Document NGD2z5joVq3zgMxzGDJpYEmVb

IN RE: ALL ASBESTOS-RELATED INJURY OR DEATH CASES FILED BY BARON & BUDD, P.C. OR TO BE FILED BY BARON & BUDD, P.C IN DALLAS COUNTY, TEXAS s s s s s IN THE DISTRICT COURTS OF DALLAS COUNTY, TEXAS 160TH JUDICIAL DISTRICT DEFENDANT U. S. GYPSUM COMPANY'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES AND REQUESTS FOR PRODUCTION TO: Plaintiffs, by and through their attorney of record, Mr. Russell W. Budd, Baron & Budd, P.C., The Centrum, 3102 Oak Lawn Ave., Ste. 1100, Dallas, TX 75219 COMES NOW, U. S. GYPSUM COMPANY, Defendant in the above- entitled and numbered cause, and files the attached objections and responses to Plaintiffs' Interrogatories. Respectfully submitted DeHAY & ELLISTON, L.L.P. 1500 Maxus Energy Tower 717 North Harwood Street Dallas, Texas 75201-6508 Telephone: (214) 953-5454 i `` DAVID W. CROWE State Bar No. 05164250 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing document has been forwarded to Plaintiffs' counsel of record, Mr. Russell W. Budd, Baron & Budd, by hand delivery on the ___ day of 1993 DEFENDANT U. S. GYPSUM COMPANY'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES f:\asb3\usg2.rog Page 1 PREFATORYSTATEMENT United States Gypsum Company (hereinafter "U.S. Gypsum") has, to the best of its abilities, gathered non-privileged documents into a document repository for inspection by plaintiffs' counsel in response to requests for production served in asbestos litigation. These documents provide information that supplements and expands upon that provided in these answers to Interrogatories and Requests for Production. Accordingly, by way of further response to these Interrogatories and Requests for Production, U.S. Gypsum hereby offers to make available these documents at a mutually convenient time at its offices at 125 S. Franklin Street, Chicago, Illinois. In giving its responses to Interrogatories and Requests for Production as to asbestos-containing products, U.S. Gypsum refers to products containing commercial asbestos as part of their formulation and to the type of commercial asbestos used as part of the formulation. OBJECTIONS U.S. Gypsum objects to the manner in which plaintiff purports to include in its definition of U.S. Gypsum "any of its merged, consolidated, or acquired predecessors, division, subsidiaries, foreign subsidiaries, foreign subsidiaries of predecessors, and/or affiliates known to have mined manufactured, sold, marketed, utilized or distributed asbestos or asbestos-containing products into ships or other water-going vessels. This definition includes present and former officers, directors, agents, employees, and all other persons acting or purporting to act on behalf of U.S. Gypsum Company or its predecessors, subsidiaries, and/or affiliates known to have mined, manufactured, sold, marketed or distributed asbestos or asbestos-containing products. Predecessors' further means any business firm, whether or not incorporated, which had all or some of its assets purchased by you or came to be acquired by you whether by merger, consolidation, or otherwise known to have mined, manufactured, sold, marketed, utilized, or distributed asbestos or asbestos-containing products. 