asbestos products which Defendant sold or distributed in any form, stating the form of the materials, the dates of such purchases, and the ultimate disposal of such materials. ANSWER: North American Refractories Company purchased chrysotile asbestos from Nicolet and Johns-Manville. Records of specific purchase dates were not kept; however, purchases of chrysotile would correspond with the years in which a few of defendant's products contained asbestos. 18 INTERROGATORY NO. 34: Does Defendant or any of its subsidiaries or predecessor currently have possession of any writings or contracts on those rebranding agreements set forth in the answer to Interrogatory No. 32 If the answer is affirmative, state: (a) The name, address, and job title of each person having custody of each of those documents and their current location. (b) A brief description of each such document, including the dates and the parties signatory. ANSWER: No. INTERROGATORY 35: Prior to 1968, did any person file a claim against a Worker's Compensation carrier covering Defendant or any of its subsidiaries or predecessors alleging that he/she contracted a disease from inhaling asbestos fibers? If so, provide: (a) A list of the claims, including each claimant's name, address and the date each claim was filed, and including the caption and jurisdiction of the claim. (b) The disease alleged in each such claim. (c) A brief summary of the disposition of each such claim. (d) ANSWER: The name, address and title of the person having custody of the records pertaining to each such claim. No. INTERROGATORY NO. 36: Did Defendant or any of its subsidiaries or predecessors maintain written minutes of corporate meetings, either board of directors, departmental, or otherwise, which reflect discussions pertaining to any subject matter related to asbestos, asbestos health hazards or asbestos products? If so, for each such set of minutes, state: (a) The dates of each such meeting. (b) The general subject matter discussed at ea^h. meeting. (c) Who was in attendance at each meeting. (d) Where and by whom the written minutes are presently maintained. (e) By whom the minutes were taken and put into final format. (f) Whether the minutes were abstracted and reports disseminated to other individuals, and if so, the names and job titles of those individuals. ANSWER: No. 19 INTERROGATORY NO. 37: Do you or any of your subsidiaries, including foreign business entities, currently manufacture any products containing asbestos? If so, state: (a) As to each product, whether such product is mined, manufactured, and/or marketed or sold. (b) The names and addresses of the companies- mining, manufacturing, marketing, and/or selling each of those products. (c) The trade or brand name of each of those products mined, manufactured, marketed, and/or sold. (d) The date each of the named products was placed on the market. (e) A description of the physical (chemical) composition of each of the named products, including the type of asbestos contained in the product. (f) A description of the physical appearance of each product and its packaging. (g) (h) ANSWER: A detailed description of the intended-uses of each of the named products. Whether there are any warning labels on said products or containers regarding potential asbestos-related health hazards. No. INTERROGATORY NO. 38: State whether you or any of your predecessors and/or subsidiaries maintain, from 1940 through the present or for any portion thereof, copies of invoices, shipping documents, bills of lading, purchase orders, or other documents pf a similar nature relating to the mining, manufacture, marketing, sale or distribution of asbestos products. If so, state: (a) The location of such documents. (b) The name and address of the custodian of the documents. (c) The format in which the documents are kept, i.e.. hard copy, microfilm, microfiche, etc. (d) ANSWER: In what form the documents can be accessed, i.e., by state, by product, etc., and if by product, whether kept according to asbestos or non-asbestos. North American Refractories Company retains copies of its sales orders at it Cleveland, Ohio offices. Jay Ehle, General Counsel and Secretary is the custodian of the documents. The documents are hard copy. The documents can only be accessed by location sold, not by product (and not according to asbestos content). 20 INTERROGATORY NO. 39: Will you call company representatives as witnesses at the trial of any of these cases? If so, list: (a) The name, address, and job title of each company representative who may be called. (b) A summary of the testimony expected to be-given by each such witness. (c) List any and all previous times that the named witnesses have either given deposition or trial testimony in an asbestos-related case, including the jurisdiction, style of the case, case number, date of testimony, and the name of the attorney taking the deposition for the Plaintiffs in that case. ANSWER: North American Refractories Company has not determined the identity of the witnesses it will call at the time of trial of these cases. However, North American Refractories Company may call the following company representatives as witnesses at the trial of these cases: a. R. C. Crosson (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 b. James Rowles (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 c. Charles Thompson (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 d. J. L. Caldwell (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 e. J. B. Poison (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 f. S. J. Metzer, Jr. (former employee) 200 Hightower Office Building Suite 401 Pittsburg, PA 15205 g. T. M. Doty (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 21 h. Carl E. Stahl, Jr. (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 i. D. E. Varanese (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 j. J. M. Campanelli (former employee) The Halle building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 k. H. P. Sullivan (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 l. John Scanlon The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 m. E. S. Chrzan (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 n. Richard Wilson 200 Hightower Office Building Suite 401 Pittsburgh, PA 15205 o. George Spahlinger (former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 p. V. R. Bruncak(former employee) The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 q. Jay Ehle The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 r. Donald Abrino Technical Center 3127 Research Drive State College, Pennsylvania 22 s. James Uchno Technical Center 3127 Research Drive State College, Pennsylvania t. Richard Landy (former employee) Princeton Drive State College, Pennsylvania u. Curt Horton (former employee) Technical Center 3127 Research Drive State College, Pennsylvania v. Larry Dilley The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115-1809 w. Ronald Coleman (former employee) P. O. Box 38 Wolmesdorf, Pennsylvania x. James Stevens P. O. Box 38 Wolmesdorf, Pennsylvania y. Robert Whitford (former employee) North American Refractories Company Curwensvile, Pennsylvania z. Kim Nelson Manager of Health and Safety North American Refractories Company 3127 Research Drive State College, Pennsylvania 16801 The named witnesses will testify as to design, manufacture, sales, uses, contents, and safety of North American Refractories Company refractory products. Prior testimony by company representatives: * 23 Narco Witness Deposed Edmund S. Wright Richard Wilson (District Sales manager) George Spahnnger (Manager Account Representative) George Spahnnger (Manager Account Representative Thomas Robbins (District Manager) Kim Nelson (Manager Health & Safety) Curtis Horton (Former Industrial Hygienist) Donald E. Abrino (Human Relations and Safety Coordinator) Richard A. Landy (Director of Research) Richard A. Landy (Director of Research Richard A. Landy (Director of Research Jurisdiction Madison Co., IL Allegheny Co., PA Cuyahoga Co., Madison Co., IL Madison Co., IL Madison Co., IL Madison Co., IL Madison Co., IL Madison Co., IL Madison Co., IL Cambria Co., PA Case No. 86-L-1827 83-18704 1987-1 86-L-1827 86-L-1230 86-L-1827 86-L-1827 86-L-1872 All Asbestos Litigation' 86-L-1827 1987-71 Date 577755 1/22/85 1/27/88 8/30/8$ 3754789 8/30/89 8/30/89 8/30/89 7/26/88 9/7/88 4/20/88 Plaintiffs' Attorney Randall E. Bono William Caroselli Robert Jennings Randall E. Bono Randall E. Bono Randall E. Bono Randall E. Bono Randall E. Bono Fred Baron Fred Baron Robert Jennings Defendant may supplement this answer by supplementation of its discovery responses in individual lawsuits ana reserves the right to call such additional representatives who may have knowledge pertinent to a particular case. 24 INTERROGATORY NO. 4Q: Have Defendant or its subsidiaries or predecessors ever acquired through purchase, reorganization, or merger another corporation, company, or business which manufactured, sold, processed, distributed, or contracted or supplied products containing asbestos? If so, for each such entity, state: (a) Full and correct name; (b) Principal place of business; (c) State of incorporation; (d) Date of acquisition by Defendant; (e) ANSWER: Whether or not the business entity was ever authorized to transact business in the State of Texas; No. INTERROGATORY NO. 41: Was each of your asbestos products generally expected to reach, or packaged to reach, the consumer or user, without substantial change in the condition in which it was sold? If not, with respect to any such product, explain in wnat way the Defendant claims its products were altered or substantially changed after sale or distribution and before reaching the user. ANSWER: North American Refractories Company expected its products to reach its industrial customers without substantial change in the condition in which they were sold. With regard to the users of the products, since this defendant's refractory products had different installations and applications, North American Refractories Company needs further specification or the product and application to answer this question. INTERROGATORY NO. 42: For each asbestos-containing product identified in response to Interrogatory No. 6, identify all foreseeable users such as insulators, helpers, pipefitters, welders, machinists, Slasterers, drywall finishers, carpenters, boilermakers, shipwrights and riggers, etc. of any of defendant's asbestos-containing products. ANSWER: Bricklayers, bricklayers helpers and masonry laborers are foreseeable users of North American Refractories Company products. 