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'< T, yf-w-st -- *, j/ V V* * * ,- .hv A.r ' ** (Jb- *, fSe~iSM31*'>3 ,V.' *V43^, "JWw ^/t' -V. - / W ~V ' J?J. ,fc V, , - ,, $ ; ^i'!, j " i ,.f j * Ji.fcVi -*'7 * ' A ;MM r,s* jfM. _ **1 ** V7 4i -l.t-'Sfc* 3*>3jg8 S mmM` MMshe ssyy P^gl - i -V'7: * -4.*ut ^uitrUKA'iXON COMMONWEALTH OF MASSACHUSETTS COUNTY OF NORFOLK ss. YiRPTtOETf 3 AFFIDAVIT OF THOMAS J. HARTNETT I. THOMAS J. HARTNETT, having been duly sworn state as follows: 1. I am the Vice President of Sale3 of Bird Incorporated and I have been employed by Bird for over 35 years. I am authorized to mate this affidavit on behalf of the corporation. I have familiarity with all of die product lines, asbestos-containing and non-asbestos containing, that Bird Incorporated has manufactured and/or sold during this century. 2. AO Roofing materials manufactured or sold by Bird Incorporated (including felt and fibered roofcoating) are manufactured such that asbestos fibers are encapsulated in asphalt 3. Between 90 and 95% of all of the roofing products ever sold by Bird Incorporated (including felt and were products which contain no asbestos whatsoever. 4. Roof applications only. and/or sold by Bird Incorporated was for commercial d have never been used on nesiden 5. Bird Incorporated only manufactured and/or sold commercial 70 6. The only asbestos-containing shingles ever manufactured or sold by Bird Incorporated were manufactured during the late 1960's and early 1970's on an experimental basis. Bird Incorporated only manufactured 3,000 squares which would only be enough for 120 roofs. The experiment failed and Bird Incorporated abandoned that experimental product 7. Bird Incorporated sold no asbestos containing siding prior to 1955. <eiuuo SUBSCRIBED before me, a Notary Public tins 24th day of September, 1996. fyaal,- Margaret M. DoaJc Notary Public My cotnmissian expires: 9/14/2001 wp/AffHH  . ''\ PLAINTIFF'S EXHIBIT exhibit u-t-qb ^ l? --s \/ ~ '* progress through innovation 1795 George Bird established the first Bird Paper Mill. 1885 First Neponset Black Building Paper was made using as a base the rosin sized sheathing paper. It was named Neponset Black Waterproof Building Paper and is believed to be the first waterproof building or sheathing paper where the saturant used had no tar in its make-up. 1886 First ready roofing (Red Rope) was made. 1901 A patent was granted to C. S Bird, Sr. for an apparatus and method for saturating roofing felt. This apparently was the first patented method used in the roofing industry to saturate felt. 1915 Patent granted on built-up feature of folded back Twin Shingles. The first Double Coated and Oouble Sur faced shingles were made by a new method using two complete coating and surfacing sections on the machine. 1916 10" Butts on Twin and Double Twin shin gles became identified with Bird. 1925 First artificial weathering system to be used in the roofing business was installed by Bird. First in the business to oil treat roofing granules to prevent dusting and to obtain better adhesion and diminish blistering. 1926 Introduced the machine made Thick Butt shingle. This type of shingle was first made at Building Products Ltd. of Canada in which Bird owned stock and later was passed oA to the other Bird mills. 1927 We developed an asbestos filled coating for shingles and siding and this was forerunner of "Asbestosized" coating for panels and for fire resistant Class A shingles. 1929 Art-Brick Siding was developed and intro duced. It was the first asphalt product produced anywhere to simulate brick. For several years we made all of this item produced in the country, making it for some of our competitors and sup plying labels and direction sheets for such com panies as Flintkote, Barber. Barrett and Ruberoid. 1930 Shatterproof Coating was perfected and introduced in January of this year. Bird & Son was first in the field with shingles which could be laid safely all through the cold weather. 