'Subsidiaries' further means any business firm whether or not incorporated, which is or was in any way owned or controlled, in whole or in part by defendant or its predecessors and which is known to have mined, manufactured, sold, marketed, utilized or distributed asbestos or asbestos-containing products." In that U.S. Gypsum Company is the named defendant, this definition is overly broad and would require U.S. Gypsum to engage in unduly burdensome research, divulge privileged informa tion and produce privilege documents. This defendant. United States Gypsum Company, responds to these Interrogatories and Requests for Production on behalf of itself. DEFENDANT U. S. GYPSUM COMPANY'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES f:\asb3\usg2.rog Page 2 U.S. Gypsum further objects to these Interrogatories and Requests for Production to the extent they ask for "identification" of voluminous documents on the ground that they are overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. As set forth infra. U.S. Gypsum will produce documents which are the proper subjects of an appropriate document request. Finally, to this defendant's best current knowledge, informa tion and belief, this defendant believes that its products were never used in the shipbuilding trade. This defendant never manufactured any asbestos insulation material suited for shipbuild ing. Most of this defendant's asbestos-containing products were gypsum-based and therefore were not suitable for use around water, moisture, ships, etc. ANSWERS TO INTERROGATORIES INTERROGATORY NO. li Identify by name and location each plant ever owned, operated, or at a later time bought or at a later time bought or under control of U.S. Gypsum Company, in which asbestos-containing products were manufactured, assembled, or prepared for sale or marketing, specifying which plants produced each item, the dated each plant is or was in operation, and the time span during which each asbestos-containing product was manufactured, assembled, or prepared for sale or marketing. Answer: See attached Schedule D. INTERROGATORY NO. 2: Does U.S. Gypsum Company have in its possession or custody any x-rays, taken before 1970, of individuals who worked in any plant in which asbestos-containing products were manufactured, assembled, or prepared for sale or marketing? If so, state: a. The name of each plant; b. The location of each plant; c. The time periods in which asbestos-containing products were manufactured, assembled, or prepared for sale at each plant; d. The date each plan closed; e. Where such x-rays are kept; and f. The occupations of the individuals who had x-rays taken. DEFENDANT U. S. GYPSUM COMPANY'S OBJECTIONS AND RESPONSES TO PLAINTIFFS * INTERROGATORIES f:\asb3\usg2.rog Page 3 Answer! Objection. This Interrogatory is overbroad, irrelevant, immaterial, and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 3: Has U.S. Gypsum Company turned over any papers, documents, writings concerning asbestos, the health effects of asbestos, or asbestos-related disease to any law firm? If so, state: a. A description of each paper, document, or writing; and b. The name and address of the law firm. Answer: Objection. This Interrogatory is overbroad, irrelevant, immaterial, and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 4: . Has U. S. Gypsum Company, or attorneys representing U. S. Gypsum Company, destroyed any documents which refer or relate to asbestos, the health effects of asbestos, asbestos-containing products, or dust studies that measured asbestos dust? If so, state: a. A description of each document; b. The author of each document; c. A summary of the subject matter of each document; and d. The reason for the destruction of each document. Answer: This defendant has a record