25 INTERROGATORY NO. 43: Rased upon the material contents of your asbestos-containing products, the method of manufacturing, and the method of application, can such products be generally applied without liberating asbestos fibers into the air? (a) If there is a different answer concerning different products manufactured, sold, distributed, or used by your company, then specify the different products by precise manufacturer's name and popular name. (b) ANSWER: If there is a difference in your answer depending on the year or years in which a particular product was used, then specify in detail what year or years you are referring to and the specific products you are referring to and year involved. Yes. INTERROGATORY NO. 44: Was it a foreseeable use of your asbestos-containing products that they may have been removed, stripped, or replaced at some time after installation/ ANSWER: Since this defendant's refractory products were used for different installations, North American Refractories Company needs specification of the type(s) and purpose(s) of installation to which this interrogatory refers in order to answer this question. INTERROGATORY Np: 45: Before 1970, did you or your subsidiaries or predecessor(s) ever arrange for any labor inspectors, insurance company inspectors or anyone from your company to go to job sites where your products were being used or installed to make or take dust level counts? If so, state when this procedure started, the purpose of such procedures, and all results of such procedures. ANSWER: North American Refractories Company had no reason to believe that there were potential health hazards associated with its few asbestos containing products due to their small percentage asbestos content, their use primarily in wet or encapsulated forms, and their use by industrial customers who were aware of safety precautions; therefore, it had no reason to believe such tests were required and none were done. INTERROGATORY NO. 46: If Defendant performed or had performed any dust level counts, what action, based on the results, did your company take? ANSWER: North American Refractories Company had no reason to believe that there were potential health hazards associated with its few asbestos containing products due to their small percentage asbestos content, their use primarily in wet or encapsulated forms, and their use by industnal customers who were aware of safety precautions; therefore, it had no reason to believe such tests were required and none were done. 26 INTERROGATORY NO. 47: Has your company or its subsidiaries or predecessor(s) ever conducted or caused to be conducted any studies designed to assist in minimizing or eliminating the inhalation of asbestos dust and fibers by those exposed to the use of your company's products? If so, give the following: (a) Name of the person or firm conducting such studies; (b) The date the studies began and the date they were completed; (c) Any publication or other written dissemination of the results of the studies; (d) ANSWER: The nature of any action to eliminate or minimize the inhalation of asbestos dust fibers. North American Refractories Company had no reason to believe that there were potential health hazards associated with its few asbestos containing products due to their small percentage asbestos content, their use primarily in wet or encapsulated forms, and their use by industrial customers who were aware of safety precautions; therefore, it had no reason to believe such tests were required and none were done. INTERROGATORY NO. 48: Does your company have, has it ever had, or have your predecessor(s) or subsidiaries ever had, a Research Department? If so, give the year sucn Research -Department was established, and whether or not such Research Department has operated continuously since being established. State also: (a) The amount of time and money expended each year on research concerning asbestos or asbestos-containing products? (b) What percentage of gross sales did your company or its predecessor(s) spend on research concerning the health effects of asbestos. (c) ANSWER: State in detail the purposes, duties, and responsibilities or such Research Department. Over the years, North American Refractories Company has maintained a research department; however, because this defendant had no reason to believe that there were potential health hazards associated with its few asbestos containing products, it did not conduct *or fund any research concerning the potential health effects of asbestos. 27 INTERROGATORY NO. S3: Did your company or its predecessors) or subsidiaries ever recall any products containing asbestos from the market or stream of commerce? If so, state: (a) All details of such recall; (b) The name of the product recalled, including the reason for the recall and the names and current addresses of those individuals who determined that it should take place; (c) The dates of recall; (d) The purpose for the recall. ANSWER: No. INTERROGATORY IfflL,5_4: Before 1970, did you ever manufacture or sell products which did not contain asbestos and which could be substituted for your asbestos-containing products? If so, state the date such asbestos-free products were first placed on the market. ANSWER: North American Refractories Company manufactured asbestos-free products from its inception. Some of those products could be used for the same general purposes. INTERROGATORY NO. 55: Have any products you identified in your response to Interrogatory Nos. 52 and 54 not performed as intended? Please list all such products that have not performed as intended. ANSWER: To the best of North American Refractories Company's knowledge, information and belief, its products have generally performed as intended. INTERROGATORY NO. 56: Did your company or its predecessors) or subsidiaries ever make, order, or arrange for any industrial hygiene surveys regarding asbestos or asbestos-containing dust? If so, give the date of such surveys and state who, or what entity, was responsible for completion of such surveys. e ANSWER: North American Refractories Company had no reason to believe that there were potential health hazards associated with its few asbestos containing products because of their small percentage asbestos content, their use primarily in wet or encapsulated forms, their use by industrial customers who were aware of safety precautions, and because of the change in the form of asbestos under heat. Therefore, it had no reason to believe such surveys were required and none were done. 29 INTERROGATORY NO. 57: As to either the threshold limit values or maximum allowable concentrations of both asbestos dust and total dust provided by the American Conference of Governmental Industrial Hygienists, state: (a) The year in which Defendant or any predecessor(s) or subsidiaries were first advised of such limits or concentrations; (b) The name of the employee or official of the company receiving such advice; (c) How Defendant received notice of such limits or concentrations. ANSWER: North American Refractories Company has no documents evidencing when or if it received notice of threshold limit values pertaining to maximum allowable concentrations of asbestos dust. INTERROGATORY NO. 58: Were the threshold limit values or maximum allowable concentrations inquired about in Interrogatory No. 63 for total dust, and not asbestos dust alone? ANSWER: North American Refractories Company has no documents evidencing when or if it received notice of threshold limit values pertaining to maximum allowable concentrations of asbestos dust. INTERROGATORY NO. 59: State in detail what tests, if any, Defendant ever made with regard to the quantity, quality, or threshold limit values of asbestos dust or particles to which workers were exposed while using, working with or around, or installing your asbestos-containing products. ANSWER: North American Refractories Company had no reason to believe that there were potential health hazards associated with its few asbestos containing products because of their small