Document N2GjdqqjZnkaZGz1yVJoMowag

plaintiffs exhibit 1 2 3 4 5 6 7 8 CALIFORNIA SUPERIOR COURT 9 CITY AND COUNTY OF SAN FRANCISCO 10 11 IN RE: ) ) 12 COMPLEX ASBESTOS LITIGATION ) ) 13 ) -------------------------------------------------------------------------------- ) 14 NO. 828684 PLAINTIFFS' STANDARD INTERROGATORIES TO ALL DEFENDANTS 15 PREFACE 16 These Interrogatories are to be answered pursuant to San Francisco Superior Court General 17 Order No. 129. 18 Unless otherwise specifically set forth, the time frame for response to these Interrogatories is 19 from 1930 until 1985; except where otherwise specifically set forth, each Interrogatory and each 20 Response are intended and should be construed as including and being limited to such time frame. 21 Where expressly stated with reference to the date and circumstances justifying use of such date, the 22 responding party may limit any such response to dates subsequent to 1930, but which in no event 23 are later than the inception of the responding party, including the inception of any predecessor in 24 interest. 25 Unless otherwise specifically set forth, the geographic scope for response to these 26 Interrogatories by domestic corporations is the United States. Hospitals and other health care entity 27 defendants shall provide responses related only to that defendant's physical facilities and shall not be 28 EXHIBIT I io GENERAL ORDER NO 129 1 required to disclose any information related to the furnishing of services to patients. 2 DEFINITIONS 3 1. "ASBESTOS-CONTAINING PRODUCT(S)" shall mean a product(s) which THIS 4 DEFENDANT knows or believes to have contained any amount of the mineral asbestos at any time. 5 2. "COMPANY" means any private enterprise including corporations, partnerships, joint 6 ventures, and sole proprietorships. 7 3. A "CONTRACT UNIT" shall mean a branch, division, subsidiary or other affiliated 8 entity of a DEFENDANT which has been or is now engaged in installation, disturbing or handling 9 and/or removal of RAW ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS. 10 4. "DOCUMENT(S)" or "WRITING(S)" shall include all writings as defined by Section 11 250 of the California Evidence Code. 12 5. "GEOGRAPHIC AREA" means the 46 counties of Northern California (Alameda, 13 Alpine, Amador, Butte, Calaveras, Colusa, Contra Costa, Del Norte, El Dorado, Fresno, Glenn, 14 Humboldt, Kem, Kings, Lake, Lassen, Marin, Mariposa, Mendocino, Merced, Modoc, Mono, 15 Monterey, Napa, Nevada, Placer, Plumas, Sacramento, San Francisco, San Joaquin, San Mateo, 16 Santa Clara, Santa Cruz, Shasta, Sierra, Siskiyou, Solano, Sonoma, Stanislaus, Sutter, Tehama, 17 Trinity, Tulare, Tuolumne, Yolo, Yuba) and military facilities/installations in the State of California, 18 or the following shipyards: Bethlehem Shipbuilding, San Pedro; California Shipbuilding, Terminal 19 Island; Consolidated Steel Shipyard^ Wilmington; Los Angeles Shipbuilding and Dry Dock aka L.A. 20 Ship, San Pedro; National Steel and Shipbuilding Corporation, San Diego; Todd Shipyards 21 Corporation, San Pedro; Triple "A" Machine, San Diego; Western Pipe and Steel Company, Los 22 Angeles and San Pedro Divisions; Naval Air Station, North Island; Thirty-second Street Naval 23 Repair Facility, San Diego; Long Beach Naval Shipyard; and San Diego Destroyer Base. 6. A request to "IDENTIFY" a "WRITING" or "DOCUMENT" or study shall mean a request to either attach such an exhibit to your answers to these Interrogatories, or to describe such with sufficient particularity that it may be made the subject of a request for production of documents. YOUR description should include an indication of: (a) the author; (b) addressee(s); (c) date of origin; (d) the nature of the writing or document (e.g., letter, telephone memorandum, audio tape recording, EXHIBIT t n GENERAL ORDER NO 129 -2- 1 photograph, etc.); and (e) its present location, name and present address of custodian thereof. 2 7. A request to "IDENTIFY" an oral communication shall mean a request to describe the j communication with particularity, and shall include the following information; (a) the identity of all 4 parties to the communication; (b) the identity of the person whom you contend initiated the 5 communication; (c) the identity of all persons present at the time of the communication; and (d) the 6 time, date and place of the communication. 7 8. A request to "IDENTIFY" or to state the "IDENTITY" of a person or individual 8 means to state his or her name, the place of employment, job title, present business or present or last 9 known home address, years of employment and last known telephone number if not employed by 10 DEFENDANT. 11 9. A request to "IDENTIFY" the product shall mean a request to describe the product, 12 the material or compound by the following means: (1) by nickname or slang name used in your 13 industry and/or occupation; (2) by the name under which it is sold in the marketplace (trade name); 14 (3) by its generic name; and (4) by manufacturer. 15 10. "MARKETING" or "MARKETED" shall mean the mining, supply, sale, labeling, 16 distribution, importing, processing or manufacture of RAW ASBESTOS and/or ASBESTOS- 17 CONTAINING PRODUCT(S). 18 11. A request to describe the "NATURE" of a product means to describe the; (a) color; 19 (b) texture; (c) form (i.e., powder, liquid, paste, solid, board, cloth, blanket, wire insulation, etc.); (d) 20 physical dimensions, if solid (length, width and height); (e) the type of shipping package and 21 shipping package dimensions if not solid; (f) type of asbestos fiber used in the composition of the product (e.g., chrysotile, amosite, crocidolite); (g) the intended use or function of such product as recommended by this DEFENDANT as the miner, producer, supplier, contractor, manufacturer, distributor, owner or seller; and (h) the type of worksite in which it was intended to be used (e.g., shipyard, refinery, commercial building construction, manufacturing plant, home, power generating plant, etc.). 