retention policy in place which will be made available. To this defendant's best knowledge, information and belief, no documents referring or relating to asbestos, etc. have been destroyed since this defendant became involved in the asbestos litigation. DEFENDANT U. S. GYPSUM COMPANY'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES f:\asb3\usg2.rog Page 4 RESPONSES TO REQUEST FOR PRODUCTION REQUEST FOR PRODUCTION NO. 1.; Produce copies of all writings or documents relating to asbestos, the health effects of asbestos, or asbestos-containing products that U.S. Gypsum Company has provided to, and which are currently kept by, any law firm, other than writings or documents that are subject to the work product privilege. RESPONSE; objection. This Request is overbroad, irrelevant, immaterial, and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, non-privileged, responsive documents, to the extent they exist, will be made available to plaintiff at a mutually convenient time through U.S. Gypsum Company's offices at 125 South Franklin Street, Chicago, IL. REQUEST FOR PRODUCTION NO. 2.: ' Produce all reports, documents or writings of dust studies performed in U.S. Gypsum Company plants or facilities in which concentrations of asbestos dust were measured. . RESPONSE: Non-privileged, responsive documents, to the extent they exist, will be made available to plaintiff at a mutually convenient time through U.S. Gypsum Company's offices at 125 South Franklin Street, Chicago, IL. REQUEST FOR PRODUCTION NO. 3.: Produce copies of all writings, documentation that show or refer to the fact that Howard Bowman testified at any OSHA hearing concerning asbestos or asbestos-containing products. RESPONSE: To this defendant's best current knowledge, information, and belief, none. DEFENDANT U. S. GYPSUM COMPANY'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES f:\asb3\usg2.rog Page 5 REQUEST FOR PRODUCTION NO. 4,: Produce all studies performed for U.S. Gypsum Company by Metropolitan Life Insurance Company, The Travelers Companies, Commercial Union Insurance Companies, Liberty Mutual Insurance Group, and/or any subsidiaries, divisions, affiliates, or predeces sors-in-interest of such companies relating to the health effects of exposure to asbestos dust. RESPONSE: Non-privileged, responsive documents, to the extent they exist, will be made available to plaintiff at a mutually convenient time through U.S. Gypsum Company's offices at 125 South Franklin Street, Chicago, IL. DEFENDANT U. S. GYPSUM COMPANY'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES :\asb3\usg2.rog Page 6 STATE OF ILLINOIS ) ) COUNTY OF COOK SS VERIFICATION I, F. M. Poremski, declare: I am the Director, Financial & Accounting Services of United States Gypsum Company, one of the above named defendants, and am authorized to make this verification for and on behalf of said company; I have read the foregoing Answers, Objections, and other Responses to Plaintiff's Interrogatories and am informed and believe that the same is true and on that ground allege that the matters therein stated are true. I declare, under penalty of perjury, that the foregoing is true and correct, and that this declaration was executed on in Chicago, Illinois. jL F. M. Poremski Subscribed and swwoorr:n to before me this 7j^L- day oof^f4^^ 1993. /Notary Public 'February 16, 1993 Schedule D ASBESTOS-CONTAINING PRODUCTS MANUFACTURED BY U.S. GYPSUM The dates listed 'here are taken Cron product operating bulletins which