1931 Multi Brie Siding was brought out. This was the forerunner of sheet brie siding. Quick Setting Cement -- a brand new idea in mooting cement for blind nail application was introduced. 1932 insulated Br:c Siding with Cap Sheet v.-as inircoucec by Bird & Son ana was the first of the insulated Sic-ngs produced in this country. 1933 A new process for coloring granules was developed. Bird was among the firs; to develop a satisfactory inexpensive method for permanent!- coloring roofing granules. ' 1956 The "Wind Seal" sningle was introduced This was the first of the seal down type of shingle which was made to be applied in the normal man ner. Previous-seal down shingles required such things as separating the shingles before applica tion, packaging the shingies in reverse order, aoplying tissue paper or aluminum foil strips over the adhesive and the like. The "Wind Seal" shingle manufactured by Bird was packaged in the regular manner as was customary for packing Strip Shingles and the applicator did not havelo pull them apart or pick them out in reverse order or the like. 1963 Solid Vinyl Siding and accessories are in troduced. It was the first Vinyl Siding which could be easily and successfully applied to sidewalls and which offered strong competition to aluminum siding. introduction of the first "no cut-out" line. of asphalt roofing shingles was made with the Architect MARK 25 shingle. Both tKe Solid Vinyl Siding and the Architect MARK:25' roofing shingle were presented at the Bird & Son "House of Good Taste" exhibit at the famed New York World's Fair. 1967 Bardstown, Kentucky. New'plant dedicated solely to the manufacture of Plastic Building Prod ucts. The new Wind Seaf"JET" roofing shingle joined the line of "no cut-out" roofing. A dramatic demonstration occurred at a Manchester, New Hampshire airport where a DC-9 jet passenger air liner was used to test the roofing shingles' resis tance to extremely high winds. 1968 The Pabco Roofing Division was purchased " from the Fibreboard Corporation of California. This ' acquisition afforded Bird & Son coast to coast " product distribution for the first time. ;' -l- 1969 A new heavyweight asphalt roofing_$hingle.was added to the line. Constructed with two sur face layers, the Architect 70 roofing shingle was introduced. It is textured and random edged to give the appearance of a wood "shake" shingle. Its name was given to symbolize the decade in which it was introduced. 1972 Through a revolutionary new process of sculpturing the surface of molten vinyl. Bird & Son announced the introduction of BRANDED Vinyl Siding. This three dimensional textured surface is further enhanced with subtle shadings of vinyi-onvinyl coloring. Work was completed on the third ms-or ex pansion program at the Plastic Products 0 vis.on in Bardstown. Ky. 3' .'J092 BIRD 017104 DATE * 1793 - 1795 1317 1333 1902 < 1904 1907 ^ 1911 ^ 1912 1913 t 1915 1919 1921 BIRD & SON, inc. GENERAL HISTORY George Bird purchased a power site at Charles River Village, Needham. Started manufacture of paper by hand at the Needham location. Began to operate a paper mill in East Walpole (present site of Hollingsworth & Vose Company). George Bird purchased the Neponset Paper Company from Jabez Coney, Jr located on the upper privilege, and began operations on the present site of the Bird & Son paper mill. Bird &. Son abolished the 12-hour working day, establishing three 8-hour shifts. Norwood Roofing plant was built - first known as Paroid Mill. Phillipsdale Felt Mill built. The Norwood Floor Covering Plant was built. Suggestion Plan started. Publication of the Bird Neponset Review started. This name was later changed to the Bird Review. The Neponset Credit Union was established - the first industrial Credit Union in the United States. Plant Hospitals were established. The Bird Club was organized - organized recreational activites for employees. Bird & Son became one of the first companies to establish paid vac ations for hourly employees. BIRD 017105 " I 3003 \ HISTORY PAPERBOARD PRODUCTS DATE 1795 Quality paper products first produced by hand as a paper making machine was not invented until 1803 - in England 1812 Paper for U.S. currency. 