12. "PREMISES" includes, but is not limited to, buildings, structures in a refinery, boilers, generators, tract housing, commercial buildings and other such structures. EXHIBIT I to GENERAL ORDER NO 129 -3 - 1 13. "RAW ASBESTOS" means asbestos fiber mined or milled, either packaged or in 2 bulk, not compounded with other substances and essentially pure with the exception of naturally 3 occurring trace amounts of other substances. 4 14. "THIS DEFENDANT" or "DEFENDANT" shall mean the named defendant herein, 5 all of its divisions and subsidiaries in which it holds a controlling interest, and all "alternate entities" 6 as defined and identified by name in any complaint pending against YOU as of the date of your 7 answers. 8 15. "YOU" and "YOUR" refer to the DEFENDANT who is named above as responding 9 party. 10 INTERROGATORIES 11 INTERROGATORY NO. 1: 12 IDENTIFY the person verifying these answers on YOUR behalf. 13 INTERROGATORY NO. 2: 14 State the date of first employment with YOU, and the dates and titles of each job position the 15 person verifying these interrogatories has held while employed by YOU. 16 INTERROGATORY NO. 3; 17 State whether or not YOU are a corporation, and if so, state: 18 A. YOUR correct corporate name; 19 B. YOUR state of incorporation; 20 C. The date of YOUR incorporation; 21 D. The address of YOUR principal place of business; E. Whether or not YOU have ever held a certificate of authority to do business in the State of California, and if so, the inclusive dates of any certificate; F. If YOU are wholly owned or the majority interest of YOUR company is owned by another business entity, state the entity's name and principal place of business; G. Whether YOU have any business offices in California, and, if so, YOUR principal place of business in California. Ill EXHIBIT 1 to GENERAL ORDEX NO 129 -4- 1 INTERROGATORY NO. 4: 2 Have YOU ever been identified, known, or done business under any other name in the State 3 of California? 4 INTERROGATORY NO. 5: 5 If your answer to Interrogatory No. 4 is in the affirmative, please state such name or names 6 and the time period during which THIS DEFENDANT was so known or identified. 7 INTERROGATORY NO. 6: 8 If YOU are not a corporation, what is YOUR business structure (partnership, joint venture, 9 sole proprietorship, etc.). 10 INTERROGATORY NO. 7: 11 If YOU are not a corporation, please IDENTIFY all persons or other entities with an 12 ownership interest in YOU. 13 INTERROGATORY NO, 8: 14 If you are not a corporation, please state the following: 15 A. The address where the HISTORICAL RECORDS of THIS DEFENDANT are 16 currently located; and 17 B. The name, job title and current address of the Custodian for THIS 18 DEFENDANTS HISTORICAL RECORDS. 19 As used herein, "HISTORICAL RECORDS" shall include all DOCUMENTS relating to the 20 formation of THIS DEFENDANT, all minutes of partners', general partners', or other owners' 21 meetings, and all DOCUMENTS relating to THIS DEFENDANTS merger with, acquisition of or 22 purchase, or sale of or by any other COMPANY. 23 INTERROGATORY NO. 9: 24 IDENTIFY YOUR custodian of Business Records. 25 INTERROGATORY NO. 10: IDENTIFY the person or persons most knowledgeable about: A. YOUR acquisition of RAW ASBESTOS and/or ASBESTOS CONTAINING PRODUCTS; EXHIBIT I u> GENERAL ORDER NO 129 -5- 1 B. YOUR use of RAW ASBESTOS and/or ASBESTOS CONTAINING 2 PRODUCTS; 3 C. YOUR contracting with others to do work involving use or handling of RAW 4 ASBESTOS or ASBESTOS CONTAINING PRODUCTS. 5 INTERROGATORY NO. 11: 6 For DEFENDANTS involved in the MARKETING of ASBESTOS-CONTAINING 7 PRODUCTS, state the IDENTITY of physicians, medical directors and/or industrial hygienists 8 employed by YOU during the time frame or prior to the time YOU discontinued the marketing of 9 such products. All other DEFENDANTS need only respond as to medical directors and/or 10 industrial hygienists or physicians employed in the area of employee health and safety. PREMISES 11 owners and domestic corporations need only respond as to the United States. 12 INTERROGATORY NO. 12 : 13 Has any employee of THIS DEFENDANT testified by deposition or at trial on behalf of 14 THIS DEFENDANT in a third-party case, in which THIS DEFENDANT was a party, wherein the 15 plaintiff has alleged an asbestos-related injury? If so, for each such third-party case (except that 16 Premises Defendants and Contractor Defendants need answer only with respect to cases relating to 17 sites within the GEOGRAPHIC AREA) please state: 18 A. The caption and case number; 19 B. The court filing including state and county; 20 C. The date of deposition or trial testimony; 21 D. The name and address of plaintiffs counsel of record; 22 E. The name and address of the court reporter. 23 INTERROGATORY NO. 13: 24 For each of the following, please state whether, at any time within the time frame or until 25 such time as any defendant which had been engaged in MARKETING RAW ASBESTOS or 26 ASBESTOS- CONTAINING PRODUCTS discontinued the MARKETING of such products, THIS 27 DEFENDANT was a member or paid dues for any representative of THIS DEFENDANT (excluding 28 faculty members of educational institutions) to be a member of the following: EXHIBIT I to GENERAL ORDER NO 129 -6- 1 A. American Conference of Governmental Industrial Hygienists; 2 B. American Industrial Hygiene Association; 3 C. American Petroleum Institute; 4 D. American Railroad Association; 5 E. Asbestos Cement Producers Association; 6 F. Asbestos Information Association (AIA)(please answer through date of your 7 answers); 8 G. Asbestos Information Association/North America (AIA/NA)(please answer 9 through date of your answers); 10 H. Asbestos Textile Institute (ATI); 11 I. Industrial Hygiene Foundation and/or Industrial Health Foundation (IHF): 12 J. Industrial Mineral Insulation Manufacturers Institute; 13 K. Magnesia Insulation Manufacturers' Association; 14 L. Magnesia Silica Insulation Manufacturers Association; 15 M. Mineral Wool Institute; 16 N. National Insulation Manufacturers Association (NIMA); 17 O. National Safety Council; 18 P. New York Academy of Sciences; 19 Q. Quebec Asbestos Mining Association (QAMA); 20 R. Refractories Institute; 21 S. Safe Building Alliance (please answer through date of your answers); 22 T. Thermal Insulation Manufacturers Association (TIMA); 23 U. U.S. Maritime Commission; V. IDENTIFY any other organizations, associations or groups of manufacturers, miners, distributors, importers, labelers, suppliers, and/or sellers of ASBESTOS-CONTAINING PRODUCTS of which THIS DEFENDANT was a member; W. IDENTIFY any such representative of THIS DEFENDANT. Ill EXHIBIT I to GENERAL ORDEX NO 129 -7- I INTERROGATORY NO. 14: 2 For each organization, association or other entity identified in YOUR Response to 3 Interrogatory No. 13, please state: 4 A. The dates during which THIS DEFENDANT was a member; 5 B. The name(s) of any publication(s) received by THIS DEFENDANT from such 6 association or organization; 7 C. The name of any committee or subcommittee of which THIS DEFENDANT 8 was a member, and the dates of such committee or subcommittee membership. 