asbestos content, their use primarily in wet or encapsulated forms, their use by industrial customers who were aware of safety precautions, and because of the change in the form of asbestos under heat. Therefore, it had no reason to believe such tests were required and none were done. 30 INTERROGATORY NO. 60: Please state the following with respect to each expert witness you that you may call during trial of these cases. Please designate with specificity the expert witnesses that you may call, including: (a) The name, address, and job classification of each such expert witness; (b) The subject matter on which the expert is expected to testify; (c) The substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion; (d) Whether any person identified in subparagraph (a) above has provided a report or other documentation to you, ana if so, identify and produce each such document or report; (e) Identify all documents that you have provided to each person identified in response to subparagraph (a) above; (0 ANSWER: Describe in detail the education and work history of, and identify any books, treatises, articles, published and unpublished reports, studies or other scholarly works authored by any individual identified in response to subparagraph (a) above. Alternatively, in lieu of said response, attach a copy of a resume or curriculum vitae ana a list of publications to your answers. See Exhibit "B" attached hereto. 31 INTERROGATORY NO. 61: Please state the name, present address and present telephone number, along with the experience and qualifications, if applicable, of each and every person, known to Defendant or to Defendant's agents, having knowledge of facts relevant to these cases involving, but not limited to: (a) Identification of asbestos-containing products to which each and every individual Plaintiff, separate and distinct from all other Plaintiffs within the group, allegedly was exposed or facts disputing the identification of asbestos-containing products in this case. (b) Each and every individual Plaintiff's, separate and distinct from all other Plaintiffs within the group, alleged damages, injuries and/or facts disputing each and every Plaintiffs alleged damages and/or injuries; (c) The negligence of any person or entity other than Defendant which Defendant contends was a cause of each and every individual Plaintiffs, separate and distinct from all other Plaintiffs within the group, alleged injunes and/or damages; (d) ANSWER: Each of Defendant's defenses enumerated in Defendant's last filed Answer in each of these cases. Because plaintiffs have no yet provided complete information regarding work histories, product exposures ana other issues at stake in this litigation, North American Refractories Company cannot fully respond to this interrogatory at this time. However, see the answer to Interrogatory No. 39 for information about company representative who may have knowledge of relevant facts. Also, see me answer to Interrogatory No. 60 for information about potential experts who may have knowledge of relevant facts. Further, see Exhibit "C". INTERROGATORY NO. 62: Please identify documents which will be used at time of trial, (Hxhibit List, Deposition List), which are relevant to each of Defendant's enumerated defenses in Defendant's last filed Answer. ANSWER: See answers to Interrogatory Nos. 39. 60 and 61. In addition, see all documents made available in response to these interrogatories. Also, see Exhibit List attached as Exhibit "D*\ 32 INTERROGATORY NO. 63: When, if ever, did Defendant or any of its predecessors-in-interest first receive a copy of the article entitled "A Health Survey of Pipe Covering Operations in Constructing Naval Vessels", published in January, 1946 in the Journal of Industrial Hygiene & Toxicology, and authored by W. Fleischer and P. Drinker, et al ("the Fleischer-Drinker Report")? . (a) Identify the name and position of the employee or officer who received same; (b) Please produce all documents generated by Defendant which discuss or in any way reference the "Fleischer-Drinker" study prior to 1968; (c) Please produce all documents upon which your responses above are based; (d) Please identify the name(s) and address(es) of any person(s) who can verify your above response; (e) Did Defendant ever rely on the Fleischer-Drinker Report in whole or in part as a basis that Defendant's asbestos products could be used in the workplace without risk of asbestos-related health impacts to the consumer and/or bystander; (f) If so, please produce every document which evidences in any way that Defendant relied on the Fleischer-Drinker Report in whole or in part for the proposition stated in Interrogatory No. 63(a) above; (g) ANSWER: If your answer to 63(e) is yes, when was the first date Defendant relied on the Fleischer-Drinker report in whole or in part for the proposition stated in 63(e) above? North American Refractories Company has no knowledge of the article referred to. 33 INTERROGATORY NO. 64: When, if ever, did Defendant or any of its predecessors-in-interest first receive a copy of the article entitled "A Study of Asbestos in the Asbestos Textile Industry", published in 1938 in Public Health Bill, No. 241, U.S. Public Health Service and authored by W. (c) Dreessen ("the Dreessen Report")? (a) Identify the name and position of the employee or officer who received same; (b) Please produce all documents generated by Defendant which discuss or in any way reference the "Dreessen" study prior to 1968; (c) Please produce all documents upon which your responses above are based; (d) Please identify the name(s) and address(es) of any person(s) who can verify your above response; (e) Did Defendant ever rely on the Dreessen Report in whole or in part as a basis that Defendant's asbestos products could be used in the workplace without risk of asbestos-related health impacts to the consumer and/or bystander; (f) If so, please produce every document which evidences in any way that Defendant relied on the Dreessen Report in whole or in part for the proposition stated in Interrogatory No. 63(a) above; (g) If your answer to 63(e) is yes, when was the first date Defendant relied on the Dreessen report in whole or in part for the proposition stated in 63(e) above? ANSWER; North American Refractories Company has no knowledge of the article referred to. 34 REQUESTS FOR PRODUCTION REQUEST FOR PRODUCTION NO. 1: Please produce a true and correct copy of each photograph of each asbestos-containing product identified in answer to Interrogatory No. 4. ANSWER: See answers to Interrogatory Nos. 39. 60 and 61. In addition, see all documents made available in response to these interrogatories. Also, see Exhibit List attached as Exhibit "D*. REQUEST FOR PRODUCTION NO. 2: Please produce any diagrams or schematics indicating, stating or detailing the existence of any of your subsidiaries, predecessors, or divisions as defined on Page 1 of these Interrogatories and Request for Production. ANSWER: See answers to Interrogatory Nos. 39. 60 and 61. In addition, see all documents made available in response to these interrogatories. Also, see Exhibit List attached as Exhibit *D*\. REQUEST FOR PRODUCTION NO. 3: Please produce copies of all reports of Defendants' experts and any and all documents relied upon by such experts. ANSWER: See answers to Interrogatory Nos. 39. 60 and 61. In addition, see all documents made available in response to these interrogatories. Also, see Exhibit List attached as Exhibit "D*. R:\ENV\FB\BEXAR\MASTROG.DOC 35 EXHIBIT "A" UAhi Piie? Cufvojr;U o:t Davidson r*rt*t Charles waiters Ht. Union womelsdorf Donald tooth Ronald Coleman Caledonia Tea Pyfco PrgCuC? Bine SAte.5 As?cs Usd from AEROCUB anti-erooe rowu HARCOCAST ES riK TROWEL NARCOCRSTX TROWEL NARCOCUN CO. MARC0LX7E SURER SOS HOT CUN C Jan. li. Mac. 21. Aug. 9. Dee. 23. MOV. 11. Hat. 23. June 2. 1971 19(3 19(3 19(3 19(4 1941 19(4 Oct. 2. - Hay 17. . Ag. , . Way 17. - Hay 17. - Apt 23. - Hay 17. 197J 1977* J977 1979 1977* 1979 1977* 10\ 1.33V 2V IV ATROCUM HARCOCAST CS TINT TROWEL NAACOLITE Jan. 11. 1971 Say. 3. 1974 Aug. 9. 39(3 - July 11. 1971 Mov. 7. 19(1 - July 11. 1971 10V IV 2V MARCOCUN SD-334 Nov.' 11. 19(4 - Jan. 12, 1977 IV 80F-C0TE BOF-PATOl CM CUE MIX CM-11 cm mx hc-cue xsx RAXCOGUB 0-343 XARCOCUE CR-344 KARCOCUE d-344 IS RAXCOCUE OtP-347 RAXCOCUB MC-339 RARCCQJE MCP-344 RARCOCUE 9-340 RAXCOCCI PP-34S RAJtMAQ OK CUE XSX MO-339 MC CUS SAJU4AC 60 08RC .. AOtOCOI Juaa a. 1946 1975** NOV. 30. 19(5 - 1973 July 2, 19(3 - May *. 1973 2V 4V 2V July 3. July 3. BOV. 11. HP- 34. *P- 1. Bov. 11. luv. 11. Bov. 11. 19(3 19(3 19(4 19(4 19(5 19(4 1944 19(4 Jan. 31. 1977 - 1975* Jaa. 34. 1977 1975** BOV. 5. 1974 197J" - 1975** - 197S* 1 1/3V 2V IV IV IX 1.33V IX IV Bov. 11. 1X4 - Hare*. 1974 BOV. 11. 1944 -- Jaa. 31. 1977 Apt. IS. 1974 - Nov.. 1974 IX IX IV Aug. 17. 1944 - 19?!`* IV March. 1976 - Fab.. 1910 Uakaowa. however tho encapsulated asbestos uc i< 1/3J- to i/I* thick tad wii a vary small % of tb total refraeeory. J*4. It, lf7I - Bp. 29.