1900 Shoe Cartons 1908 Solid fibre shipping cases. 1924 - 1925 Corrugated fibre boxes first manufactured. 1950 Approximate date the following products introduced for shoetrade: platform board, wedgie board, innersole board. 1958 Paper Mill Cores, Textile Tubes, Paper Tubes for special purposes (all made at newly acquired Dinsmoor Plant). 1960 Plastic FlowerPots (Horticultural Division). 1969 Sold Fibre Box plant to Hoerner Waldorf. B13094 BIRD 017106 DATE 1962 1963 1964 1964 1967 1967 1968 1969 1971 HISTORY BUILDING MATERIALS GROUP V A plant for the manufacture of roofing felt was purchased at Chicago. Bird Solid Vinyl Siding introduced. '* Bird Solid Vinyl Shutters introduced. Also the Bird Solid Vinyl Rain Carrying System. Bird Architect Mark 25 Shingle, with no cut outs. Bird Wind Seal "Jet" Shingle introduced. A Vinyl Siding Plant was built at-Bardstown, Ky., to manufacture all vinyl products, and the vinyl production at the Norwood and Chicago Roofing Plants was discontinued. Bird & Son purchased the Pabco Oivision of Fibreboard Corporation witn roofing plants located at Martinez and Wilmington, California and Portland, Oregon; office at San Mateo, California and laboratory at Fair Oaks, California. Now known as the Pacific Division. Bird Architect 70 introduced. Chicago Roofing Plant closed 4/30/71. q^ 3095 BIRD 017107 / / DATE 1877 1894 1904 1507 1917 1928 1928 1937 1941 1943 1954 1957 1959 1962 1962 HISTORY BUILDING MATERIALS GROUP Charles S. Bi_rd started experimenting in the field of building papers- - -Paroid Roofing Norwood Roofing Plant was built - first known as the Paroid Mill. Phillipsdale Felt Mill built. The Chicago Roofing Plant was purchased. Thick Butt Shingles manufactured at all Bird Plants. Insulating Board introduced. The Shreveport Roofing Plant was purchased. Insulating Board Mill built at Phillipsdale, R.I. Granule Plant established at Glenwood, Arkansas. New Roofing Plant opened in Charleston, South Carolina; built during 1953. A warehouse for Building Materials Products opened in St. Louis, Mo. Roof Insulation introduced. Bird Vinyl Drip Edge and Rake Edge - first sol id vinyl products introduced. A plant for the manufacture of roofing materials was purchased from Kusby Madison in Perth Amboy. Now known as Perth Amboy Roc-*:'c plant. BIRD B 10096 / DATE 1909 1912 1915 1920 1972 HISTORY BIRD MACHINE A partnership, started several years earlier between Charles Bird and Otto Wandel, was incorporated as the Wandel Screen Manufact uring Company. This was the beginning of the 8ird Machine Co. Mr. Bird bought out Mr. Wandel's share in the Wandel Screen Manuufacturing Company. The Wandel Screen Manufacturing Co. name was changed to Bird Machine Co. Space for offices and engineering work was rented from Bird & Son on second floor of Shoe Carton Plant, over the Fire Brigade Room. Manufacturing was done by L.F. Fales Machine Co., in Walpole. The Bird Machine Company moved to its present location in South Walpole, Bird Machine Company became a wholly owned subsidiary. B-1309 7 BIRD / OATE 1945 1947 1947 1963 BIRD & SON, inc. GENERAL HI STORY First formal plan established for retirement annuities for salaried employees (John Hancock). Changed to a retirement trust with in surance provided by Massachusetts Mutual in 1947. New Group Insurance plan with Aetna Life Insurance replacing Mutual Benefit Association which had been in operation since 1901. Plan provides: life insurance, hospitalization, surgical fees, weekly sick benefits, for hourly employees and payment for doctor's services. Formal retirement plan established for all employees, operated under a Trust Fund. For salaried employees, this replaced the John Hancock plan. The Floor Covering Division was said to New London Mills, Inc., of Connecticut. Most management and hourly paid employees continued in employment with the new company. aA3098 BIRD PLAINTIFF'S EXHIBIT bur SYSiat BURQUNST.RPT ID * BOND NUMBER SIATE SIATUS 13787 20PBU 1598 . DE 0 10966 20JPBU 4301 DE T 12923 20JPBU 4184. DE 0 10965 20JPBU 4703F DE 0 10968 20JPBU 50B5F DE , T 10967 20PBU 3349 DE T 14221 20PBU 2356 DE ? 