9 INTERROGATORY NO. 15: 10 Had THIS DEFENDANT prior to 1973 received any DOCUMENTS containing results or 11 conclusions of any studies and/or tests conducted by Bonsib for Standard Oil of New Jersey relating 12 to asbestos exposure in the workplace or the human health consequences of exposure to asbestos? If 13 so: 14 A. Either (1) attach all DOCUMENTS evidencing the information sought in this 15 Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing 16 such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made 17 the subject of a request for production of documents. 18 B. State the date upon which THIS DEFENDANT first received such 19 DOCUMENTS; 20 C. State the IDENTITY of the custodian of such DOCUMENTS. 21 D. This interrogatory does not apply to DOCUMENTS contained in a library 22 maintained by a DEFENDANT hospital or a DEFENDANTS library providing access to the general 23 public. 24 INTERROGATORY NO. 16: 25 Had THIS DEFENDANT prior to 1973 received a copy or any portion of any studies and/or 26 tests conducted by any insurance company, including but not limited to Metropolitan Life Insurance 27 Company and Aetna Insurance relating to asbestos exposure in the workplace or the human health 28 consequences of exposure to asbestos? If so: EXHIBIT llo GENERAL ORDER NO 129 -8- 1 A. Either (1) attach all DOCUMENTS evidencing the information sought in this 2 Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing 3 such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made 4 the subject of a request for production of documents. 5 B. State the date upon which THIS DEFENDANT first received such 6 DOCUMENTS; 7 C. State the IDENTITY of the custodian of such DOCUMENTS. 8 D. This interrogatory does qq! apply to DOCUMENTS contained in a library 9 maintained by a DEFENDANT hospital or a DEFENDANTS library providing access to the general 10 public. 11 INTERROGATORY NO. 17: 12 Had THIS DEFENDANT prior to 1973 received any DOCUMENTS containing results or 13 conclusions of any studies and/or tests conducted by any laboratory, including but not limited to, the 14 Saranac Laboratory relating to asbestos exposure in the workplace or the human health consequences 15 of exposure to asbestos? If so: 16 A. Either (1) attach all DOCUMENTS evidencing the information sought in this 17 Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing 18 such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made 19 the subject of a request for production of documents. 20 B. State the date upon which THIS DEFENDANT first received such 21 DOCUMENTS; C. State the IDENTITY of the custodian of such DOCUMENTS. D. This interrogatory does qqI apply to DOCUMENTS contained in a library maintained by a DEFENDANT hospital or a DEFENDANTS library providing access to the general public. INTERROGATORY NO. 18: Had THIS DEFENDANT (except for a defendant that is an educational institution) prior to 1973 ever maintained a library (or libraries) which contained books, articles, periodicals, journals, EXHIBIT I to GENERAL ORDER NO 129 -9- 1 and/or reference materials that related to the subjects of asbestos, industrial hygiene, medicine, safety 2 and/or occupational disease. If so, state: j A. The date each such library was established; 4 B. The location of each such library; 5 C. The IDENTITY of each librarian or other person in charge of such library. 6 INTERROGATORY NO. 19: 7 With the exception of OSHA compliance, had THIS DEFENDANT (except for a defendant 8 that is an educational institution) prior to 1980 exchanged DOCUMENTS or communicated with any 9 person or other COMPANY expressly regarding the results of tests and/or studies relating to 10 asbestos exposure in the workplace or the human health consequences of exposure to asbestos? If 11 so, state: 12 A. Each person or COMPANY with whom the information was exchanged or to 13 whom it was communicated. 14 B. The date(s) of any such exchanges or communications; 15 C. The IDENTITY of the custodian of such DOCUMENTS. 16 INTERROGATORY NO. 20: 17 Has any employee or designee of THIS DEFENDANT testified as a representative of THIS 18 DEFENDANT before the Occupational Safety and Health Administration, the National Institute of 19 Occupational Safety and Health, or any committee or subcommittee of the United States Congress 20 relating to asbestos exposure in the workplace or the human health consequences of exposure to 21 asbestos? If so, please state: 22 A. The entity before whom such testimony was given; B. The date(s) and location(s) of such testimony; C. The IDENTITY of the individual(s) who so testified; D. Whether any DOCUMENTS were presented to the entity before which testimony was given; E. Whether copies of DOCUMENTS presented were retained by THIS DEFENDANT and, if so, state the IDENTITY of the custodian of such DOCUMENTS. EXHIBIT ! to GENERAL ORDER NO 129 - 10- 1 INTERROGATORY NO. 21: 2 Has THIS DEFENDANT (except for a defendant that is an educational institution) 3 conducted, or caused to be conducted, tests, and/or studies of ambient asbestos dust created during 4 the manufacture, processing and/or assembling for sale of ASBESTOS-CONTAINING 5 PRODUCTS? If so. state: 6 A. Each manufacturing facility, including location and address, at which any such 7 test and/or study was conducted; 8 B. The date of each such test and/or study; 9 C. The individual(s) or entity conducting each such test and/or study; 10 D. Whether THIS DEFENDANT has any DOCUMENTS containing the results 11 and/or conclusions of each such study; 12 E. The IDENTITY of the custodian of such DOCUMENTS. 