Document NGK6NB5x8ZxwmNmzn6nQGr9zV

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION URL 06618 MARY A. DENDINGER, etc. Plaintiff, vs. CHRYSLER PLASTIC PRODUCTS CORPORATION, et al., Defendants. ) Case No. C 87-7117 ) ) [Judge Nicholas J. Walinski] ) ) RESPONSES OF DEFENDANT TENNECO ) INC. TO PLAINTIFF'S REQUESTS FOR ) PRODUCTION OF DOCUMENTS DIRECTED ) TO ALL DEFENDANT PVC MANUFACTURERS ) ) -0O0- Now comes defendant Tenneco, Inc. and for its response to plaintiff's Requests for Production of Documents, states as follows: 1. All records of sales, direct or indirect, of Polyvinyl Chloride (PVC) resin from you to Chrysler Plastic Products Corporation (Chrysler) between January 1, 1967 and December 31, 1980. ANSWER: Tenneco, Inc. possesses no documents which would be responsive to this request. 2. All documents indicating the extent to which PVC resin sales to Chrysler during the time period indicated above, represented sales of PVC resin manufactured in the: (a) suspension; (b) emulsion; (c) bulk? or, (d) solution process. 6(990 ian ANSWER: Tenneco/ Inc. possesses no documents which would be responsive to this request. 3. All documents indicating the extent to which PVC resin sales to Chrysler during the time period specified in request number' 1, were of (a) Homopolymer? (b) copolymer? or, (c) terpolymer. ANSWER: Tenneco, Inc. possesses no documents which would be responsive to this request. 4. All written documents indicating, with respect to PVC resin sold to Chrysler during the time period specified above, the size (in microns) of the resin sold. ANSWER: Tenneco, Inc. possesses no documents which would be responsive to this request. 5. All written documents indicating the results of any tests done on any PVC resin by you or any other entity to determine the concentration (in parts per million) of residual vinyl chloride monomer in PVC resin of the type sold to Chrysler during the time period specified in request number 1. ANSWER: Tenneco, Inc. possesses no documents which would be responsive to this request. -2- URL 06620 6. All Material Safety Data Sheets published by you prior to January 1, 1986, relating to any PVC resin manufactured by you. ANSWER: Tenneco, Inc. possesses no documents which would be responsive to this request. 7. All documents in your possession indicating the dates of manufacture and the dates of shipment of PVC resin sold to Chrysler. ANSWER: Tenneco, Inc. possesses no documents which would be responsive to this request. 8. All written results of any testing done on the PVC resin identified in the prior request to determine the concentration of residual vinyl chloride monomer. ANSWER: Tenneco, Inc. possesses no documents which would be responsive to this request. 9. All documents sent by you to the Occupational Safety & Health Administration, relating, in any way, to PVC. ANSWER; Tenneco, Inc. possesses no documents which would be responsive to this request. 10. All documents reporting or summarizing efforts taken by you, at any time since January 1, 1967 to reduce the -3- URL 06621 percentage of residual vinyl chloride monomer in PVC resin manufactured by you. ANSWER: Tenneco, Inc. possesses no documents which would be responsive to this request. 11. Each and every document sent to Chrysler, informing Chrysler of any known or potential human health hazard relating to exposure or over exposure to vinyl chloride monomer. ANSWER: Tenneco, Inc. possesses no documents which would be responsive to this request. - 4- AS TO OBJECTIONS: Of Counsel For Defendants The BFGoodrich Co., The Goodyear Tire & Rubber Co., Firestone Tire & Rubber Co., Conoco, Inc., Uniroyal, Inc., Union Carbide Corp., Diamond Shamrock Corp., Tenneco, Inc. and Occidental Chemical Corp.: FULLER & HENRY 1200 Edison Plaza 300 Madison Avenue P.O. Box 2088 Toledo, Ohio 43603 P.O. Box 2088 Toledo, Ohio 43603 Telephone: (419) 255-8220 Attorney for Defendants The BFGoodrich Co., The Goodyear Tire & Rubber Co., Firestone Tire & Rubber Co., Conoco, Inc., Uniroyal, Inc., Union Carbide Corp., Diamond Shamrock Corp., Tenneco, Inc. and Occidental Chemical Corp. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Responses to Plaintiff's Requests for Production of Documents Directed to all Defendant PVC Manufacturers was mailed by United States mail, postage prepaid, to Kirk J. Delli Bovi, Esq., attorney for plaintiff, at his office located at Murray & Murray Co., L.P.A., 300 Central Avenue, Sandusky, Ohio 44870, and to defense counsel V ti as set forth in the attached Schedule of Service this day of February, 1987. URL 06622 An Atit^tfneS' for [Defendants The Goodyear Tire & Rubber Company, The BFGoodrich Company, Firestone Tire & Rubber Company, Conoco, Inc., Uniroyal, Inc., Union Carbide Corporation, Diamond Shamrock Corp., Tenneco, Inc. and Occidental Chemical Corp. SCHEDULE OF SERVICE M. Donald Carmin, Esq. 800 United Savings Building Toledo, Ohio 43604 Attorney for Defendants Chrysler Plastic Products Corporation Norman P. Phillips Albert W. Cramer Robert D. Gustine William C. Holsapple Ron C. Abbott Willis P. Jones, Jr., Esq. 200 Toledo Legal Building 416 N. Erie Street Toledo, Ohio 43624 Attorney for Defendant DiversiTech General, Inc. S. Stuart Eilers, Esq. Douglas N. Barr, Esq. Timothy J. Coughlin, Esq. 1100 National City Bank Bldg. Cleveland, Ohio 44114 Attorney for Defendant Stauffer Chemical Company H. William Bamman, Esq. 414 N. Erie Street Toledo, Ohio 43624 Attorney for Defendant A. Schulman, Inc. Ellis F. Robinson, Esq. 610 United Savings Building Toledo, Ohio 43604 Attorney for Defendant Shintech, Inc. URL 061323 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION ETTA WALLACE, personal representative of the Estate of Fred A. Wallace, vs. Plaintiff, CHRYSLER PLASTIC PRODUCTS CORPORATION, et al.. Defendants. ) Case No. C 84-7864 ) [Hon. Nicholas J. Walinskil ) ) AFFIDAVIT OF TENNECO, INC. ) ) ) ) ) - *4"9 -0O0- STATE OF TEXAS COUNTY OF HARRIS SS: Richard J. Lorenz, Esq., being duly sworn according to 9- -- -- law, deposes and says that he is authorized to make an affidavit on behalf of Tenneco, Inc., defendant herein, and that the facts set forth in the foregoing Response of Defendant Tenneco, Inc. to Plaintiffs' Requests for Production of Documents Directed to All Defendant PVC Manufacturers in this case are true and correct to the best of his knowledge, information and belief. URL 06624 Richard J. Lorenz (please type name) Sworn to and subscribed before me this 3rd day of Februaxy. 1987. -----ELISA Q. GONZALES Notify Public STATE OF TEXAS _____ My Comm. Exp. -7-'U PMMMMMMMMMMMMMMMM Notary Public