-1977 10X **r# ^fcoatiouod oa or before May 3 Tbtto **ro discontinued prior to 197S. 1977. All of the above listed products were Nnuftetured with ehrysotile asbestos. All of the products, except for NAftKAG 60 OSSC, were gtroing aixe* or eastables. North American did provide to eustemers upon their specifications a line of metalelod brick with an encapsulated asbestos expansion sat, which North American designated aa Hammg 60 D8SC; however, net all metalelod brick contained asbestos. Occasionally, certain customers would specifically request asbestos in a aetalclod brick other than Name? 60 08RC, but this occurred in less than IX of metalelod briek tales. for a period of time ending in 1971, this defendant told Eagte-Picher products Super 66 and One-Catecement inder a relabeling agreement as Staton and Unieote. This defendant has no records from which it can determine the details of emnufoeture, design or composition of thefe products. In June, 1964, Eagle-Picher informed this defendant it planned to place asbestos warning labels on Super 66 and One-Cote and proposed to do the same for Staten and Unieote which this defendant agreed. These products were sold very infrequently and in small quantities. In March, 1984, this defendant was first informed by manufacturer Curosaki Refractories Company of Japan that a Euroseki slide gate refrectory distributed in the United States from May, 1982 until April, 1983 by this defendant contained an encapsulated ceramic amt with a 4.5-SX asbestos eenponent. This product was distributed on a trial basis in small quantities to only a few of defendant's customers. This defendant does not know the precise details of the design or amnufacturc of this product at the time it was sold with asbestos. ANSWER TO INTERROGATORY WO. 60 EXHIBIT MB" Dr. James Robert Shepherd, III University of Texas Health Center at Tyler Department of Radiology P.` 0. Box 2003 Tyler, Texas 75710 * May testify regarding the radiographs of the plaintiff and/or plaintiff's decedent. Dr. Michael Henderson 330 Rittiman Road San Antonio, Texas 78209 May testify concerning the relationship of asbestos and smoking to the development of cancer. Dr. James E. Lockey Institute of Environmental Health University of Cincinnati Medical Center Clinical Studies Division 5251 Medical Science Building ML182 231 Bethesda Avenue Cincinnati, Ohio 45267-0182 May testify about the state of the scientific and medical knowledge concerning asbestos. Included in the testimony may be- discussion of the respiratory system, asbestos related diseases and the effect of other substances on the respiratory system. Dr. A. Mitchell Polinsky Stanford University Professor of Law and Economics Crown Quadrangle Stanford, California 94306-8610 ` r May testify about the inappropriateness of punitive damages in this and similar cases based upon research he and others have conducted. Dr. Oscar Auerbach 158 Long Hill Drive Short Hills, New Jersey 07078 May testify about the plaintiff's medical condition and about asbestos-related diseases. Dr. Stephen M. Ayers St. Louis University School of Medicine 1325 S. Grand Avenue St. Louis, Missouri 63104 Pulmonary specialist. May testify to matters pertaining to the history of scientific knowledge, research and study concerning exposure to asbestos and its effects on the human body. (7) Dr. Brian Bradley, M.D. The Lung Center 4003 Woodlavn Pasadena, Texas 77504 May testify about "the medical condition of the plaintiff and about asbestos-related diseases. (8) Dr. Phillip Cagle 6565 Fannin MS 205 Houston, Texas 77030 May testify regarding the pathology of the plaintiff and/or plaintiff's decedent. (9) Dr. Gregory Foster, M.D. North Texas Pulmonary Associates 375 Municipal Drive, Suite 140 Richardson, Texas 75080 May' testify about the medical condition of the - plaintiff and about asbestos-related diseases. (10) - Dr. Sam H. Cade, Jr. Radiology Department Baylor University Medical Center 3500 Gaston Avenue Dallas, Texas 75242 May testify regarding the radiographs of the plaintiff and/or plaintiff's decedent. (11) Dr. Peter Heidbrink Southwest Pulmonary Associates St. Paul Professional Building No. 5959 Harry Hines Blvd., Suite 711 Dallas, Texas 75235 2 Specialist in the area of respiratory diseases. May testify as to matters pertaining to his examination of the plaintiff and plaintiff's medical records. (12) Dr. Robert O'Neal Rt. 1, Box 168 Perkingston, Mississippi 39573 -2- May testify regarding general pathology and the pathology of the plaintiff and/or plaintiff's decedent. (13) Dr. Joseph Cimino New York Medical College 50 Willard Avenue N. Carrington, New York 10591 Professor and Chairman of the Department of Community and Preventative Medicine. May testify generally about research in the area of pulmonary pathology and about the process by which medical knowledge evolved. May also testify regarding the state of medical knowledge from the early part of the century to the middle 1960s as it regards pathological changes due to exposure to asbestos and about his conclusions regarding the studies conducted for Owens-Illinois by the Saranac Laboratories as they relate to the state of medical knowledge at that time. (14) " Dr. John E. Craighead Department of Pathology University of Vermont College of Medicine Burlington, Vermont 05405 May testify about the plaintiff's medical condition and about asbestos-related diseases. (15) Dr. George L. Delclos 6550 Fannin, No. 2403. Smith Tower Houston, Texas 77030 Medical doctor. May testify about the medical condition of the plaintiff and about asbestos- related diseases. (16) Dr. Milton Grey 521 Crestbend Houston, Texas Medical doctor and board certified as a specialist in internal medicine. May testify as to the structure and function of the respiratory system, the effects of cigarette smoking and the diseases of the lungs, including asbestos-related diseases. (17) Dr. Donald Greenburg One Baylor Plaza Baylor College of Medicine Houston, Texas 77030 -3- May testify about asbestos-related diseases and the effect of other substances such as cigarette smoke upon the respiratory system. (18) Dr. William K. C. Morgan University Hospital University of Western Ontario P. 0. Box 5339, Postal Station A London Ontario N6A 5 A5 Professor of Medicine and Director of Chest Diseases Services at the University of Western Ontario. He has knowledge of the pathology, diagnosis, testing and causation of pulmonary and related disease, including mesothelioma, lung cancer and asbestos. May testify about the state of the medical art as it relates to the knowledge of health hazards associated with exposure to asbestos dust. (19) Dr. Paul Stevens Professor of Medicine' Baylor College of Medicine 6516 Bertner Houston, Texas 77030 Specialist in the area of respiratory diseases. May testify as to matters pertaining to his ' examination of the plaintiff and plaintiff's medical records. (20) Dr. Harry Demopolous 550 First Avenue New York, New York 10016 May testify about the state of the scientific and medical knowledge concerning asbestosis. (21) Dr. H. Corwin Hinshaw 450 Sutter Street San Francisco, California May testify about the state of the scientific and medical knowledge concerning asbestosis. (22) Dr. Hans Weill Tulane University School of Medicine 1700 Perdio Street, 2nd New Orleans, Louisiana Floor 70112 Pulmonary disease specialist. May testify about scientific knowledge, research and study regarding -4- exposure to asbestos and its effects on the human body. (23) Dr. R. Keith Wilson Chief of Pulmonary Section Methodist Hospital 6535 Fannin, Suite F-966 Fondren Brown Building Houston, Texas 77Q30 Specialist in the area of respiratory diseases. May testify as to matters pertaining to his examination of the plaintiff and plaintiff's medical records. (24) Dr. Thomas Wheeler 2919 Eagle Creek Kingvood, Texas 77345 Pathologist. May testify about asbestos-related diseases and the effect of other substances such as cigarette smoke on the-plaintiff. (25) Dr. Joe G. N. Garcia Department of Medicine Wilshire Memorial Hospital - Indianapolis, Indiana 46202 Medical doctor. May testify about the medical condition of the plaintiff and about asbestos- related diseases. (26) Dr. David Jarvis First Scoville Medical Group 345 24th Avenue, North Suite 201 Nashville, Tennessee 37203 Pulmonologist. May testify about the medical condition of the plaintiff based on his examination of the plaintiff and/or review of the plaintiff's medical records, and ^about asbestos-related diseases. (27) Dr. Allen Goldstein Pulmonary Medicine Associates, 860 Montclair Road, Suite 862 Birmingham, Alabama 35213 P.C. Pulmonologist. May testify about the medical condition of the plaintiff based on his examination of the plaintiff and/or review of the plaintiff's medical records, and about asbestos-related diseases. -5- (28) Dr. Kenneth J. Boudreaux, PhD Consulting Economist A. B. Freeman School of Business Tulane University 1424 Boudreaux New Orleans, Louisiana 70115 Economic consultant. May testify regarding economic loss incurred by the plaintiff. (29) Dr. John Sartain Consulting Economist Sartain & Company 3S11 Turtle creek Center, Dallas, Texas 75291 Suite 760 Economic consultant. May testify regarding economic loss incurred by the plaintiff. (30) Dr. Richard Bradt Dean of Mackey School of Minds University of Nevada, Reno Reno, Nevada 89557-0047 May testify to the nature, characteristics, and intended uses of NARCO's products and any changes which occur with the use of its products. (31) Dr. Richard Landy Vice President of Technology North American Refractories Company 500 Halle Building ' . 