13498 10JPBU 8709 DE 0 BUILT UP ROOFING BONDS OWNER BY APPLICATION SITE STATE OF DE PAGE-# l PRINTED 14-1 BOND VALUE DATE OWNER ' S NAME CITY STATE SORT APPLICATOR'S C IIY STATE 0.00 07// /68 270.00 OS/08/BO AMERICAN BROADCASTING CO. . RIGOLIBROS. WILMINGTON DE ' AMERICAN. ` VINELAND ; ^ ..NJ . R; -' BALTIMORE IRUSI CO .. QLIPHANT .t; SQNSi,';C.C. SELBYVILLE DE BALXIMQR, 0.00 CAULK CO.. L.D. 02/21/71 MILEORD DE 1,210.00 CHESUOLD FIRE CO. 02/04/72 CHESUOLD DE CAULK CO CHESUOLD IRIrSIATE RFQ. . SEAWARD JpE%n ` '; - OLIPHANI, C.C.'; rSONvRK ' LAUREL " DE . Cl . 770.00 DELHARVA POWER t LIGHT CO. 12/12/72 HILLSBORO DE DELMARVA 200.00 NANTICOKE MEM. HOSPT. 12/09/70 SEAFORD DE NANTICOK OLIPHANI ANB SONS, C.D'/, LAUREL DE 'dl OLIPHANI i SON C.C. SEAFORD DE 01 0.00 RIDLEY SCH. DIST. 7/7 DELEUARE CNTY. DE ' RIDLEY S PAITI RFG. EAST RUIHERFORD NJ ? 80.00 SUSSEX CNTY. COUNCIL LIBRARY , WARRINGTON. FRANK J.' OB/22/79 GEORGETOWN DE .SUSSEX C GEORGETOWN' DE U .DIAL NUMBER OF BONDS LISTED EOR STATE DE = 8 EXHIBIT HflKTT\W S U-Ku Lid BIRD 017111 *5 . v.W%\;'V" Kv- ` ; T - I'S ggg| wI -'' **1 sg'Seea K rl' ''O;.^' MS'Vsdt i,?v%.lcS*W-9fa&i Sr-;/ ` ** '/'* & v^V^TfjJSrr '' ' m s#'# 9&fg &V55 #2 aia *3% s * * grapffiMBi t* *t * *> H w ta v*M SSSkMj >-'.'v,r ^fr.< Mil :,s3' 'rtf'* i a S$? S8& gglliiSl * '^<1 >-': -..ckkr' :.;\v.' t L,-f-;ri-. i.'.<r..-.*. v ^.vjes'FM rf ' Mu* y<< ' *A ' r^ V* r. ^a'vA. IV4 / $ *&f`^f.v,4 '-%J ' -%kr^-i^V*A ;l''2iff;; v> * L 1 T r,'t 'jV'" ,,. r i "o(, V r.Sti i- r-J I - '#;"' '.mV,. ,j * ' T> r' \ ** '- - il ~ ^ >) Vv /' vC-- '%*/ * ^^riiuog>tn^ffi fl8rasJ .fn,4VJ; / ......ipi-%*:-^>>-,' ...'....'.V.;.*.^..r>\^-.V- ,* ^ ,, ffafftfb&fc ( ' * 41 3K^ *** > v - \ r -^-f' -j-'?X-'. J- ^ Aj? 4 fi; " * * 2 *w"' m%* vy tC `;5t /" -. ;.,''iV-tH'^ i &3g* !.-/'/ V '^r - s' - "; ' is '< '" ' " T `; '-^C-V-- r.'.Sj yV -,- A' * s/ \ '. /-- - . ' ,;'1'f',';/,'l^-' v-; t'f - ,,'i,; j.7* . ^ ^ ^ j < * ,< . -', > - \ -j-', T'-C* [ ' t J \y1^^ r ' "^ /\Mv*-.,: . - ^v<-v'.:>' "-:'-'"V"^ r>-kvl v.:; -' ..V'.'-'^v-.-i.>-V\^yrK'&. ^,'- ... -' - :- .v ... '' ' ............. ; ?- ?&-i&5W SlUs IN THE SUPERIOR COURT OF THE STATE OF DELAWARE IN AND FOR NEW CASTLE COUNTY IN RE: ASBESTOS LITIGATION George Harrigan Michael McLaughlin Edward Kline Fredrick Dieterle C. A. C. A. C. A. C. A. No. No. No. No. 96C-03-050 96C-06-063 96C-03-115 96C-07-167 CONLEY TRIAL GROUP Limited to: Francis Conley C. A. No. 94C-05-137 C. A. No. 94C-05-137 BRUCE TRIAL GROUP Limited to: William Emmell C. A. No. 94C-11-226 KUBASKO TRIAL GROUP Limited to: Beatrice Wiseman C.A. No. 95C-06-283B GALLOWAY TRIAL GROUP Limited to: Arnold Wiseman C.A. No. 95C-06-283A 1996 ATION' S f/k/a BIRD & SONS, INC., RESPONSE TO PLAINTIFF'S NOTICE OF DEPOSITION DUCES TECUM Jonathan L. Parshall Murphy Welch & Spadaro Bird Corporation Defendant Bird Corporation ("Bird") submits its responses to Plaintiff's Notice of Deposition Duces Tecum pursuant to Rules 30(b)(5) and 34 of the Rules of Civil Procedure for the Superior Court of Delaware. GENERAL OBJECTIONS 1. Bird objects to the Notice to the extent that it seeks information protected by the attorney-client privilege, work product doctrine and any other privileges BIRD 017112 2 and. immunities. 