Document NEjpa0OnnX9kpnDMY7gZRE8Jp
HENDERSON, HANEMANN & MORRIS
A Or(llONAk LAW COAAOAATIOH
MIU* p. HCNOCnON CHARLf* HANKMANN J. MAMA OffAHAM JOIC^H A, ftClLLY, J*. aa*y j, aouoncAux KKVIN J. W(B KMIUC MCLANCON OAVC
Mr. William B. Baggett, Jr.
900 LArAVtTTB ri**r HOUMA, LOUISIANA 70300
March 12, 1999
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BAGGETT, MCCALL & BURGESS
3006 Country Club Road
Post Office Drawer 7820 Lake Charles, LA 70606-7820
RECEIVED MAR 1 B1999
># Re: Daniel J. and Elizabeth Elaine Ross v. Conoco, Inc., et al.
Our File No, 0177.2738708
Dear Mr. Baggett:
I am delivering herewith Minnesota Mining and Manufacturing Company's objections, comments, and response to the plaintiffs supplemental request for production of documents, together with copies ofthe documents.
By copy of this letter, I am notifying all defense attorneys that they may obtain copies of the documents by requesting them from me.
Sincerely,
KJW/sb Enclosures
F:\2738TCORRESVBAggettl7.doc
cc: All Counsel of Record
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ELIZABETH ELAINE ROSS, ET AL.
VERSUS NO. 90-4837
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CONOCO, INC., ET AL.
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14TH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU STATE OF LOUISIANA
MINNESOTA MINING AND MANUFACTURING COMPANY'S OBJECTIONS, COMMENTS, AND RESPONSES TO PLAINTIFFS'
SUPPLEMENTAL REQUEST FOR PRODUCTION OF DOCUMENTS
Minnesota Mining and Manufacturing Company (3M) makes the following objections,
comments, and responses to plaintiffs' supplemental request for production of documents:
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3M makes the following general objections, which apply to all seven of the plaintiffs'
supplemental requests for production:
1
Insofar as the plaintiffs' requests call for the production of documents that relate to any
substance other than vinyl chloride, 3M objects because documents concerning any substance
other than vinyl chloride are neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence.
3M objeci ts to the requests for production on grounds that they geek to extend the time period for discovery beyond the period set forth by the court in its order ofMarch 12, 1996. All
of 3M's responses to the plaintiffs' requests for production are limited to the period 1973
through 1995 to conform with that order.
t 3M makes the following general comments, which apply to all sixteen of the plaintiffs'
supplemental requests for production:
, I 3M makes this response to the plaintiffs' requests for production after a diligent search
of its records This search is continuing. 3M reserves the right to supplement its response
should it discover additional documents which may be responsive to the plaintiffs' request for
production.
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i 2. Certain of the documents produced herewith may be responsive to more than one of
the plaintiffs' numbered requests.
3 3M has assigned production numbers to the documents which are being produced herewith The production numbers assigned by 3M and the individual numbered request or requests to which 3M believes them to be responsive are:
3M_Ppturotni gtn
3M 110285 - 3M 110291 3M 110293-3M 110317 3M 110320 -3M 110341 3M 110366-3M 110375 3M 110387-3M 110390 3M 110398 - 3M 110435
3M 010111-3M 010112 3M 010523 -3M 010526 3M 105130-3M 105132 3M 105169-3M 105175 3M 105183 -3M 105185 3M 105723-3M 105727 3M 107458 - 3M 107459 3M 107462 3M 107467 - 3M 107469 3M 109721 -3M 109732 3M 110436-3M 110457 3M 110469 -3M 110488 3M 110497 - 3M 110524 3M 110542-3M 110643 3M 110648-3M 110667 3M 110669 - 3M 110674 3M 1106^7-3M 110713 3M II0725-3M 110737 3M 110754-3M 110778 3M 110809 - 3M 110929 3M 111007 ~3M 111107
3M 110398 -3M 110435 3M 110930-3M 110966
No Responsive Documents
&qpqtum w 1&2 3
4&5 6& 7
RESPONSES AND SPECIFIC OBJECTIONS
3M makes the following responses and/or specific objections to the plaintiffs' supplemental requests for production:
REQUEST FOR PRODUCTION NO. 1;
Please produce any notes, memorandum, correspondence, record, mifiutes of meetings,
calendar entries, and any other documents with regards to the ISEA (Industrial Safety Equipment
Association) and passive dosimeters for any employee and/or officers of 3M, including but not
limited to. Bob Weber and James Kvickstad.