1228 Euclid Avenue Cleveland, Ohio 44115 May testify to the nature, characteristics, and intended uses of NARCO's products and any changes which occur with the use of its products. (32) Nurtan Esmen 2531 Wickline Road Gibsonia, Pennsylvania (412) 443-3785 * 15044 May testify to the nature, characteristics, and intended uses of NARCO's products and any changes which occur with the use of its products, as well as the aerodynamics and characteristics of fibers. -6- (33) R. Keith Wilson, M.D. Pueblo Pulmonary Asso. 1925 E. Orman Ave., Suite Pueblo, Colorado 81004 (719) 561-1542 254 Medical doctor specializing in pulmonology. May testify about the medical condition of the plaintiffs and about asbestos-related diseases. (34) Dr. Edvard Gaensler Boston University Medical Center 80 East Concord Street Boston, Massachusetts 02118 May testify about the state of the scientific and medical knowledge concerning asbestosis. (35) Dr. Elliot Hinkes Board Certified Oncologist & Hematologist 301 N. Prairie Avenue, Suite 311 Englewood, California 90301 May testify about the relationship of asbestos and smoking to the development of cancer and the incidence of lung cancer among individuals with - asbestosis or exposure to asbestos. (3 6). Dr. Robert Jones Tulane Medical Center 3900 Cambridge Kansas City, Kansas 66103 (913) 588-6044 Medical doctor. May testify about the medical condition of the plaintiffs and about asbestos- related diseases. (37) Dr. Joseph Bates 5 Glenridge Road Little Rock, Arkansas (501) 660-2029 72202 ,,. Medical doctor. May testify about the medical condition of the plaintiffs and about asbestos- related diseases. (38) Dr. Bill Tranum 9501 Lyle Drive Little Rock, Arkansas (501) 223-8003 -7- Medical doctor. May testify about the medical condition of the plaintiffs and about asbestos- related diseases. (39) Dr. Brent Harrison Department of Radiology University of Mississippi Medical Jackson, Mississippi (601) 984-2515 Center Medical doctor. May testify about the medical condition of the plaintiffs and about asbestos- related diseases. (40) Dr. Alton Ochsner Jefferson Hospital 1507 Metairie Road New Orleans, Louisiana (504) 833-3783 (by deposition) Medical doctor. May testify about the medical condition of the plaintiffs and about asbestos- related diseases. (41) Dr. Victor Roggli VA Medical School - Lab Service 5089 Fulton Street . Durham, North Carolina (919) 286-0411 Dr. Roggli may testify regarding general pathology and the pathology^ of the plaintiffs and/or plaintiffs' decedents.' (42) Dr. Brooks Emory Ochsner's Clinic New Orleans, Louisiana (504) 838-4078 Medical doctor. May testify about the medical condition of the plaintiffs and about asbestos- related' diseases. (43) Dr. Russell p. Shervin Department of Pathology USC School of Medicine Los Angeles, California (213) 342-1165 Dr. Sherwin may testify regarding general pathology and the pathology of the plaintiffs and/or plaintiffs' decedents. -8- (44) Roy steinfurth Room 505, Machinist Building 1300 Connecticut Avenue, N.W. Washington, D.C. As the Administrator of the Asbestos Worker's International Health Hazards Program, Roy J. Steinfurth may provide .testimony that the insulators' union was, or.should have been, aware of hazards associated with inhalation of asbestos fibers, and that this information was distributed to the union members through various means, including the "green sheets." (45) Or. Lee B. Reichman Professor of Medicine New Jersey Medical School 2 Brook Road Tenafly, New Jersey 07670 Or. Reichman may provide testimony concerning the anatomy and function of the respiratory and circu latory systems; the symptomatology, disease process and diagnosis of asbestosis and cancer of the res piratory system, peritoneum and peritoneal cavity; the- nature and extent of medical and scientific - knowledge regarding any association of pulmonary disease with asbestos fiber and the effect of . exposure to substances other than asbestos in the development and manifestation of diseases of the respiratory system; the methods of diagnosis and means of establishing the differential diagnosis of asbestos-related diseases with non-asbestos related diseases; the incidence of lung cancer in the general population and those individuals exposed to asbestos; cigarette smoking and its effect on the lungs; the difference between impairment and disa bility; the effect of asbestosis on disability and life expectancy; the lack of relationship between pleural plaques and development of any cancer; the history of evolution and knowledge of asbestosrelated diseases; and the,, evolution of the medical communities awareness of the increased risks for an asbestos-related disease in the cases of prolonged exposure. (46) Gerald Kerby, M.D. University of Kansas Medical Center 3900 Cambridge Kansas City, Kansas 66103 Dr. Kerby may provide testimony concerning the anatomy and function of the respiratory and circu latory systems; the symptomatology, disease process -9- and diagnosis of asbestosis and cancer of the res piratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of pulmonary disease with asbestos fiber and the effect of exposure to substances other than asbestos, in the development and manifestation of diseases of the respiratory system; the methods of diagnosis and means of establishing the differential diagnosis of asbestos-related diseases with non-asbestos related diseases; the incidence of lung cancer in the general population and those individuals exposed to asbestos; cigarette smoking and its effect on the lungs; the difference between impairment and disa bility; the effect of asbestosis on disability and life expectancy; the lack of relationship between pleural plaques and development of any cancer; the history of evolution and knowledge of asbestosrelated diseases; and the evolution of the medical communities awareness of the increased risks for an asbestos-related disease in the cases of prolonged, exposure. (47) Dorsett Smith, M.D. 4301 Colby, Suite 201 Everett, Washington 92203 Dr. Smith may provide testimony concerning the anatomy and function of the respiratory and circu latory systems; the symptomatology, disease process and diagnosis of asbestosis and cancer of the res piratory system, peritoneum and peritoneal cavity; the nature and extent of medical and scientific knowledge regarding any association of pulmonary disease with asbestos fiber and the effect of exposure to substances other than asbestos in the development and manifestation of diseases of the respiratory system; the methods of diagnosis and means of establishing the differential diagnosis of asbestos-related diseases with non-asbestos related diseases; the incidence of lung cancer in the general population and those individuals exposed to asbestos; cigarette smoking and its effect on the lungs; the difference between impairment and disa bility; the effect of asbestosis on disability and life expectancy; the lack of relationship between pleural plaques and development of any cancer; the history of evolution and knowledge of asbestosrelated diseases; and the evolution of the medical communities awareness of the increased risks for an asbestos-related disease in the cases of prolonged exposure. -10- (48) Dr. Stephen Jenkinson UT Health Science Center at San Antonio 7703 Floyd Avenue Drive San Antonio, Texas 78284-7885 Dr. Jenkinson may testify concerning his examina tion and diagnosis of the physical condition of the particular Plaintiff and the relationship, if any, to the Plaintiff's exposure to asbestos. Each doctor will also testify concerning those areas described for witnesses Demopoulos, Hinshaw, Weill, Craighead, and Gaensler (49) Dr. Bob Baird 3600 Gaston #806 Wadley Tower Dallas, Texas 75246 Dr. Baird may testify concerning his examination and diagnosis of the physical condition of the particular Plaintiff and the relationship, if any,, to the Plaintiff's exposure to asbestos. Each doctor will also testify concerning those areas described for witnesses Demopoulos, Hinshaw, Weill, Craighead, and Gaensler (50} Dr. Russell M. Harley Medical University of South Carolina - 171 Ashley Avenue Charleston, South Carolina 29401 Dr. Harley is a physician who is an expert in the fields of pathology'and etiology and diagnosis of asbestos-related disease based upon review of tissue and tissue slides obtained as a result of biopsy or autopsy. He may testify concerning matters pertaining to the diagnosis of asbestos- related disease generally and the diagnosis of the condition of plaintiffs in these cases specifically. Further, he may testify concerning the diagnosis, or lack thereof of an asbestos- related disease based upon-the medical records of plaintiffs, including, but not limited to, tissue and/or slides that he will review. (51) Dr. Thomas Peter Howard Osier Clinic of Medicine Pulmonary Director 930 South Harbor City Boulevard Melbourne, Florida 32901 Dr. Howard is an expert in the field of pulmonary medicine. He is board certified in internal medicine and pulmonary medicine and has been -11- certified by NIOSH as a WB Reader." Dr. Howard may testify on matters pertaining to the diagnosis of asbestos-related disease generally and the diagnosis of the condition of plaintiffs in these cases specifically. Further, he may testify concerning the effect or lack thereof of asbestos on the lungs of persons occupationally