2. Bird objects to the Notice to the extent that it seek's information, not within Bird's possession, custody or control; it seeks information that is unreasonably cumulative or duplicative, or is obtainable from some other source that is more convenient, less burdensome or less expensive; and that it may be construed to require responses beyond those required by the Civil Rules. 3. Bird objects to the Notice to the extent it is vague, ambiguous., overly broad and does not identify the documents sought with reasonable particularity. 4. Bird objects to the Notice to the extent it seeks documents not relevant to, nor reasonably calculated to lead to the discovery of admissible evidence in this litigation. RESPONSES TO SPECIFIC REQUESTS 1. Copies of all documents, memos, invoices, photographs, diagrams, or other records which indicate the type of asbestos or asbestos containing material or product which was supplied or produced between 1930' and 1975 and was supplied to sites including but not limited to Amoco Chemicals Corporation, formerly Avisun; Allied Chemical Corporation; E..I. duPont de Nemours & Company, Inc., at their Delaware facilities including its Newport plant, Edgemoor plant, Seaford plant and Laboratories in New Castle County, Delaware, Delaware; E.I. duPont de Nemours & Co., at its New Jersey facilities, including but not limited to its BIRD 017113 3 Chambers Works Plant, Carneys Point Plant and Linden Plant; Delmarva Power & Light Company, Tidewater Oil Company at its Delaware Refinery; and contractors for use in the State of Delaware including but not limited to, Catalytic, Inc; Delaware Insulation Company; Bechtel & Bauer; as well as with regard to the supply of asbestos materials to JohnsManville; Philip Carey; Owens-Coming Fiberglass; Crane Packing Co.; Owens-Illinois, Inc.; Anchor Packing Co.; Shields Lumber Company; Flite Insulation Co; Garlock Inc.; Insulations Materials; Kay Asbestos Co.; and McCrath Gasket Company; Haveg Industries or Hercules, Inc., for use in Delaware. RESPONSE: Bird objects to this Request as vague, ambiguous, overly broad, unduly burdensome and oppressive. Subject to the foregoing general and specific objections, responsive documents from Bird's files which can be identified as relating to sales in the State of Delaware will be made available for inspection and copying at the deposition. 2. Copies of all documents, memos, records or other written material (in your possession or available to you) which indicate the type and brands of asbestos and asbestos containing materials used in your products between 1930 and 1975 (the same document with notes on it shall be considered two documents). RESPONSE: Subject to the foregoing general objections. BIRD 017114 4 responsive documents will be made available for inspection and copying at the deposition. 3. Copies of all brochures, product information sheets or advertising copy (in your possession or available to you covering the time period from 1930 to 1975) which mention asbestos or -asbestos containing material or products that defendant manufactured or distributed, including but not limited to, asbestos containing products, or information defendant possesses concerning co-defendants' asbestos containing products. RESPONSE: Subject to the foregoing general objections, responsive documents will be made available for inspection and copying at the deposition. 4. Copies of all correspondence pertaining to your sale of asbestos or asbestos containing products to any of the aforementioned companies, distributors or contractors. RESPONSE: Bird objects to this Request as vague, ambiguous, overly broad, unduly burdensome and oppressive. Subject to the foregoing general and specific objections, responsive documents from Bird's files which can" be identified as relating to sales in the State of Delaware to the entities referenced will be made available for inspection and copying at the deposition. 