13 INTERROGATORY NO. 22: 14 Has THIS DEFENDANT (except for a defendant that is an educational institution) 15 conducted, or caused to be conducted, any tests and/or studies on ambient asbestos dust levels at any 16 location or job site where ASBESTOS-CONTAINING PRODUCTS were installed, utilized or 17 removed? If so, for the first 5 tests and/or studies, state: 18 A. The location, including name and address, at which each such test and/or 19 study was conducted; 20 B. The individual(s) or entity conducting each such test and/or study; 21 C. The date of each such test and/or study; 22 D. Whether THIS DEFENDANT has any DOCUMENTS containing the results 23 and/or conclusions of each such test and/or study; 24 E. The IDENTITY of the custodian of such DOCUMENTS. 25 INTERROGATORY NO. 23: 26 Did THIS DEFENDANT (except for a defendant that is an educational institution) have any 27 laboratory or other similar type of facility anywhere in the United States at which it conducted, or 28 caused to be conducted, any tests and/or studies of ASBESTOS-CONTAINING PRODUCTS or EXHIBIT I to GENERAL ORDER NO 129 - 11 - 1 RAW ASBESTOS relating to the health consequences of asbestos or the dust generated by any use 2 of asbestos or ASBESTOS-CONTAINING PRODUCTS. If so, state: 3 A. The location, including name and address, at which each test and/or study was 4 conducted; 5 B. The individual(s) or entity conducting each such test and/or study; 6 C. The date of each such test and/or study; 7 D. Whether THIS DEFENDANT has any DOCUMENTS containing the results 8 and/or conclusions of each such test and/or study; 9 E. The IDENTITY of the custodian of such DOCUMENTS. 10 INTERROGATORY NO. 24: 11 Has THIS DEFENDANT made available to its employees a medical examination program to 12 determine the absence or presence of asbestos-related disease? If so, state: 13 A. Whether chest x-rays or pulmonary function tests were part of such 14 program(s); 15 B. Whether participation in any such program was a mandatory condition of 16 employment or was voluntary; 17 C. Whether THIS DEFENDANT has DOCUMENTS of such program(s); 18 D. The IDENTITY of the custodian of such DOCUMENTS. 19 INTERROGATORY NO. 25; 20 Prior to 1973, did any person file a Workers' Compensation claim for asbestos-related injury 21 against THIS DEFENDANT or against any Workers' Compensation insurance carrier which 22 provided coverage for THIS DEFENDANT? If so, state the total number of such claims and, for the 23 first 20 such claims state: 24 A. The date of such claim; 25 B. The name of the claimant; 26 C. The case number, 27 D. The court in which the claim was filed; 28 E. The IDENTITY of THIS DEFENDANTS custodian of DOCUMENTS EXHIBIT I to GENERAL ORDER NO 129 -12- 1 evidencing such claims. 2 INTERROGATORY NO. 26: 3 Does THIS DEFENDANT have insurance available to cover judgment(s) entered against it in 4 asbestos-related personal injury lawsuits? If so, state: 5 A. The name and principal place of business of any insurance carrier who has 6 issued such policy of insurance; 7 B. The number and effective date of each policy; 8 C. The amount(s) of coverage of each policy; 9 D. The applicable dates of coverage. 10 INTERROGATORY NO. 27: 11 State whether YOU have controlled, purchased, or in any way acquired any controlling 12 interest in any corporation or business entity which has mined, manufactured, produced, processed, 13 compounded, sold, supplied, distributed and/or otherwise placed RAW ASBESTOS or ASBESTOS- 14 CONTAINING PRODUCTS in the stream of commerce. If so, state: 15 A. The name and address of said corporation or business entity; 16 B. The dates YOU controlled, purchased or acquired any interest; and 17 C. The nature of the business as it pertains to asbestos. 18 INTERROGATORY NO. 28: 19 State whether THIS DEFENDANT, between 1930 and 1985, has ever engaged in the 20 following activities with regard to RAW ASBESTOS, and if so, state the inclusive dates of such 21 activity: 22 A. Mining; 23 B. Milling; 24 C. Supply; 25 D. Importing; 26 E. Processing; 27 F. Distribution; 28 G. Marketing; EXHIBIT I to GENERAL ORDER NO 29 - 13 - 1 H. Sale; 2 I. Brokering. 3 INTERROGATORY NO, 29: 4 If YOUR answer to any of subparts of Interrogatory 28 regarding RAW ASBESTOS is in 5 the affirmative, state: 6 A. The trade, brand name, and/or generic name of such RAW ASBESTOS milled 7 or MARKETED in any form or quantity between 1930 and 1985; 8 B. The date(s) such RAW ASBESTOS was first placed on the market, including 9 the date(s) such RAW ASBESTOS was first marketed; 10 1. On an experimental basis; 11 2. On a test basis; 12 3. For sale. 13 C. The date(s) such RAW ASBESTOS: 14 1. Ceased to be produced; or 15 2. Was recalled from the market, if ever. 16 D. A description of the chemical composition of such RAW ASBESTOS, 17 including the type and/or grade of asbestos; 18 E. A description of the physical appearance and nature of such RAW 19 ASBESTOS, including any color coding, distinctive marking and/or logo on the packaging or 20 container; 21 F. A detailed description of the intended use of such RAW ASBESTOS, 22 including any temperature limits for each such use; 23 G. Whether such RAW ASBESTOS was on the U.S. Government's "Qualified 24 Products List," and if so, the inclusive dates it was on such list; 25 H. IDENTIFY to whom such RAW ASBESTOS has, at any time, been sold. As 26 to each such, state: 27 I. Whether any of THIS DEFENDANTS RAW ASBESTOS has, at any time, 28 been sold, shipped, or otherwise distributed, used or installed to or at any COMPANY (including EXHIBIT 1 GENERAL ORDER NO 129 - 14- 1 power company or utility), governmental agency or entity, shipyard, distributor, refinery, contractor, 2 supplier, PREMISE owner or occupant, ship owner, or other PREMISE or site in the 3 GEOGRAPHIC AREA and whether any of THIS DEFENDANTS RAW ASBESTOS has at any 4 time, been sold to any manufacturer, or manufacturing facility, of ASBESTOS-CONTAINING 5 PRODUCTS. If so, state: 6 1. The names of each such COMPANY, governmental agency or entity', 7 shipyard, distributor, supplier, manufacturer or refinery; 8 2. The inclusive dates of each such sale, and the amount (quantity) and 9 the trade brand name of such RAW ASBESTOS sold; 10 3. The manner of shipment (e.g. boat, rail, etc.) 11 4. Whether you have any records indicating any such sale or shipment 12 and, if so, the name, address and job classification of each person who currently has possession of 13 such records. 