exposed to asbestos and the pulmonary condition of plaintiffs based upon medical records to be reviewed, including, but not limited to, pulmonary function tests and chest x-rays. (52) Dr. Andrew Marc Churg Department of Pathology University of British Columbia 2212 Westbrook Mall Vancouver B.C. Canada Dr. Churg is a physician who is an expert in the fields of pathology and etiology and diagnosis of asbestos-related disease based upon review of tissue and tissue slides obtained as a result of biopsy or autopsy. Dr. Churg may testify concerning the diagnosis or lack thereof of an asbestos-related disease based upon the medical records of plaintiffs, including, but not limited " to, tissue and/or slides that he will review. Further, he may testify on matters pertaining to - the diagnosis of asbestos-related disease generally and the diagnosis of the condition of plaintiffs in these cases specifically. (53) Dr. Scott R. Donaldson North Texas Pulmonary Associates 375 Municipal Drive, Suite 140 Richardson, Texas 75080 May testify regarding the medical condition of the plaintiffs and about asbestos-related diseases. (54) Dr. Lewis Solmon Associate Dean Graduate School of Education U.C.L.A. ` 308 Moore Hall Los Angeles, California 90024 May testify about the historical sales and market shares of asbestos insulation manufacturers. -12- (55) Dr. William Eschenbacher Baylor College of Medicine Department of Internal Medicine/Pulmonary Section 6550 Fannin Smith Tower /1220 Houston, Texas 77030 May testify regarding the medical condition of the plaintiffs and about asbestos-related diseases. (56) Dr. R. Brent Harrison The University of Mississippi Department of Radiology 2500 North State Street Jackson, Mississippi 39216 Medical Center May testify regarding the radiographs of the plaintiffs and/or plaintiffs' decedent. (57) Dr. Robert N. Jones, M.D. Tuland University School of Medicine Pulmonary Diseases Section 1700 Perdido Street New Orleans, Louisiana 70112 May testify regarding the medical condition of the ' plaintiffs and about asbestos-related diseases. (58> Dr. William Emory Ochsner Clinic 1514 Jefferson Highway New Orleans, Louisiana 70121 May testify regarding the medical condition of the plaintiffs and about asbestos-related diseases. (59) Dr. Dietrick A. Weyel 660 Edward Carnegie, PA 15106 May testify to the nature, characteristics, and intended uses of NARCO' s ^-products and any changes which occur with the use of its products. (60) James J. Uchno Director of Technology North American Refractories Company 3127 Research Drive State College, Pennsylvania 16801 May testify to the nature, characteristics, and intended uses of NARCO's products and any changes which occur with the use of its products. -13- (61) Dr. Otto Wong Applied Health Services 181 Second Avenue, Suite 628 P. 0. Box 2078 San Mateo, California 94401 May testify regarding epidemiological studies or surveys in connection with asbestos-related issues which may be involved in specific cases. (62) All physicians who`examine plaintiffs to testify regarding matters contained in their medical records and reports. This defendant reserves the right to name additional expert witnesses. Reports have been provided by some of the potential experts. These reports are available for inspection or copying upon reasonable notice. NARCO has not provided any .documents to these potential experts specifically in connection with this litigation. Those potential experts who have been employed by NARCO have reviewed various documents in connection with that employment, but have not kept records of all documents reviewed. NARCO does not have detailed information about the education, work history, and writings of all the potential experts named; however, NARCO will provide resumes or CV's for those experts who are directly associated with NARCO for inspection or copying upon reasonable notice. 14648 ANSWER TO INTERROGATORY HO. 61 EXHIBIT "C" George Spahlinger Manager - Sales Administrator North American Refractories Company The Halle Building 1228 Euclid Avenue,- 5th Floor Cleveland, Ohio 44115 (216) 621-5200 Vonda Bruncak Manager - Sales Administrator North American Refractories Company The Halle Building 1228 Euclid Avenue, 5th Floor Cleveland, Ohio 44115 (216) 621-5200 Don Abrino Coordinator of Product Safety and Human Relations North American Refractories Company 3127 Research Dr. State College, Pennsylvania 16801 (814) 234-7981 Richard Landy Vice President of Technology 500 Halle Building 1228 Euclid Avenue Cleveland, Ohio 44115* (216) 621-5200 ' Daniel Boring General Sales Manager - Iron & Steel 500 Halle Building 1228 Euclid Avenue Cleveland, Ohio 44115 (216) 621-5200 Mark Rafferty General Sales Manager - Western Division 7831 Paramount Boulevard Pico Rivera, California 90660 (213) 723-3316 Larry Dilley Plant Manager North American Refractories Company Wolmesdorf, Pennsylvania (215) 589-2535 (8) Wally Evans District Sales Manager North American Refractories company 200 Vestavia Parkway 1000 Birmingham, AL 35216 (205) 822-6514 (9) Mark Jacobs North American Refractories Company 200 Vestavia Parkway 1000 Birmingham, AL 35216 (205) 822-6514 (10) James Uchno Director of Technical Center North American Refractories Company 3127 Research Drive State College, Pennsylvania 16801 (814) 234-7981 (11) R. C. Crosson North American Refractories The Halle Building Cleveland, Ohio Company (12_) James Rovles North American Refractories Company The Halle Building Cleveland, Ohio (13) Charles Thompson North American Refractories The Halle Building Cleveland, Ohio Company (14) Edward London North American Refractories The Halle Building Cleveland, Ohio Company (15) Craig Cline North American Refractories The Halle Building Cleveland, Ohio Company (16) J. L. Caldwell North American Refractories Company The Halle Building Cleveland, Ohio (17) J. B. Poison North American Refractories The Halle Building Cleveland, Ohio Company -2- (18) S. J. Metzer, Jr. North American Refractories Company The Halle Building Cleveland, Ohio (19) T. M. Doty North American Refractories The Halle Building Cleveland, Ohio Company (20) Carl E. Stahl, Jr. \ North American Refractories The Halle Building Cleveland, Ohio Company (21) D. E. Varanese North American Refractories The Halle Building Cleveland, Ohio Company (22) J. M. Campanelli North American Refractories Company The Halle Building Cleveland, Ohio (23) - H. t>. Sullivan North American Refractories The Halle Building Cleveland, Ohio Company (24) John Scanlon North American Refractories The Halle Building ' Cleveland, Ohio Company (25) J. H. Ammerman North American Refractories Company The Halle Building Cleveland, Ohio (26) E. S. Chrzan North American Refractories'Company The Halle Building Cleveland, Ohio (27) Richard Wilson North American Refractories The Halle Building Cleveland, Ohio Company (28) Jay Ehle North American Refractories The Halle Building Cleveland, Ohio Company -3- (29) Curt E. Horton North American Refractories Technical Center 3127 Research Drive State College, Pennsylvania Company (30) Ronald Coleman North American Refractories P.O. Box 38 Wolmesdorf, Pennsylvania Company (31) J ames Stevens North American Refractories P.O. BOX 38 Wolmesdorf, Pennsylvania Company (32) Robert F. Whitford North American Refractories Company Curvensville, Pennsylvania (33) Robert Davidson North American Refractories Company Curvensville, Pennsylvania (3 5) Kim. Nelson North American Refractories Company 3127 Research Drive State College, Pennsylvania 16801 In addition, defendant may supplement this answer by supplementing its discovery responses in individual lawsuits and reserves the right to call such additional witnesses who may have knowledge pertinent to-a particular case. 14651 * -4- EXHIBIT MD" WORTH AMERICAN EXHIBITS Exhibit Wo, Description 1 Epidemiology/Epidemiologists Chart 2 Critical Factors in Disease Causation Chart 3 The Asbestos Minerals Chart 4 Photocopy of Electron Micrographs of Asbestos Minerals 5 Particle Sizes Chart 6 Definition of a Fiber Chart 7 Fiber Concentrations Chart 8 Diseases Reported to be Associated with "Asbestos" Exposure Chart 9 Mesothelioma Chart 10 Diagnostic Difficulty Chart 11 McDonald AD, Magner D & Eyssen G (1973) Primary Malignant Mesothelial Tumors in Canada 19601968 Cancer 31: 869-876 12 McDonald JC, Armstrong B,- Case B, Doell D, McCaughey WTE, McDonald AD, and Sebastian P (1989) Mesothelioma and Asbestos Fiber Type Cancer 63: 1544-1547,1989 13 Daya Dean and McGaughey W.T. Elliott (1989) Well-Differentiated Papillary Mesothelioma of the Peritoneum Cancer 65: 292-296,1990 14 Latency chart 15 Lung Cancer Etiology Chart 16 Hughes Janet (Publication Date: 1989) The Derivation and Use of Asbestos Risk Estimates Symposium on Health Aspects of Exposure to Asbestos in Buildings - Harvard University, Dec. 14-16,1988 17 Lung Cancer Etiology Chart Exhibit No. Description 18 Hammond EC, Selikoff IJ & Seidman H (1979) Asbestos Exposure, Cigarette Smoking and Death Rates Ann NY Acad Sci 130 473-490 19 Relative Risks (RR) Associated vith Smoking Chart 20 McDonald JC, Liddell FDK, Gibbs GW, Eyssen GE and MacDonald AD (1980) Dust Exposure and Mortality in Chrysotile Mining, 1910-75 Brit. J. Industr. Med. 37 11-24 21 Lung Cancer Etiology (Chemicals) Chart 22 ACGIH (1946-90) Threshold Limit Values for Chemical Substances