governed the manufacturing process. The cancellation of these operating bulletins usually coincided with cessation of production, but occasionally bulletins would remain uncancelled after the manufacture of a product had been discontinued. Consequently, the years shown for cancellation of authorization are believed to be the last possible year of manufacture, although manufacture may have in fact ended earlier. Production dates established through documentation other than product operating bulletins have been footnoted. Temporary and trial production runs are inoludad (along with regular production). These have been footnoted for Firecoda and can be determined for other products from a review of operating bulletins. With texture products, such runs were occasionally given slight name variations. fraflust Hbb* 6ABIHITE1 Product Type Acoustical Plaster First Authorized For Production With, ftgbspfcog.. 1930 1930 1930 1930 1939 1930 1931 1931 Cancellation of Authorisation 1945 1964* 1945 1946 1945 1964* 1964 194B Manufacturing J^ocatisiiS. East Chicago, IN Fort Dodge, Ia Gypsum, OH Midland, CA Nephi, UT New Brighton, NY Hagersville, CAN* Hillsborough, CAN RED TOP ACOUSTICAL PLASTER HI-LITE AUDICOTE5 Acoustical Plaster Acoustical Plaster Acoustical Plaster 1951 1951 1953 1953 1955 1955 1954 1954 1955 1961 1953 1953 1954 1954 1972 1972 1972 1972 1956 1975 . Fort Dodge, IA New Brighton, NY Fort Dodge, IA* Naw Brighton, NY* Fort Dodge, IA New Brighton, NY Fort Dodge, IA New Brighton, NY Midland, CA* Hagersville, CAN* page l of 16 February 16, 1993 Prpdvst Haas RED TOP GYPSUM PLASTER (marketed as CEMEHT PLASTER Until 1967)1 Product-Tvse Building Plaster RED TOP GYPSUM PLASTER FOR HACHINB APPLICATION (marketed as CEMENT PLASTER FOR MACHINE application until 1967)' Building Plaster RED TOP TROWEL FINISH Building Plaster WAINSCOAT TROWEL FINISH ORIENTAL INTERIOR FINISH Building Plaster Building Plaster Piret Authorized For Production VAth Mbs&QM. 1943 1950 1944 1955 only . 1961 1961 1962 1959 only 1957 1957 Cancellation of Authorisation 1947 1971 1974 1966 1966 1966 1972 1972 Manufacturing Lpgfltiana_____ Loveland,. CO Hagaraviile, CAN1 Hillsborough, CAN Montreal, CAN* Detroit, MI Gypsum, OH Oakfield, NY Southard, OK* . Hagersville, CAN* Montreal, CAN1 1930 1930 1950 1930 1930. 1946 1946 only 1942 1942 1942 1949 1942 1942 1949 1942 1935 1935 1951 1935 1935 1953 . 1944 1972 1944 1950 1946 1971; 1972 1950 1972 East Chicago, in Port Dodge, IA Port Dodge, IA Gypsum, OH New Brighton, NY Port Dodge, IA Southard, OK Boston, MA Fort Dodge, IA Gypsum, OH Jacksonville, PL Milwaukee, WI New Brighton, NY Norfolk, VA Oakfield, NY page 2 of February 16, 1993 Product Mfllilfl Product tyec ORIENTAL EXTERIOR FINISH STUCCO* Building Plaster RED TOP PATCHING PLASTER Building Plaster RED TOP COVER COAT FINISH PLASTER Building Plaster First Authorised For Production Hlth ..AgfrgctPff 1942 1949 1942 Cancellation of Authorization 1944 1973 1973 1932 1930 1930 1949 1932 1930 1949 1930 1932 1949 1930 1964 1944 1973 1944 1972 1946 1972 1973 1972 1944 1972 1972 1974 1929 1942 1929 1929 1944 1947 1951 1946 1947 1947 1948 1948 1956 only 1964 1954 Manufacturing Locations Philadelphia, PA Philadelphia, PA Sweetwater, TX Boston, MA Fort Dodge, IA Gypsum, OH Jacksonville, FL Milwaukee, WI New Brighton, NY Norfolk, VA Oakfield, NY Philadelphia, PA Philadelphia, PA Sweetwater, TX Montreal, CAN* Gypsum, OH Milwaukee, HI Nephi, UT New Brighton, NY South Gate,.CA New Brighton, NY Southard, OK