14 5. Either (1) attach all DOCUMENTS evidencing the information sought 15 in this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks 16 containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may 17 be made the subject of a request for production of documents. 18 INTERROGATORY NO. 30: 19 Between 1930 and 1985, did YOU ever engage in any of the activities listed below with 20 regard to ASBESTOS-CONTAINING PRODUCTS? If so, state the inclusive dates of such activity: 21 A. Supply; B. Importing; C. Distribution; D. Marketing; E. Sale; F. Labeling; G. Manufacturing; H. Brokering; EXHIBIT I id GENERAL ORDER NO 129 - 15- 1 INTERROGATORY NO. 31; 2 If your answer to any subpart of Interrogatory No. 31 regarding "ASBESTOS- 3 CONTAINING PRODUCTS" is in the affirmative, state: 4 A. The trade, brand name, and/or generic name of each such ASBESTOS- 5 CONTAINING PRODUCT MARKETED in any form or quantity between 1930 and 1985; 6 B. The date(s) each such ASBESTOS-CONTAINING PRODUCT was first 7 placed on the market, including the date(s) each such ASBESTOS-CONTAINING PRODUCT was 8 first MARKETED; 9 1. On an experimentalbasis; 10 2. On a test basis; or 11 3. For sale. 12 C. The date(s) each such ASBESTOS-CONTAINING PRODUCT: 13 1. Ceased to be produced; or 14 2. Was recalled from the market, if ever. 15 D. A detailed description of the chemical composition of each such ASBESTOS- 16 CONTAINING PRODUCT, including the type and/or grade of asbestos and/or asbestos fiber 17 contained in each such product and the quantitative percentage of asbestos or asbestos fiber in each 18 such product, and all non-asbestos components of the ASBESTOS-CONTAINING PRODUCT, and 19 if the chemical composition changed over time, the inclusive dates of each formulation; 20 E. A description of the physical appearance and nature of each such 21 ASBESTOS-CONTAINING PRODUCT, including any color coding, distinctive marking and/or 22 logo, either on the product or on the packaging; 23 F. A detailed description of the intended use of each such ASBESTOS- 24 CONTAINING PRODUCT, including any temperature limits for each such use; 25 G. Whether any such ASBESTOS-CONTAINING PRODUCT was on the U.S. 26 Government's "Qualified Products List," and if so, the inclusive dates it was on such list; 27 H. The name and address of the supplier of the RAW ASBESTOS used in each 28 such product and the time period of such supply; EXHIBIT I GENEJLAL OHDEX NO 129 - 16- 1 I. Whether any of THIS DEFENDANTS RAW ASBESTOS OR ASBESTOS- 2 CONTAINING PRODUCTS have, at any time, been sold, shipped, or otherwise distributed to any 3 COMPANY (including power company or utility), governmental agency or entity, shipyard, 4 distributor, refinery, contractor, supplier, manufacturer, PREMISE owner or occupant, ship owner, 5 or other PREMISE or site in the GEOGRAPHIC AREA. If so, state: 6 1. The names of each such COMPANY, governmental agency or entity, 7 shipyard, distributor, supplier, manufacturer, refinery, contractor, PREMISE owner or occupant, ship 8 ov/ner, PREMISE or site; 9 2. The inclusive dates of each such sale, shipment, distribution, use or 10 installation and the amount (volume) and the trade or brand name of each such ASBESTOS- 11 CONTAINING PRODUCT sold; 12 3. Whether you have any records indicating any such sale, shipment, 13 distribution, use or installation and, if so, the name, address and job classification of each person 14 who currently has possession of such records. 15 J. Either (1) attach all DOCUMENTS evidencing the information sought in this 16 Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing 17 such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made 18 the subject of a request for production of documents. 19 INTERROGATORY NO. 32 (PREMISES DEFENDANTS only) 20 Did YOU install, remove, or handle or contract to have others install, remove, or handle 21 RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS at any PREMISES in the 22 GEOGRAPHIC AREA which PREMISES is at issue as to YOU in San Francisco Superior Court 23 asbestos litigation as of the date of your answers to these interrogatories? If so: 24 A. IDENTIFY the PREMISES. 25 B. For each of the PREMISES: 26 1. State the nature of your ownership or possessory interest; 27 2. State the inclusive date of that interest; 28 3. EXHmm general order no 129 IDENTIFY the party from whom that interest was acquired; - 17- 1 4. IDENTIFY the party, if any, to whom that interest was transferred. 2 C. IDENTIFY every contract to which YOU were a party or of which you have 3 knowledge wherein the performance of such contract involved the installation, removal, disturbing 4 or handling of any RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS at YOUR 5 PREMISES. For each such contract: 6 1. IDENTIFY the parties to the contract; 7 2. Provide a general description and specific location of the work to be 8 performed by each party to the contract; 9 3. IDENTIFY and describe the NATURE of the RAW ASBESTOS or 10 ASBESTOS-CONTAINING PRODUCTS installed, removed, disturbed or handled in the 11 performance of the contract; 12 4. State the dates of the contract and the dates of performance; 13 D. Except as provided in response to subpart (c), has any work other than routine 14 maintenance been done on or to the PREMISES that involved the installation, removal, disturbing or 15 handling of RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS? If so, for each such 16 instance: 17 1. State the inclusive dates of the work; 18 2. Provide a general description and specific location of the work; 19 3. State whether the work was done by YOU and/or YOUR employees; 20 4. IDENTIFY and describe the NATURE of the RAW ASBESTOS or 21 ASBESTOS-CONTAINING PRODUCTS installed, removed, handled or disturbed; 22 5. IDENTIFY from whom the RAW ASBESTOS OR ASBESTOS- 23 CONTAINING PRODUCTS were acquired. 