ACGIH Cincinnati, Ohio 45211 23 Asbestosis - Clinical Diagnostic Factors and Tissues Chart 24 Observer Variation Chart 25 Parker D, Bender A, Hankinson S & Aeppli D (1989) Public Health Implications of the Variability in the Interpretation of "B" Readings for Pleural Changes J.O.M. 31 775-780 26 Non-Specificity of Chest Radiograph Chart 27 Weiss, William (1991) Cigarette Smoking and Small Irregular Opacities Brit. J, Industr. Med. 48 841-844 28 Pleural Calcification Chart 29 Gibbs, Graham W. (1979) Etiology of Pleural Calcification: A Study of Quebec Chrysotile Asbestos Miners and Millers Archives of Environmental Health 30 Mesothelioma in Various Cohorts(McDonald, Acheson) Chart 31 McDonald AD and McDonald JC (1978) Mesothelioma After Crocidolite Exposure during Gas Mask Manufacture Environ. Research 17 340-346 Exhibit No. Description 32 33 34 35 36 37 38 39 40 41 42 43 Acheson ED, Gardner MJ, Pippard EC 4 Grime LP (1982) Mortality of Two Groups of Women Who Manufactured Gas Masks from chrysotile and Crocidolite Asbestos: A 40 Year Follow-Up Brit 3 Industr Med 39 344-348 Mesothelioma in Various Cohorts (Hobbs) Cart Hobbs Woodward S.D., Murphy, B., Musk, A W., and Elder, J.E. (1980) The Incidence of Pneumoconiosis, Mesothelioma and Other Respiratory Cancer in Men Engaged in Mining and Milling Crocidolite in Western Australia Mesothelioma in Various Cohorts (Seidman, Acheson) Chart Seidman H, Selikoff IJ & Hammond EC (1979) Short-Term Asbestos Work Exposure and Long Observation Ann N Y Acad Sci 330 61-89 Term Acheson ED, Gardner MJ, Winter PD and Bennett C (1984) Cancer in a Factory Using Amosite Asbestos International Journal of Epidemiology, Vol. 13, No. l Mesothelioma in Various Cohorts-I.nsulation Industry- Mixed Exposures Chart '* Selikoff IJ, Hammond CE and Seidman H. (1979) Mortality Experience of Insulation Workers in United States and Canada, 1943-1976 Ann N.Y. Acad Sci 330 91-116 the Mesothelioma in Various Cohorts-Dockyard Workers-f&ei Exposures Chart Rossiter, C.E., Coles, R.M. (1980) HM Dockyard, Devonport: 1947 Mortality Study Mesothelioma in Various Cohorts-Amphibole & Qirysatile Mixed Exposures Chart Newhouse, M.L and Bery, G. (1979) Patterns of Mortality in Asbestos Factory Workers in London Ann NY Acad Sci 330 53-60 Exhibit No. Description 44 Mesothelioma in Various Cohorts - Chrysotile (Jthescn) Chart 45 Mesothelioma in Various Cohorts - Chrysotile (McDonald, Rubino) Chart 46 Rubino, G.F., Piolatto, G., Nevhouse, M.L, Scansette, G., Aresine, G.A., and Murrey, R. (1979) Mortality of Mesothelioma Asbestos Workers at the Balangero Mine, Northern Italy Brit. J. Industr. Med. 36:187-194 47 Mesothelioma in Various Cohorts - chrysotile (Nicholson) Chart 48 Nicholson, WJ, Selikoff IJ, Seidaan H, Lilis R, and Formby, P (1979) Long-Term Mortality Experience of Chrysotile Miners and Millers in Thetford, Mines, Quebec Ann NY Acad Sci 33011-21 49 Mesothelioma in Various Cohorts - Chrysotile (Weiss, Thomas) Chart 50 weiss, W. (1977) Mortality of a Cohort Exposed to Chrysotile Asbestos JOM 19 737-740 52 Thomas HF, Bennarain IT, Elwood P and Sweetnam PM (1982) 53. McDonald AD, Fry JS, Woolley AJ and McDonald JC (1363) Dust Exposure and Mortality in an American Chrysotile Textile Plant Brit 3 Industr Med 40 361-367 Further Follow-Up study of Workers from an Asbestos Cement Factory. t Brit. J. Industr. Med. 39: 273-276 Mesothelioma in Various Cohorts - Chrysotile (McDonald) Chart 54 Mesothelioma in Various Cohorts Chrysotile (McDonald, Newhouse & Sullivan) Chart Exhibit No. Description 55 56 57 58 59 60 61 62 63 64 65 66 McDonald AD, Fry JS, Woolley AJ & McDonald JC (1984) Dust Exposure and Mortality in an American Chrysotile Asbestos Friction Products Plant Brit. J. Industr. Med. 41 151- 1S7 Newhouse ML & Sullivan KR (1989) A Mortality study of Workers Manufacturing Materials; 1941-86 Brit J Industr Med 46176-179 Friction Mesothelioma & Brake-Lining Work (Meso Case Reports) Chart Mesothelioma & Brake-Lining Work Studies) Chart (Registry Linkage Hansen ES (1989) Mortality of Auto Mechanics - A Ten Year Follow-Up Scand J Work Environ Health 15 43-46 1989 Mesothelioma & Brake-Lining Work Studies) (Jarvholm & Brisman) Chart (Registry Linkage Jarvholm B & Brisman J (1988) Asbestos Associated Tumors in Car Mechanics Brit J Industr Med 45 645-646 Mesothelioma & Brake-Lining Work Studies) (Malker) Chart (Registry Linkage Malker HS, Mclaughlin JK, Malker BK, Stone BJ, Weiner JA, Erickson JL & Blot WJ (1985) Occupational Risks for Pleural Mesothelioma in Sweden J Natl Cancer Inst 74 61-661985 Factors Important in Mesothelioma Production Chart Lung Cancer Risk and Asbestos Exposure by Industry Sector Chart and References Fibre Concentrations in Friction Manufacturing - UK Chart Exhibit No. Description 67 Berry G & Nevhouse ML (1983) Mortality of Workers Manufacturing Friction Materials Using Asbestos Brit J Industr Med 401-71983 68 Studies of Car Mechanics (Marcus, Jarvholm & Larson) Chart 69 Marcus K, Jarvholm BG & Larsson S (1987) Asbestos - Associated Lung Effects in Car Mechanics Scand J Work Environ Health 13 252-254 1987 70 Studies of Car Mechanics (Boillat & Lob) Chart 71 Boillat MA & Lob M (1973) Risque d'asbestose chez les travailleurs occupe a remplacer les garnitures de frein (Risk of Asbestosis in Workers Employed at Replacement of Brakelining) Schwei2 Med Wschr 103 1354-1359 72 Studies of Garage Workers Chart 73 Nicholson WJ (1982) Investigations of Health Hazards in Brake Lining Repair and Maintenance Workers Occupationally Exposed to Asbestos Environmental Sciences Laboratory, Mount Sinai School of Medicine, NIOSH contract 210-22-0119 (PB 83-22089 7) 99 pp & appendices 74 Pulmonary Function Results by Job Category Chart 75 Study Deficiencies/Difficulties/Biases Chart 76 Fiber Size and Fibrosis Charts 77 Kushner N & Wright GW (1977) . The Influence of Varying Lengths of Glass and Asbestos Fibers on Tissue Response in Guinea Pigs Inhaled Particles IV, Volume 2 47-69 78 Prevalence of Small Opacities (>l/0) and Cumulative Exposure (F/ML Years) - Tremolite and Chrysotile Chart Description McDonald JC, McDonald AD, Armstrong B and Sebastien P (1986) Cohort Study of Mortality of Vermiculite . Miners Exposed to Tremolite Brit. 3 Industr. Med. 43 436-444 Prevalence of Small Irregular Among 181 NonAsbestos Exposed Workers Chart Opacities (SIO>Q/l) Critical Factors in Disease Causation Chart Photograph of Bendix Brake Linings Photocopy and photograph of electron micrographs of asbestos minerals Photocopy of Electron Micrographs Chrysotile Asbestos (X5330) - (10 Microgram Filtered) Photocopy of Electron Micrographs UICC Chrysotile Asbestos (X33580) - (Matches SAED) - (10 Microgram Eiltered) Photocopy of Selected Pattern - UICC Chrysotile Asbestos Area Electron Diffraction Chrysotile Content of Brake Wear Debris Chart Lynch J (1968) Brake Lining Decomposition Products Journal of Air Pollution Control Association 18 824826 Hickish DE & Knight KL (1970) Exposure to Asbestos During Brake Maintenance Ann Occup Hyg 13 17-21 1970 Rowson DN (1978) The Chrysotile Content of the Wear Debris of Brake Linings Wear 47 315-321 Williams RL & Muhlbaier, Jean L. Asbestos Brake Emissions Environmental research 29 70-82 (1982) Exhibit Mo. Description 89 90 91 92 93 94 95 95a 95b 95c 95d 96 Anderson AE, Gealer RD, McClune RC & Sprys JW (1973) Asbestos Emissions from Brake Dynamometer Tests Automobile Engineering Meeting, Detroit, Michigan May 14-18 1973 Society of Automotive Engineers, New York, New York 12 pp Particle Si2e of Brake Wear Debris Chart Rohl AN, Danger AM, Wolff MS & Weisman I (1976) Asbestos Exposure During Brake Lining Maintenance and Repair Environ Res. 12 110-128 Lorimer tfV, Rohl AN, Miller A, Nicholson WJ & Selikoff IJ (1976) Asbestos Exposure of Brake Repair Workers in the United States The Mount Sinai Journal of Medicine 43 207-218 1976 Rohl AN, Danger AM, Klimentidis, R Wolff & Selikoff XJ (1977) Asbestos Content of Dust Encountered in Brake Maintenance & Repair Prop. Royal Soc. Med 70 32-37 1977 Rodelsperger K, Jahn H, Bruckel B., Manke J, & Woitovitz HJ (1986) Asbestos Dust Exposure During Brake Repair Amer J Xndustr Med 10 63-72 1986 Paur R, Photocopy of Electron Micrographs of Wear Debris Photocopy of Electron Micrographs of Wear Debris with Visible Chrysotile Fibres (5330X) - (200 Microgram Filtered) Photocopy of Electron Micrographs of Wear Debris (5330X) - (200 Microgram Filtered) Photocopy of Selected Pattern - Fibre From Brake Wear Dusts Area Electron Diffraction Photocopy of Electron Micrograph - Fibre from Brake Wear Dust (33580X) (Matches SAED) - Approx. 