5. Copies of all correspondence, memos, invoices, brochures or other written materials pertaining to your receipt, from any company or distributor, U.S. or foreign. BIRD 017115 of raw asbestos fibers which were used by you in your manufacturing process. RESPONSE: Subject to the foregoing general objections, responsive documents will be made available for inspection and copying at the deposition. 6. Samples of product bags or containers used by defendant for asbestos containing products manufactured or sold by defendant, including but not limited to, asbestos containing products, photographs, slides, sketches or other pictorial depiction of said product bags or containers are also requested. RESPONSE: A pail of roofing cement will be made available for inspection at a mutually agreed upon time and place. 7. Copies of any depositions or any testimony given before any government or quasi government body or court regarding asbestos, and any similar document (including but not limited to speeches, pamphlets, brochures, articles, books and the like) which refers to asbestos. RESPONSE: Bird objects- to this request as vague and ambiguous. Bird further objects to producing deposition transcripts for deponents other than its current and former employees. Subject to that objection and the general objections, responsive documents related to current and former Bird employees will be made available for inspection and copying at the deposition. 6 8. All documents dealing with membership and involvement with any of the following organizations: The National Insulation Manufacturers Association (NIMA); Thermal Insulation Manufacturers Association (TIMA) Industrial Health Foundation and Industrial Hygiene Foundation (IHF); Asbestos Textile Institute (ATI); Magnesia Insulation Manufacturers Association (MIMA); Quebec Asbestos Mining Association (QAMA); Asbestos Information Association (AIA) ; Spray Mineral Fibers Manufacturers Association (SMFMA); and National Insulation Contractors Association(NICA) . RESPONSE: Subject to the foregoing general objections, responsive documents will be made available for inspection and copying at the deposition. 9. Copies of all documents, memos, invoices, photographs, diagrams, or other records which indicate the type of asbestos or asbestos containing material or product which was supplied or produced between 1930 and 1975 and was supplied to any roofing and/or building supply businesses. RESPONSE: Subject to the foregoing general objections, responsive documents will be made available for inspection and copying at. the deposition. /s/ Jonathan L. Parshall MURPHY WELCH & SPADARO Roger D. Landon, ID No. 2460 Jonathan L. Parshall, ID No. 3247 BIRD 017117 6 B. All documents dealing with membership and involvement with any of the following organizations: The National Insulation Manufacturers Association (NIMA); Thermal Insulation Manufacturers Association (TIMA); Industrial Health Foundation and Industrial Hygiene Foundation {IHF}; Asbestos Textile Institute (ATI); Magnesia Insulation Manufacturers Association (MIMA); Quebec Asbestos Mining Association (QAMA) ; Asbestos Information Association (AIA) ; Spray Mineral Fibers Manufacturers Association (SMFMA); and National Insulation Contractors Association(NICA) . RESPONSE: Subject to the foregoing general objections, responsive documents will be made available for inspection and copying at the deposition. 9. Copies of all documents, memos, invoices, photographs, diagrams, or other records which indicate the type of asbestos or asbestos containing material or product which was supplied or produced between 1930 and 1975 and was supplied to any roofing and/or building supply businesses. RESPONSE: Subject to the foregoing general objections, responsive documents will be made available for inspection and copying at. the deposition. /s/ Jonathan L. Parshall MORPHY WELCH &. SPADARO Roger D. Landon, ID No. 2460 Jonathan L. Parshall, ID No. 3247