24 E. Has any asbestos abatement effort been made at the PREMISES? If so, for 25 each such effort: 26 1. IDENTIFY who did the work; 27 2. State the inclusive dates thereof; 28 3. State whether samples were taken, and, if the samples still exist. EXHIBIT I w GENERAL ORDER NO 129 - 18- 1 IDENTIFY the custodian of the samples; 2 3 of each test; 4. State whether any material was tested, and, if so, what were the results 4 5. IDENTIFY each test result with sufficient particularity for purposes of 5 a request for production of documents, or, in the alternative, attach a copy to YOUR answers to these 6 interrogatories. 7 F. Except for insurance coverage litigation, have you filed suit against, or 8 otherwise sought to recover from, any person or entity for some or all of the cost of asbestos 9 abatement or for the property damage allegedly caused by the presence of RAW ASBESTOS or 10 ASBESTOS-CONTAINING PRODUCTS on the PREMISES identified in response to subpart (A) 11 above? If so: 12 1. IDENTIFY the person or entity against whom YOU have filed suit or 13 otherwise sought to recover; 14 2. If YOU have filed suit, state the court in which the action was filed, 15 the date on which it was filed, IDENTIFY all Plaintiffs and Defendants and their counsel of record; 16 3. State whether or not the case has been resolved, and, if so, what was 17 the status or disposition. 18 G. Either (1) attach all DOCUMENTS evidencing the information sought in this 19 Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing 20 such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made 21 the subject of a request for production of documents. 22 H. IDENTIFY the person(s) presently most knowledgeable about the information 23 sought in this interrogatory or its subparts. 24 INTERROGATORY NO. 33 (CONTRACTOR DEFENDANTS only) 25 At any time between 1930 and 1985, did YOU hold a contractor's license in the State of California? If so: A. IDENTIFY each license by type, date and number. B. If on the date of your answers YOU are a defendant in four or more asbestos EXHIBrT I to GENERAL ORDER NO 129 -19- 1 actions in San Francisco Superior Court, IDENTIFY each job or contract that YOU performed 2 (directly or through one or more subcontractors) during this time period for work in any PREMISES 3 which is at issue as to YOU on such date, and in any PREMISES of 50,000 square feet or more in 4 the GEOGRAPHIC AREA which job or contract involved installation, removal, disturbing or 5 handling RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS. (Alternatively, at your 6 option, you may IDENTIFY each job or contract YOU performed (directly or through one or more 7 subcontractors) during this time frame for all work, or for all work on PREMISES of 50,000 square 8 feet or more, in the GEOGRAPHIC AREA.) As to each such job or contract: 9 1. IDENTIFY the location (including name of ship, if applicable) where 10 the job or work was performed; 11 2. State the date of the contract or the inclusive dates of the work; 12 3. IDENTIFY the person or entity with whom you contracted; 13 4. State your job or contract number. 14 C. If on the date of your answers you are not a defendant in four or more 15 asbestos actions in San Francisco Superior Court, IDENTIFY each job or contract that YOU 16 performed (directly or through one or more subcontractors) during this time period for work in any 17 PREMISES which is at issue as to YOU on such date. As to each such job or contract: 18 1. IDENTIFY the location (including name of ship, if applicable) where 19 the job or work was performed; 20 2. State the date of the contract or the inclusive dates of the work; 21 3. IDENTIFY the person or entity with whom you contracted; 22 4. State your job or contract number. 23 INTERROGATORY NO. 34: 24 Did any of the distributors identified in your Answer to Interrogatory Nos. 29 and 31 above 25 have an exclusive distributorship? If so, state the relevant time period. 26 INTERROGATORY NO. 35: 27 If THIS DEFENDANT entered into any agreements for the rebranding of any ASBESTOS- 28 CONTAINING PRODUCTS by THIS DEFENDANT for resale or distribution by another person or EXHIBIT I id (SNERAL ORDER NO 129 -20- 1 entity, describe each agreement's terms and the parties to said agreement, the duration of the 2 agreement, and name of each product(s) and/or material(s) covered by each such agreement. 3 INTERROGATORY NO. 36: 4 If THIS DEFENDANT entered into any agreements for the rebranding of ASBESTOS- 5 CONTAINING PRODUCTS manufactured, sold, supplied or distributed by another person or entity 6 for resale or distribution by YOU, describe each of the agreements and the parties to said agreement, 7 the terms, the duration, and the names of each product(s) and/or material(s) covered by each such 8 agreement. 9 INTERROGATORY NO. 37: 10 As to RAW ASBESTOS and to each such ASBESTOS-CONTAINING PRODUCT listed in 11 YOUR responses to Interrogatories No. 29 and 31 did DEFENDANT warn of the health hazards of 12 asbestos? If so, state for each such warning: 13 A. The content, size, color, and location; whether the warning appeared on the 14 material and/or on the container, and/or was placed on a tag; whether the warning was included in 15 contracts; whether the warning was included in advertising or other promotional materials. 16 B. State whether you have any photographs thereof; 17 C. The inclusive dates on which you used each such warning; 18 D. State all changes you made in such warnings and the dates of such changes; 19 and 20 E. Identify the person most knowledgeable about your warnings and warning 21 policy. 