4UM in length Potential for Exposure Chart Exhibit Wo. Description 97 98 99 100 101 102 103 104 105 Dust Concentrations (Kauppinen & Korhonen) Chart Kauppinen T & Korhonen K (1987) Exposure to Asbestos During Brake Automotive Vehicles by Different Methods Amer Industr Hyg Assoc J 48 499-506 Maintenance of Dust Concentrations(Rodelsperger) Chart Results of MeasurementsDuring Brake Maintenance (USPHS and NIOSH Surveys) Charts Repair and Dement JM (1972) U.S.P.H.S. Survey, Cincinnati Municipal Automobile Brake Servicing Operation, Cincinnati, Ohio, Report Number XHS 32-11 NTIS PB83-188-045 pp Garage, 3 Roberts DR (1980) Industrial Hygiene Report Asbestos at Allied Brake shop. Cincinnati, Ohio NIOSH, Division Surveillance, Hazard Evaluations and Field Studies, Cincinnati, Ohio, pp 12 Roberts DR (1980) Industrial Hygiene Report Asbestos at Reading Brake and Alignment Service, Reading, Ohio NIOSH1 Division Surveillance, Hazard Evaluations and Field Studies, Cincinnati, Ohio, pp 107 Johnson PL (1976) Preliminary Industrial Hygiene Survey at Auto Brake Clinic, Cincinnati, Ohio NIOSH, Division Surveillance, Hazard Evaluations and Field Studies, Cincinnati, Ohio, pp 3 Sheehy JW, Godbey FW, Cooper TC, Lenihan KL, VanWagenen HD & McGlothlin JD (1987) In-Depth Survey Report: Control Technology for Brake Drum Brake Operations at Ohio Department of Transportation Report No: ECTB 152-18b. NIOSH, Division of Physical Sciences & Engineering, Cincinnati, Ohio, pp 33 Exhibit No. DescriDtion 106 107 108 109 110 111 112 113 114 115 115a 115b 115c 115d Sheehy JW, Todd WF, Cooper TC & VanWagenen HD (1987) In-Depth Survey Report Evaluation of Brake Drum Service Controls at Cincinnati Bell Maintenance Facility, Fairfax, Ohio Report No: ECTB 152-2lb. NIOSH, Division of Physical Sciences & Engineering, Cincinnati, Ohio, pp 26 Cooper TC, Sheehy JW, O'Brien DM, McGlothlin JD & Todd WF (1988) In-Depth Survey Report: Evaluation of Brake Drum Service Controls at Cincinnati, Evanston and Monroe Ohio and Covington, Kentucky Report No: ECTB l52-22b. NIOSH, Division of Physical Sciences & Engineering, Cincinnati, Ohio, pp 28. Almaguer D & Matte T (1987) Health Hazard Evaluation Report, Four Corporation, Clintonville, Wisconsin HETA 86-524-1851 Wheel Drive Pattern of Work Performed by 210 Vehicle Mechanics Chart Cumulative Lifetime Exposures Chart Lung Cancer Risks and Asbestos Exposure by Industry Sector Chart Occupational Exposure Limits and Exposure of Brake Repair Mechanics Chart Summary of Newhouse & Sullivan (1989), McDonald et al. (1986) Summary of Brake Mechanics' Risk of Asbestos-Related Disease Diagrams of Energy Dispersive Spectrums from Asbestos Minerals Chrysotile Anthophyllite Crocidolite Amosite Exhibit No. Description 116 117 118 119 120 121 122 123 124 Videotape Illustrating Testing Conducted in Connection vith Removal and Installation of Brake Shoe in Connection with Expert Testimony Anderson, A., Knapp, Robert A. (1989) Hot Spotting in Automotive Friction Systems Presented at the International Conference on Materials, Denver, CO, April 1989 Wear of Anderson, A.E., Gealer, R.L., McCune, R.C., Sprys, J.W. (1973) Asbestos Emissions from Brake Dynamometer Tests Automobile Engineering Meeting, Detroit, MI, May 1973 Amandus HE and Wheeler R (1987) The Morbidity and Mortality of Vermiculite Miners and Millers Exposed to Tremolite-Actinolite:Part II Mortality Amer 3, Industr. Med. 11 15-26 Rowlands N, Gibbs GW, McDonald AD (1982) Asbestos Fibers in the Lungs of Chrysotile.Miners and Millers -- A Preliminary Report Ann Occup Hyg 26 411-415 Vianna NJ, Maslowsky J, Roberts S, Spellman G & Patton RB (1981) Malignant Mesothelioma.' Epidemiologic Patterns in New York State. New York State J. Med., April, 735-738 Sebastien P, McDonald JC, McDonald AD, Case B & Harley R (1989) Respiratory Cancer in Chrysotile Textile and Mining Industries Exposure Inferences from Lung Analysis.. 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Ltd., Old Woking, Surrey, England pp 49-57 Timbrell V (1973) Physical Factors as Etiological Mechanisms In: Biological Effects of Mineral Fibers (Ed JC Wagner) , IARC Scientific Publication No 8, IARC, Lyon, France pp 295 -303 Allison AC (1973) Experimental Methods - Cell and Tissue Culture Effects of Asbestos Particles on Macrophages, Mesothelial Cells and Fibroblasts In: Biological Effects of Mineral Fibers (Ed JC Wagner), IARC Scientific Publication No 8, IARC, Lyon, France 89-93 Cohen D, Arai SF & Brain JO (1979) Smoking Impairs Long-Term Dust Clearance From the Lung Science 204 514-517 Morgan A & Cralley L (1973) Chemical Characteristics of Asbestos and Associated Trace Elements In: Biological Effects of Mineral Fibers (Ed JC Wagner), IARC Scientific Publication No 8 IARC, Lyon France 113-118 Exhibit No. Description 143 144 145 146 147 148 149 150 151 152 Stanton MF and Wrench C (1972) Mechanisms of Mesothelioma Induction with Asbestos and Fibrous Glass J. Hat Cancer Institute 48 797-821 Stanton M (1973) Some Etiological Considerations of Fibre Carcinogenesis In: Biological Effects of Asbestos (Ed Wagner JC), IARC Scientific Publications No 8, Lyon 289-294 Stanton MF and Layard M (1977) Carcinogenicity of Fibrous Glass: Pleural the Rat in Relation to Fiber Dimension J Natl. Cancer Inst. 58:587-603,1977 Response in Davis JMG (1972) The Fibrogenic Effects of Mineral the Pleural Cavity of Mice Brit J Exp Pathol 53 190-201 Dusts Injected into Davis JMG & Coniam SW (1973) Experimental Studies on the Effects of Heated Chrysotile Asbestos and Automobile Brake Lining Dust Injected into the Body Cavities of Mice Experimental and Molecular Pathology 19 339-353 Gross P (1968) Report on the Pulmonaly Response to Brake-Drum Dust: A Preliminary Investigation for Johns-Manville Corporation Industrial Hygiene Foundation - unpublished report. Vorwald AJ, Durkan TM & Pratt PV (1951) Experimental Studies of Asbestosis AKA Arch Ind Hyg Occup Med 3 1-13 Gibbs GW & Hwang CY (1980) Dimensions of Airborne Asbestos Fibers In: Biological Effects of Asbestos (Ed Wagner JC) Scientific Publications No 30Vol 1 Lyon 69-78 IARC McDonald AD & Fry JS (1982) Mesothelioma and Fibre Type in Three American Asbestos Factories Preliminary Report Scand J. Work Environ Health 8 suppl 153-58 McDonald JC (1984) Mineral Fibers and Cancer Annals of Academy of Medicine of Singapore 13 (s) 352 1984 34 5- Description 153 154 155 156 157 158 159 160 161 Lee GL (1970) Removing Dusts from Brake Assemblies ServicingAlternative Cleaning Methods Ann Occup Hyg 13 33-36 During Vehicle Castleman B, Camarota. LA, Fritsch AJ, Mazzocchi S & Crawley RG (1985) The Hazards of Asbestos for Brake Mechanics Public Health Reports 90 254-256 1985 Huncharek M, Muscat J & Capotorto JV (1989) Pleural Mesothelioma in a Brake Mechanic Brit J Industr Med 46 69-71 1989 McDonald JC (1985) Health Implications of. Environmental Asbestos Environ Health Perspectives 62 319-328 Exposure to McDonald JC (1988) Tremolite, Other Amphiboles and Mesothelioma Amer J Indust Med 14 247-249 McDonald JC & LiddellFDK (1979) Mortality in Canadian Miners and Canadian Chrysotile Ann NY Acad sci 330 1-10. Millers Exposed to Montanari AR, Pedro-Botet J, Ferrer ML, Momplet Otero FJF, Morato RF (1977) Asbestosis y cancer. Presentacion de neuve cacos Med Cin 68 215-222 JV, Newhouse ML & ThompsonH (1965) Mesothelioma of Pleura and Peritoneum Exposure to Asbestos in the London Area Brit J Industr Med 22 261-269 Following Paur R, Woitowitz HJ, Rodelsperger K & Jahn H (1985) Pleuramesotheliom nach Asbeststaubgefahrdung ' bei Bremsreparaturen im Kfz-Handwerk: Kasuistische Beobachttunge Praxis und Klinik der Pneumolode 139 362-366 Exhibit No. Description 162 163 164 165 166 167 168 169 Pooley FD & Clark NJ (1980) A Comparison of Fibre Dimensions in Chrysotile, Crocidolite and Amosite Particles from Samples of Airborne Dust and from Post-Mortem Lung Tissue Specimens In: Biological Effects of Mineral Fibers (Ed JC Wagner), IARC Scientific Publication.No 30, Vol 2 IARC, Lyon, France 79-86 Sullivan RJ & Athanassiadis YC (1969) Preliminary Air Pollution Survey of Asbestos National Air Pollution Control Administration, 69-271, Rayleigh,N.C. 1969, p 32 APTD Liddell FDK (1988) Epidemiological Observations on Mesothelioma and Their Implications for Non-Occupational Exposure to Asbestos In: Symposium on health aspects of exposure to asbestos in buildings, Dec 14-16 1988. Harvard University. Cambridge, Mass McDonald JC Sc McDonald AD (1977) Epidemiology of Mesothelioma from Estimated' Incidence Preventive Medicine 6 426-446 Damber LA & Larrson LG(1987) Occupation and Male Lung Cancer: A Case-Control in Northern Sweden Brit J Industr Med 44 446.-453 1987 Study Schwartz E (1987) Proportionate Mortality Ratio Analysis of Automobile Mechanics and Gasoline Service Station Workers in New Hampshire Amer J Industr Med 12 91-99 1987 Photocopy of Electron Micrographs of U.I.C.C. Chrysotile and S.A.E.D. Pattern McDonald AD, Fry JS, Woolley AJ and McDonald JC (1984) Cancer Risks in Asbestos Friction Products Manufacture In: Proceeding of Vlth International Pneumoconiosis Conference, Bochum 1983 747-767 1984 Exhibit No. DescriDtion 170 171 172 173 174 174a 174b 174C 175 175a 175b 175c Sebastian P, MDonald JC, McDonald AD, Case B and Harley R (1989) Respiratory Cancer in Chrycotile Textile and Mining Industries: Exposure Inferences from Lung Analysis Brit. J. Industr. Med. 1989:46:180-187 McDonald AD and McDonald JC (1980) Malignant Mesothelioma in North America Cancer 46:1650-1656, 1980 Weiss, William (1984) Cigarette Smoke,;. Asbestos, and Small Opacities Am. Rev.&RespiEjs*^)is\. 1984;130:293-301 Irregular Graham --(Apr*,1 ldsm The Risk, ^jofHeSith Effects in Vehicle Brake Main t"*V~n - a-nee & Repair Workers as a Result of Exposure to Dusts Associated with Brake Linings Plaintiffs' Answers and Supplemental Answers to Master Discovery Requests Thomas Ricketts Horace Rhodes James Mayo All independent medical evaluations, interpretations, pathology reports, and B-reading reports rendered by retained in this litigation. x-ray experts Thomas Ricketts Horace Rhodes James Mayo JJ7$9