RESPONSE TO REQUEST FOR PRODUCTION NO. I:
See comment No. 3 above
REQUEST FOR PRODUCTION NO. 2:
Please produce any correspondence, telephone message slips, telephone conversation summaries, or any other documents with regards to the 1SEA (Industrial Safety Equipment
Association) and passive dosimeters for any employee and/or officers of 3M, including but not limited to. Bob Weber and James Kvickstad.
RESPONSE TO REQUEST FOR PRODUCTION NO, 2: See comment No. 3 above
REQUEST FOR PRODUCTION NO, 3:
Please produce any written or electronic record, including e-mail, which in any way
concerns passive dosimeters and vinyl chloride and/or halogenated hydrocarbons and/or
chlorinated hydrocarbons.
*
RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
For written or electronic records that pertain to passive dosimeters and vinyl chloride,
please see the documents produced by 3M in its response to the plaintiffs' original request for production.
Insofar as the request seeks written or electronic records that pertain to passive dosimeters and any other halogenated or chlorinated hydrocarbons, 3M objects to the request on
grounds that it is too broad, vague and general to be susceptible of a categorical response, calls
for information which is not admissible or reasonably calculated to lead to the discovery of the
admissible evidence, and cannot be answered without imposing undue hardship and expense L
upon Minnesota Mining and Manufacturing Company. Without waiving those objections, 3M
responds to the request as follows:
See comment to No. 3 above. REQUEST FOR PRODUCTION NO. 4:
Please produce any notes, memorandum, correspondence, record, minutes of meetings,
calendar entries, and any other documents with regards to the SEI (Safety Equipment Institute)
and passive dosimeters.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
See comment No. 3 above
REQUEST FOR PRODUCTION NO. S:
Please produce any correspondence, telephone message slips, telephone conversation
summaries, or any other documents with regards to the SEI (Safety Equipment Institute) and
passive dosimeters.
RESPONSE TO REQUEST FOR PRODUCTION NO. S:
See comment No. 3 above
REQUEST FOR PRODUCTION NO, 6:
Please produce any notes, memorandum, correspondence, record, minutes of meetings,
calendar entries, and any other documents with regards to the ASTM Committee D22 on
Sampling and Analysis of Atmospheres (including but not limited to Subcommittee designation
D22.04 on Methods of Sampling and Analysis ofWork Place Atmospheres).
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: None.
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REQUEST FOR PRODUCTION NO. 7:
Please produce any correspondence, telephone message slips, telephone conversation
summaries, or any other documents with regards to the ASTM Committee D22 on Sampling and
Analysis of Atmospheres (including but not limited to Subcommittee designation 022.04 on
i
Methods of Sampling and Analysis of Work Place Atmospheres).
RESPONSE TO REQUEST FOR PRODUCTION NO. 7; None.
....
Kevin | Webb(^l 7857) Henderson, Hanemann & Morris A Professional Law Corporation 300 Lafayette Street Houma, LA 70360 Tel: (504) 868-2081 Attorneys for Minnesota Mining and Manufacturing Company
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CERTIFICATE
I HEREBY CERTIFY that a copy of the above and foregoing has this day been forwarded to all known counsel of record by placing same in the United States mail, postage prepaid and properly addressed.
Houma, Louisiana, this I 3^-- day of jlQ Qa rAy . 1999.
F:OT*N>IJXWUq. for Produce
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