22 INTERROGATORY NO. 38: 23 With respect to each of YOUR ASBESTOS-CONTAINING PRODUCTS, state whether 24 THIS DEFENDANTS name, a trademark, logos, color coding, or other identifying markings ever 25 appeared on the actual product itself. If so, IDENTIFY each such product, state when the practice to place such identifying markings upon the product was begun and when it ended, if applicable, and describe in detail the pertinent marking(s) and the purpose, if any, of such markings. Ill EXHIBIT 1 GENERAL ORDER NO 129 -21 - 1 INTERROGATORY NO. 39; 2 Between the years 1930 to 1985, did THIS DEFENDANT purchase or otherwise acquire any 3 ASBESTOS-CONTAINING PRODUCT lines from another person or entity? If so, state for each 4 such purchase: 5 A. Date of purchase or acquisition; 6 B. Terms of purchase or acquisition agreement; 7 C. Either (1) attach all DOCUMENTS evidencing said acquisition, or (2) attach 8 disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they 9 may be made the subject of a request for production of documents. 10 D. Trade, brand, and/or generic name of each such product line so acquired; 11 E. Name of the person or entity from whom YOU purchased or acquired each 12 such ASBESTOS-CONTAINING PRODUCT line; and 13 F. Location of any manufacturing facilities so acquired, and the type of 14 ASBESTOS-CONTAINING PRODUCTS manufactured therein. 15 INTERROGATORY NO. 40; 16 Between the years 1930 to 1985, did THIS DEFENDANT sell any ASBESTOS- 17 CONTAINING PRODUCT line to another person or entity? If so, state for each such sale: 18 A. Date of sale; 19 B. Terms of sales agreement; 20 C. Either (1) attach all DOCUMENTS evidencing said sale, or (2) attach disks 21 containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may 22 be made the subject of a request for production of documents. 23 D. Trade, brand, and/or generic name of each such product line sold; 24 E. Name of person or entity to whom you sold each such ASBESTOS- 25 CONTAINING PRODUCTS line; and 26 F. Location of any manufacturing facilities so sold, and the type of ASBESTOS- 27 CONTAINING PRODUCTS manufactured therein. 28 Ill EXHIBIT I id GENERAL ORDER NO 129 -22- 1 INTERROGATORY NO. 41: 2 IDENTIFY all brochures, pamphlets, catalogs or other advertising relating to ASBESTOS- j CONTAINING PRODUCTS and/or RAW ASBESTOS which THIS DEFENDANT manufactured, 4 sold, distributed or supplied from the year 1930 to 1985. For each such document, state: 5 A. A description of the document; 6 B. The year it was printed; 7 C. The period of time in which it was used; 8 D. The purpose of such document; 9 E. Whether the documents or copies of said documents presently exist; 10 F. If said documents or copies still exist, where they are located; and 11 G. The IDENTITY of the custodian of such documents. 12 INTERROGATORY NO. 42: 13 State if YOU have or had within YOUR corporate or other business structure any 14 CONTRACT UNITS. 15 INTERROGATORY NO. 43: 16 State whether or not any of YOUR CONTRACT UNITS installed and/or removed RAW 17 ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS in the GEOGRAPHIC AREA at any 18 time between 1930 and 1985. If so: 19 A. State the business addresses and name of the CONTRACT UNIT; 20 B. State the inclusive periods of time the CONTRACT UNITS were working in 21 the GEOGRAPHIC AREA; 22 C. State the name and address of each job site within the GEOGRAPHIC AREA 23 and the dates the CONTRACT UNIT worked at those job sites, and, IDENTIFY the RAW 24 ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS installed or removed on each 25 occasion; 26 D. Either (1) attach all DOCUMENTS evidencing the information sought in this 27 Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing 28 such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made EXHIBIT I a GENERAL ORDEX NO 129 - 23 - 1 the subject of a request for production of documents. 2 INTERROGATORY NO. 44: 3 When do YOU contend that THIS DEFENDANT first became aware that there is an 4 association between asbestos exposure and disease in human beings? 5 INTERROGATORY NO. 45i 6 How do YOU contend that THIS DEFENDANT first became aware that there is an 7 association between asbestos exposure and disease in human beings. 8 INTERROGATORY NO. 46; 9 Either (1) attach all DOCUMENTS evidencing the information upon which YOUR 10 contentions in YOUR answers to Interrogatories No. 44 and No. 45 are based, or (2) attach disks 11 containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may 12 be made the subject of a request for production of documents. 13 INTERROGATORY NO, 47: 14 When did THIS DEFENDANT first warn its employees that exposure to asbestos could be 15 hazardous to human health? State: 16 A. Whether the first such warning was written or oral; 17 B. Whether copies of DOCUMENTS containing such warning exist; 18 C. The IDENTITY of the custodian of such DOCUMENTS; 19 D. The content of the warning. 20 INTERROGATORY NO. 48: 21 Did THIS DEFENDANT ever issue a written COMPANY policy discontinuing warning its 22 employees that exposure to asbestos could be hazardous to human health? If so, 23 A. Provide the date; B. Describe the circumstances; and C. Either (1) attach all DOCUMENTS evidencing the information sought in this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents. EXHBrT I a GENEXAL OHM* NO 129 -24- 1 INTERROGATORY NO. 49 : 2 Did THIS DEFENDANT provide any Independent Contractor or Subcontractor within the 3 GEOGRAPHIC AREA with a written warning that exposure to asbestos could be hazardous to 4 human health. 5 INTERROGATORY NO. 50: 6 Has THIS DEFENDANT been cited for or otherwise charged by a public agency with a 7 violation in the GEOGRAPHIC AREA of any statute, ordinance, safety order, regulation, or law 8 pertaining to asbestos exposure? For each occasion, IDENTIFY: 9 A. The code section, safety order, statute, or regulation for which THIS 10 DEFENDANT had been cited or otherwise charged; 11 B. The date(s) thereof. 12 C. The agency or other governmental unit which issued the citation or otherwise 13 charged YOU. 14 D. All persons known to YOU with information relevant to the incident. 15 E. What was the ultimate resolution. 