Southard, OK page 3 of February 16, 1993 ' 'k\% Product Hate red top wood FIBER PLASTER REGULAR BASEOOAT PrQtjUCt TYPfl Building Plaster RED TOP WOOD FIBER PLASTER MACHINE APPLECATION-BASECOAT Building Plaster First Authorized For Production 1931 1945 1930 1952 1931 1948 1931 1945 1940 1945 1945 1945 1931 1945 1948 1931 1936 . Cancellation of ftyrthcrizatign 1941 1963 1972 1960 1963 1952 7 1972 > 1966 1959 1952 1940 1960 1972 1967 1965 1961 1963 1960 1972 1966 1961 . Manufacturing Locations --... Detroit,-MI Detroit, MI East Chicago, IN Empire, NV Fort Dodge, IA Gerlach, NV Gypsum, OH Heath, MT Laramie, WY Loveland, CO Midland, CA Nephi, UT Oakfield, NY Plaster City, CA Sigurd, UT Southard, OK Sweetwater, TX East Chicago, IN Fort Dodge, IA Plaster City, CA page 4 of February 16, 1993 *a Product flan* Product Tver RED TOP STRUCTOLITE PLASTER FOR MACHINE APP LICATION-BAS ECOAT* Building Plaster RED TOP BONDCRETK PLASTER*-BASECOAT* REO TOP SANDED WALL PLASTER1 PYROBAR MORTAR MIX1 ACOUSTONE 120 Building Plaster Building Plaster Tile Cement Ceiling Tile First Authorized For Production with Aabsatoa. 1955 1955 1971 1954 1954 1955 1964 1955 1955 1955 1955 1955 1955 1955 1955 1958 1955 1957 1954. 1954 . 1940 1964 1961 1937 1931 1967 1965 I960 1968 page 5 of Cancellation of ftuthoric&Ugfl 1962 1962 1972 1963 1960 1963 1973 1962 1962 1962 1959 1963 1962 1962 1962 1963 1962 1962 1962 1963 1943 1975 1970 1940 1937 1970 1972 1976 1976 Manufacturing Locations .... Boston, MA Detroit, MI Detroit, MI East Chicago, IN Empire, NV Fort Dodge, IA Fort Dodge, IA Gypsum, OK Jacksonville, FL Loveland, CO Milwaukee, WI Hew Brighton, NY Norfolk, VA Oakfield, NY Philadelphia, PA Plaster City, CA Plasterco, VA Shoals, IN Southard, OK Sweetwater, TX Midland, CA Hagersville, CAN1 Montreal, CAN1 Black Rock, NY Detroit, MI Eaat Chicago, IN New Brighton, NY Gypsum, OH Walworth, WI February 16, 1993 1 ErpflMst. Hama ACOUSTONE 180 BED TOP FIRECODE PLASTER Pcodust ,,Ty.b& Calling Tile Fireproofing Plaster RED TOP FIRECODE "V PLASTER Fireproofing Plaster First Authorized For Production Wifch-ABfrftSfcQg- 1966 1966 . 1962 1962 1959" 1960 1959" 1961 1959" 1962 1962 1961 1962 1964 only 1965 1962 1962 1962 1962 1964 1962 1962 1963 1962 1962 1962 1967 1962 1963 1963 . Cancellation of Authorization 1975 1975 1963 1963 1964 1964 1964 1964 1964 1963 1963 1963 1963 1969 1963 1963 1969u 1969u 1965 1963 1968 1967 1969" 1963 1963 1968 1963 1969 1969" ' page'6 of Manufacturing Locations_ _ Gypsum, OH Walworth, WI Boston, MA* Detroit, MI* East Chicago, 1H Empire, NV Fort Dodge, 1A Gypsum, OH Hew Brighton, NY Oakfield, NY* Philadelphia, PA* Sperry, IA stony Point, NY* Hagersvillo, CAM* Baltimore, HD Boston, MA* Detroit, MI* East Chicago, IN Empire, NV Fort Dodge, IA Galena Park, TX* Gypsum, OH Midland, CA New Brighton, NY Oakfield, NY* Philadelphia, PA* Plaster City, CA Stony Point, NY* Sweetwater, TX Hagersville, CAN* February 16, 1993 Frotiwt name SPRAYDON STANDARD Au SPRAYDOH STANDARD C11 SPRAYDON POWERCOTB*1 Product Typo Fireproofing Fireproofing Thermal Insulation X-FAC INDUSTRIAL INSULATING BLOCK Rigid Block Insulation K-FAC 19" FIRS DOOR CORBBOARD11 Rigid Block Insulation Fire Board COLUMN FIRE BOARD1* Fire Board SHEETROCK RADIANT HEAT FILLER - MACHINE APPLICATION Plaster First Authorized For Production with Asbestos 1965 1965 1970 Cancellation of Authorization 1971 1971 1971 1966 1966 1970 only 1970 1970 1969 1969 1969 1970 1971 1971 1971 1971 1943 1950 Manufacturing