Document NXjbKmVR9NgEKRV69JNMg1ER

PLAINTIFF'S EXHIBIT NO. B-126,986 RUSSELL H. ALLEN, ET AL VS. AMERICAN PETROFINA, ET AL S IN THE DISTRICT COURT OF JEFFERSON COUNTY, TEXAS S 60TH JUDICIAL COURT MOBIL'S RESPONSES TO SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS TO: Russell H. Allen, et al. Plaintiffs, by and through their attorneys of record, Herschel Hobson, 2190 Harrison, Beaumont, Texas 77701 COMES NOW, Defendant Mobil Oil Corporation (including the responses of Mobil Mining & Minerals Company and Mobil Chemical Company, Inc.), and pursuant to Rule 167 of the Texas Rules of Civil Procedure, files its responses to second request for production of documents, as follows: I. PRELIMINARY STATEMENT Subject to any objections that might be made at the time of trial as to the admissibility into evidence of the information contained herein and without waiving any of the same. Defendant makes the following responses: II. RESPONSE TO SECOND REQUEST FOR PRODUCTION OF DOCUMENTS 1. Please produce a copy of your document retention policies this Defendant has used since it began such a policy, but not before 1945. This request seeks sufficient information to determine when a document retention policy began (or if one existed in 1945), what each policy was and each change and when each change became effective. 014143 RESPONSE: Mobil hereby produces the following documents which may be responsive to the request: 1. Sections of the 1964 policy manual regarding record retention and disposal. (Please note that this is the best copy Defendant could locate, and it is possible that it may not contain each and every page and/or section of the original, due to the passage of time.) 2. 1986 "Record Retention/Disposal Guidelines" for the Beaumont Refinery, which are believed to have been designed to supplement the 1964 manual referenced above. 3. A 1980 pamphlet entitled "Twenty Questions About Records Management In Mobil." Defendant, in producing the policies requested, cannot affirm that all policies have been observed on all occasions. Respectfully submitted, BENCKENSTEIN, NORVELL, BERNSEN & NATHAN 7 ^GAIL STATE feAR NO. 052&1525 P.O.^BOX 551 40NT, TEXAS 77704 (409) 833 - 4309 ATTORNEYS FOR DEFENDANT, MOBIL CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been hand-delivered to plaintiffs' counsel on this 014150 LIPSCOMB NORVELL. JR. DAVID ERIC BERNSEN JERRY J. NATHAN GERALD W. RIEDMUELLER GAIL C. JENKINS MICHAEL J. REVIERE * RUSSELL W. HEALD DAVID . GROVE BOARD CERTIFIED PERSONAL INJURY TRIAL LAW TEXAS BOARD OF LEGAL SPECIALIZATION BOARD CERTIFIED PERSONAL INJURY ft CIVILTRIAL LAW TEXAS BOARD OF LEGAL SPECIALIZATION BENCKENSTEIN, NORVELL, BERNSEN & NATHAN ATTORNEYS AT LAW 2615 CALDER. 6TH FLOOR P.O. BOX 551 BEAUMONT. TEXAS 77704 TELEFAX (409) 833-9558 TELEPHONE M09> 833-4309 HOUSTON OFFICE 8 GREENWAY PLAZA SUITE 802 HOUSTON. TEXAS 77046 TELEFAX (7131871-1509 TELEPHONE (7131871-8081 August 30, 1990 VIRGINIA P. FAWCETT DONALD FRANCIS LIGHTY PAUL A SCHEURICH FLOYD F. McSPAODF.N. JR. AMY STOUT BEAN L BRENT FARNEY KERRY B. McKNIGHT IRL L NATHAN ELIZABETH E. BROWN WAYNE E. REVACK JOHN H. BENCKENSTEIN OF COUNSEL P.O. BOX 669 In Res Cause No. B-126,986; Russell Allen Consolidated Lawsuit Mr. Herschel Hobson 2190 Harrison Beaumont, Texas 77701 BY HAND DELIVERY Dear Herschel: Enclosed please find the following responsive pleadings in reference to the above styled cases 1. Mobil's Responses to Second Request for Production of Documents to Defendants; and 2. Fina's Responses to Second Request for Production of Documents to Defendants. Sincerely, GCJspjd ENCLOSURES ccs Mr. Joe Blanks ALL COUNSEL OF RECORD HAND DELIVERY .014143 ftV563vn99