16 INTERROGATORY NO. 51: 17 If THIS DEFENDANT has ever owned or operated a railroad, state: 18 A. The IDENTITY of each such railroad, including the name(s) of such railroad 19 during the time-period of YOUR ownership and/or operation, the principal place of business of such 20 railroad and the dates of YOUR ownership and/or operation; 21 B. The geographic area of operation of such railroad; C. The name(s) of such railroad prior to YOUR ownership and/or operation; D. The IDENTITY of the person or entity from whom YOU purchased your ownership or operating interest, and the date of such purchase; E. The IDENTITY of the person or entity to whom YOU sold your ownership or operating interest, and the date of such sale; F. Whether copies of DOCUMENTS evidencing your ownership/operation and/or sale exist; EXHIBIT I GENERAL ORDER NO 119 - 25 - 1 G. The IDENTITY of the Custodian of such DOCUMENTS; 2 H. To the extent that information has not been given in answers to Interrogatory 3 Nos. 32 and 33, the information requested in Interrogatory Nos. 32 and 33, for each railroad owned 4 or operated by YOU. 5 INTERROGATORY NO. 52: 6 If DEFENDANT has ever owned or operated a shipyard, state: 7 A. The IDENTITY of each such shipyard, including the name(s) of such shipyard 8 during the time period of YOUR ownership and/or operation, the place of business of such shipyard 9 and the dates of YOUR ownership and/or operation; 10 B. The name(s) of such shipyard prior to YOUR ownership and/or operation; 11 C. The IDENTITY of the person or entity to whom YOU sold your ownership or 12 operating interest, and the date of such sale; 13 D. Whether copies of DOCUMENTS evidencing your ownership/operation 14 and/or sale exist; 15 E. Whether any representative of THIS DEFENDANT attended the Maritime 16 Commission Conference in December 1942 in Chicago, Illinois? If so, IDENTIFY any such 17 representative of THIS DEFENDANT; 18 F. The IDENTITY of the Custodian of such DOCUMENTS; 19 G. To the extent that information has not been given in answers to Interrogatory 20 No. 32, the information requested in Interrogatory No. 32, for each shipyard owned or operated by 21 YOU. 22 INTERROGATORY NO. S3: 23 At any time between 1930 and 1985, did you import, export, ship, transship or otherwise 24 transport RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS into, out of or through 25 any port in the GEOGRAPHIC AREA? If so, for each occasion: 26 A. IDENTIFY and describe the NATURE and amount of RAW ASBESTOS 27 and/or ASBESTOS-CONTAINING PRODUCTS; 28 B. IDENTIFY the ship or ships (including the owners and operators thereof) onto EXHIBIT I GENERAL ORDEX NO 129 -26- 1 or from which the RAW ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS were loaded. 2 unloaded or transshipped; 3 C. State the dates, port and pier involved for each occasion; 4 D. Either (1) attach all DOCUMENTS evidencing the information sought in this 5 Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing 6 such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made 7 the subject of a request for production of documents. 8 DATED: 9 10 STUART R. POLLAK 11 Judge of the Superior Court 12 13 14 ALFRED G. CHIANTELLI Judge of the Superior Court 15 16 17 18 19 20 21 22 23 EXHIBIT I to GENEAA1 ORDER NO 129 -27- 1 THOMAS E. PFALZER - State Bar No. 85261 GEOFFREY J. MACMILLAN, JR. - State Bar No. 189658 2 MCNAMARA, HOUSTON, DODGE, McCLURE & NEY 1211 Newell Avenue, Second Floor 3 Post Office Box 5288 Walnut Creek, California 94596 4 Telephone: (925) 939-5330 Facsimile: (925) 939-0203 5 Attorneys for Defendant 6 RILEY STOKER CORPORATION 7 8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO 9 10 IN RE: 11 COMPLEX ASBESTOS LITIGATION 12 13 14 15 16 ) NO. 828684 ) ) DEFENDANT RILEY STOKER ) CORPORATION'S ANNUAL (1999) ) VERIFICATION TO STANDARD ) GENERAL ORDER 129 ) INTERROGATORIES AND PROOF OF ) SERVICE ) ) ) 17 18 19 20 21 22 23 24 25 26 27 28 r'~r~ ' 1000 v.rwwun 00129 1______________________________________________________ (In Re: Complex Asbestos) VERIFICATION COMMONWEALTH OF MASSACHUSETTS) ) COUNTY OF WORCESTER ) ss JAMES S. BRANTL, being duly sworn, deposes and says that he is an authorized agent of DB Riley, Inc., and that he verifies the foregoing Defendant, DB Riley, Inc.'s Responses to Plaintiffs' Standard General Order 129 Interrogatories for and on behalf of DB Riley, Inc.; that certain of the matters stated therein are not within the personal knowledge of deponent; that the facts stated therein have been assembled by authorized employees and counsel of DB Riley, Inc., and deponent is informed that the facts stated therein are true. s S. Brand A SWORN TO BEFORE ME and subscribed in my presence this day of , 1999. 1 PROOF OF SERVICE BY MAIL (C.C.P. 1013a, 2015.5) 2 I hereby declare that I am a citizen of the United States, am 3 over the age of eighteen years, and not a party to the within 4 action; my business address is 1211 Newell Avenue, Second Floor, 5 Walnut Creek, California 94596. 6 On this date I served the foregoing DEFENDANT RILEY STOKER 7 CORPORATION'S ANNUAL (1999) VERIFICATION TO STANDARD GENERAL ORDER 8 129 INTERROGATORIES on the parties in said action, by placing a 9 true copy thereof enclosed in a sealed envelope with postage 10 thereon fully prepaid, in the United States Post Office mail box at 11 Walnut Creek, California, addressed as follows: 12 San Francisco County Superior Court Attn: Court Clerk 13 400 McAllister Street San Francisco, CA 94107 14 Clarence Mamaril, Esq. 15 BRAYTON, PURCELL, CURTIS & GEAGAN 222 Rush Landing Road 16 P.0. Box 2109 Novato, CA 94948 17 Alan R. Brayton. Esq. 18 BRAYTON, PURCELL, CURTIS & GEAGAN 222 Rush Landing Road 19 P.O. Box 2109 Novato, CA 94948 20 Christopher E. Grell, Esq. 21 LAW OFFICES OF CHRISTOPHER E. GRELL 685 Market Street, Suite 540 22 San Francisco,- CA 94105 23 Jack K. Clapper, Esq. LAW OFFICES OF JACK K. CLAPPER 24 Marine Office Plaza 2330 Marinship Way, Suite 140 25 Sausalito, CA 94965 26 Steven Kazan, Esq. KAZAN, MCCLAIN, EDISES, SIMON & ABRAMS 27 171 Twelfth Street, Suite 300 Oakland, CA 94607 28 3_____________________________ _______________ fin R/' rvtmnlex Asbestos) 1 Harry F. Wartnick, Esq. WARTNICK, CHABER, HAROWITZ, SMITH & TIGERMAN, INC. 2 101 California Street, Suite 2200 San Francisco, CA 94111 3 Dean A. Hanley, Esq. 4 LAW OFFICES OF DEAN A. HANLEY 5430 Cerro Sur Street 5 El Sobrante, CA 94803-3873 6 I declare under penalty of perjury that the foregoing is 7 true and correct. 8 , at Walnut Creek, 9 California. 10 HEATHER BRANS CUM^ 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LAW f Rilev Stoker Corp.'s 1999 Verification to G0129 4 (In Re: Complex Asbestos)