teSAUgna-. . Plainfield, NJ Torrance, ca Weston, CAN1 Plainfield, NJ Torrance, CA Weston, CAN1 Plainfield, NJ Torrance, ca Corsicana, TX11 Weston, CAN1 EaBt Chicago, ] 1970 1971 1966 1971 1966only 1968 1969 1968 1969 1971 1971 1971 1971 page 7 of 16 Greenville, MS Greenville, MS Greenville, MS Baltimore, MD Boston, MA Detroit, MI East Chicago, in February.16, 1993 > naiEfl Product Tvpq PAC-TEX TEXTURE PAINT A-B TEX TEXTURE PAINT Texture Texture TEXTURE PAINT Texture First Authorized For Production with Asbestos 1970 1968 1969 1969 1968 1969 1968 1969 1969 . 1962 1943 1949 1959 1935 1954 1973 only 1935 1954 1943 1954 1948 1954 1962 1966 1959 1964 1930 1937 1948 1948 page 6 of Cancellation of Authorization 1972 1971 1971 1971 1971 1971 1971 1970 1972 1963 1970 1962 1973 1949 1973 1949 1968 1944 1973 1950 1955 1977 1967 1973 1973 1973 1973 1970 1964 Manufacturing irtSflUons-..... Empire, MV Ft. Dodge, IA Gypsum, OH Mew Brighton, NV Norfolk, VA Philadelphia, PA Plaster City, CA Shoals, IN Sweetwater, TX Dallas, TX South Gate, CA Sweetwater, TX Chamblee, GA Gypsum, OH Gypsum, OH Midway, IL New Brighton, MX New Brighton, MV South Gate, CA South Gate, ca Sweetwater, TX Sweetwater, TX Hagersville, CAN: Montreal, CAN1 Chamblee, GA . Dallas, TX Gypsum, OH New Brighton, NY South Gate, CA Sweetwater, TX February 16, 1993 >t Product Name PEQdUfft TYM TEXOLITE DRY FILL Texture TEXOLITE DRYWALL SURPACBR, AGGREGATED renamed DRYWALL SURPACBR, TEXTURE XXI, in 1965 Texture SPRAY TEXTURE ' Texture PAINT (or FINISH) MULTI-PURPOSE TEXTURE FINISH Texture IMPROVED SPRAY TEXTURE B-8 SANDED, COLORED TEXTURE PAINT CONCRETE CEILING TEXTURE TEXTONE TEXTURE FINISH Texture Texture Texture Texture First Authorized For Production With Asbestos 1959 . 1963 1961 1970 1963 1963 1961 1961 1960 1970 1966 1956 1959 1964 1963 1965 1971 1965 1963 cancellation of Authorization 1961 1965 1977 1972 1965 1965 1976 1976 1976 1976 1968 1973 1961 . 1976 1976 1976 1976 1966 . 1973 Manufacturing LQCfttlQna New Brighton, NY Dallas, TX Gypsum, OH Midway, IL New Brighton, NY South Gate, CA Chamblee, GA Dallas, TX Gypsum, OH Midway, IL New Brighton, NY South Gate, CA Sweetwater, GA Chamblea, GA Dallas, TX Gypsum, OH Midway, IL Hew Brighton, NY South Gate, CA 1952 1952 1970 1953 1955 1973 New Brighton, NY Sweetwater, TX , South Gate, CA 1959 1962 1972 1972 Chamblee, GA Dallas, TX page19 of February 16, 1993 k1 Product.Hres ECOflUCt TYBft TEXOLITE BLOCK FILLER * 6HEETROCK SMOOTHCOAT Texture SHEETROCK RADIANT HEAT SIMULATED ACOUSTICAL TFXTURE SPECIAL TEXTURE PAINT simulated Acoustical Ceiling Texture Texture TEXTURE XII, SUPER VINYL AGGREGATED SPRAY FINISH, WHITE Texture Texture First Authorised For Production With Asbestos 1928 1937 1944 1949 1965 . 1961 1966 1958 19S8 1959 1959 1966 1965 1971 1970 Cancellation of Author!gation 1975 1972 1972 1972 1977 1966 ? ? ? 1966 1966 1974 1974 1974 1972 Manufacturing Locations Gypsum, OH New Brighton, NY South Gate, CA Sweetwater, TX Hagersville, CANJ Chamblee, GA Dallas, TX Gypsum, OH New Brighton, NY South Gate, CA Sweetwater, TX Dallas, TX Gypsum, OH Midway, 1L South Gate, CA 1962 1955 only 1954 1970 1970 1967 1964 1971 only 1972 1964 1976 1976 1968 1966 page 10 of 16 Dallas, TX New Brighton, NY Sweetwater, TX Gypsum, OH Midway, IL ' Dallas, TX Gypsum, OH Midway, IL February 16, 1993 X* * radoct-Hflao Product Type SMOOTH HARD FINISH Texture 5UPBRHARD SPRAY TEXTURE FINISH Texture EXTERIOR TEXTURE WALLBOARD FINISH Texture SIMULATED ACOUSTICAL SPRAY TEXTURB/FINISH ' Simulated Acoustical Ceiling Texture "QT" SIMULATED ACOUSTICAL SPRAY TEXTURE IMPERIAL QTM (SPRAY) TEXTURE FINISH-REGULAR IMPERIAL "QT" (SPRAY) TEXTURE FINISH-LC Simulated Acoustical Calling Texture simulated Acoustical Ceiling Texture Simulated Acoustical Ceiling Texture First Authorized For Production With .A8bSRtO- 1968 1968 Cancellation of Authorisation 1969 1969 Manufacturing Locations South Gate, CA South Gate, CA 1971 1971 1964 only 1963 1959 1961 1959 1961 1963 1973 1972 1964 1964 1964 1964 1962 1973 . ,, Dallas, TX South Gate, CA Chaoblee, GA Dallas, TX Gypsum, OH New Brighton, NY South Gate, CA Sweetwater, TX South Gate, CA 1964 1967 1964 1966 only 1968 1965 1965 1965 1965 1966 only 1965 1969 1968 1973 1968 1968 1966 1966 Dallas, TX Dallas, TX New Brighton, NY South Gate, CA South Gate, CA Dallas, TX Gypsum, OH ., New Brighton, NY Hagersville, CAN3 Montreal, CAW1 page 11 of 16 February 16, 1993 *4 Product Name IMPERIAL "QT* (SPRAY) TEXTURE FINISH - NC-LC fredact,typs Simulated Acoustioal Ceiling Texture IMPERIAL "QT" (SPRAY) TEXTURE FINISH-EXTRA HARD FINE Simulated Acoustical ' Ceiling Texture IMPERIAL HQT (SPRAY) TEXTURE FINISH-VERHICULITJS, COARSE and REGULAR Simulated Acoustical ceiling Texture IMPERIAL "QT" (SPRAY) TEXTURE FINISH-POLYSTYRENE, COARSE and REGULAR IMPERIAL MQT" (SPRAY) TEXTURE FINISH-MC4 Simulated Acoustical ceiling Texture Simulated Acoustical Celling Texture READY-MIXED IMPERIAL "QT SPRAY FINISH Simulated Acoustical Ceiling Texture First Authorised For Production Hith.Aafreatsa- 1968 1966 1966 1970 1966 1964 1964 1964 1964 1967 1966 1968 1970 1968 1967 Cancellation of ft^harlsatlgp 1976 1974 1976 1975 1975 1974 1971 1974 1973 1976 1976 1976 1976 1976 1976 Manufacturing IflgftUQna Chamblee, GA Dallas, TX Gypsum, OK Midway, XL Hew Brighton, NY Chamblee, GA Dallas, TX Gypsum, OH New Brighton, NY Chamblee, GA Dallas, TX Gypsum, OH Midway, 1L Hew Brighton, NY Dallas, TX 1968 1968 1967 1970 1967 1966 1972 1971 1972 1972 1972 1967 Chamblee, GA Dallas, TX Gypsum, OH Midway, IL Hew Brighton, NY . Hew Brighton NY page 12 of February 16, 1993 Product Nana THERMALUX RADIANT HEATING PANELS Type Radiant Heating Panels First Authorized For Production With.AgfrfigtGg . 1964 cancellation of Av>thori8fitlan 1969 Manufacturing Legations____ Shoals, IN (assembled) OthcrPrQdugtfl (by generic group) PIPECOVERINGS, ASBESTOS PAPER, ASBESTOS BOARD PASTE SPACKLING POTTY JOINT COMPOUNDS ADHESIVES 1936 19381* Jersey city, NJ 1952 1920's? 1975 1976 1953 1973 1968 1955 1971 page 13 of 1973 1974 1973 1965 1977 . Chamblea, GA Gypsum, OH New Brighton, NY Sweetwater, TX Calgary, CAN,,ao Chanblee, GA Dallas, TX East Chicago, IN Gypsum, OH Hagersville, CAN: Jacksonville, FL Midway, IL Montreal, CAN1*" New Brighton, NY south Gate, CA Sweetwater, TX . Gypsum, OH Midway, ILU Nashville, TN New Brighton, NY Roaeraont, IL11 February 16, 1993 ' t product Mama Product. Type SIDING SHINGLES ROOFING PRODUCTS INSULATING CEMENT First Authorized For Production With Asbeatos 1961 1957 1974 1937 Cancellation of Mithprlsafetan 1972 1962 1977 1975 1936 1967 1967 1934 1934 1954 1937 1967 1975 1978 1978 1975 1960 1977" 1960 1978 . Manufacturing Locations_____ South Gate, CA Sweetwater, TX Trenton, NJM East Chicago, IN Jersey city, NJ Mt. Dennis, CAN3 st. Hubert St., < St. Paul, KN South Bend, IN South Gate, CA Toronto, CAN3 Vancouver, CAN* 1936 1938 Jersey City, NJ page 14 of 1$ February 16, 1993 HOIK; Not all products were necessarily made at all plants at all times