Document NEZ4G9yX6mqqQXDMb4G3KabQD

FILE NAME: Asbestos Z>> DATE: DOC#: AC> OCUMENT DESCRIPTION>ZZZ>ZZZZ  " IOM1NSKY, JOSEPH & WELSH, P. C. BY: EDWARD B. JOSEPH/FREDRIC IDENTIFICATION No.02938/27799 16TH FLOOR, TWO PENN CENTER PLAZA PHILADELPHIA. PA. 19102 (215) L. GOLDFEIN ATTORNEV FOR Defendant ASBESTOS CORPORATION LIMITED CLARENCE JOHNSON, et ale v. TURNER & NEWALL, et ::al. IN THE UNITED STATES"DISTRIC I COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA No. 78-464 RESPONSE OF ASBESTOS CORPORATION LIMITED TO REQUESTS FOR ADMISSIONS 1. This request does not list the dates of alleged em- ployment of the persons listed with Asbestos Corporation Limited nor are the middle initials, or other identifying criteria given. Asbestos Corporation Limited has searched what files exi.st respecting present and former employees and admits that it had former employees named: Theodore Courture Leo Goupil Joseph Marceau Thomas Provencal Ernest Rouleau William Bizier AUG 5 1900 . ,. ., ' Albert Champagne Wilfred Fortier William Cooling Joseph Tremblay Louis Lessard Joseph Adams Ludger Ainsley Eddy Lemieux Alexandre Nadeau Asbestos Corporation Limited has no record of employment of: Albert Simard Joseph Turcotte Arthur Ainsley 2. Asbestos Corporation Limited can neither ~dmit nor deny Request No.2. Asbestos Corporation Limited's records respecting events of 30 years ago are not complete. Asbestos Corporation Limited has no record of it having sent any medical files, x-rays, or x-ray reports, pathology reports or autopsy report to the Saranac Laboratory, the Trudeau Foundation, Saranac Lake, New York. Plaintiffs' request states "was sent" and it is assumed that plaintiffs. mean that the material described was sent by Asbestos Corporation Limited. 3. Asbestos Corporation Limited can neither ac~it nor deny Request No.3. The alleged letter of September 22, 1950, addressed to Mr. Alfred Penhale is 30 years old. Asbestos Corporation Limited does not retain all correspondence and proposa1s for such a period. Those files that do exist do not contain the letter identified in (a) nor the proposals identified in (b). OMINSKY, JOSEPH & WELSH EDWARD B. JOSEPH {J FREDRIC L. GOLDFEIN . . COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF PHILADELPHIA FREDRIC L. GOLDFEIN, being duly sworn according to law, deposes and says that he is attorney for Defendant Asbestos Corporation Limited; that he is authorized to and does take this affidavit on its behalf; and that he is acquainted with the facts set forth herein; and that the, same are true and correct to the best of his knowledge, information and belief. FREDRIC L. GOLD,F,-,,,E,,, TN SWORN TO AND SUBSCRIBED rw'v:' before me this\ day of ~~ ,1980. ,J <{ ' ( ::. ' \ { OJ