listed, even though they were authorized Cor production. At some period of time between 1926 and 1930, Sabinlte is believed to have been manufactured at U.S. Gypsum's plant at Arden, Nevada. However, no bulletins for that plant have been located, it having been closed in 1930. Sabinlte may have been produced until this date, but sales diminished substantially by the mid-1950's. Not sold in the United States. Two-component Hi-Lite plaster was authorized for production in June 1953 and discontinued in August 1954. Approximately 4 tons of a temporary variant was produced during 1953, and packaged as "Lime-Keene'e Acoustical Plaster." Marketed as Red Top Acoustical Plaster with the word 'Spray' stenciled on the bag from 1954 to 1935} marketed as Red Top Spray On Acoustical Plaster in 1955; marketed as Red Top Audicote Acoustical Plaster from 1955 to 1968. A trial job of 3 tons only. Contained less than 1.0% asbestos (not asbestos-containing products under applicable law). Two month production run only. Temporary production of Firecode only. Trial jobs were produced in 1959 for tests by Underwriters' Laboratories; regular production commenced In 1960. 1 As of December of 1969 Firecode V had been dropped from U.S. Gypsum's product line and sales of this produat had not been actively solicited by the company for some time. U.S. Gypsum believes that a limited quantity of Firecode V was produced in early 1970 at the Bast Chicago plant for the completion of a single job already In progress. page 15 of 16 February 16, 1993 ta u.s. Gypsum manufactured fiprayDon pursuant to the specifications of Sprayon Research Corporation. While Types A and G remained on operating bulletins until 1973, production of G was discontinued in 1970, and A was discontinued on January 1, 1972. Type I, though authorized, was never produced. u From production records. u K-Fac 19 was produced for A.P. Green and packaged and sold by that company under the name IUSBLOK. Information contained in plant records suggests that production may have commenced in 1969. it Information contained in plant records suggests that production may have commenced in 1965. u Temporary production only. i) Trial job authorized for temporary production only on and off from 1959 to 1961. u Marketed from 1970 to 1977 as Sheetrock Texture Finish Paint In Canada. i Although authorization to manufacture these products was not cancelled until 1940, the last sales took place in 1938. i* Actual Canadian production ceased in 1978. ai This product line was manufactured by a company that beoame a u.s. Gypsum subsidiary in 1971, and records of the production history are incomplete. at Records regarding the production history of this product line are incomplete. u Though authorized for production until 1978, actual production ceased in 1977. Most of the products identified in this exhibit have a shelf life of approximately six months, with some variation due to humidity and storage conditions. It is the policy of the defendant to provide this information to all customers. Therefore, date of last production approximates date of last , sale, though U.S. Gypsum is not certain whether shelf life guidelines were adhered to by its customers. Reasonable investigation is continuing. Further information concerning products which are established to be at Issue is contained in documents which will be made available for inspection at the offices of United States Gypsum, 125 South Franklin Street, Chicago, XL 60606-4678. page 16 of 16