Document Negb9bdK74Eap85Kg9RrLnbKE
FILE NAME Kubota KUB
DATE 2007
DOC KUB014
DOCUMENT DESCRIPTION Legal - Defendant Kubota's Amended Responses to Plaintiffs Request for Admissions
Howard L. Halm State Bar No. 44498 Aide C. Ontiveros State Bar No. 169629 WILSON ELSER MOSKOWITZ
EDELMAN & DICKER LLP
555 S. Flower Street Suite 2900 Los Angeles California 90071
Telephone 213 443-5100 Facsimile 213 443-5101 Attorneys for Defendant
KUBOTA CORPORATION
6
Randall K. Bernard Esq State Bar No. 181522 7 WILSON ELSER MOSKOWITZ
EDELMAN & DICKER LLP
8 525 Market Street 17th Floor
San Francisco California 94105
9 Telephone 415 433-0990
Facsimile
415 434-1370
Attorneys for Defendant
KUBOTA CORPORATION
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES - CENTRAL DISTRICT
CHRIS WEBBER
Plaintiff
V.
A.H. VOSS et al and 1 DOES to 300
Defendants
) Case No BC 368967
eu? Action Filed April 5 2007
Seat! Judge
aad!
Hon James C Chalfant Dept. 13
Sweet! DEFENDANT KUBOTA Sane! CORPORATION'S AMENDED Senet! RESPONSES TO PLAINTIFF'S
Neusat? REQUEST FOR ADMISSIONS
Sea! Sea! SET NOS 1-5 Nese! Sent!
See
PROPOUNDING PARTY :
~
Plaintiff CHRIS WEBBER
RESPONDING PARTY
SET NOS
>:
Defendant KUBOTA CORPORATION
1-5
Defendant KUBOTA CORPORATION Defendant hereby responds to Plaintiff
Chris Webber's Plaintiff Request for Admissions Set Nos 1-5 as follows
/// ///
1
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
6078061
PRELIMINARY STATEMENT
These responses are made solely for the purpose of and in relation to this action Each
answer is given subject to all appropriate objections including but not limited to objections
concerning competency relevancy materiality propriety and admissibility which would require
the exclusion of any statement contained herein where made by a witness present and testifying
6 in court All such objections and grounds therefore are reserved and may be interposed at the
time of trial
8
It should be noted that this responding party has not fully completed its investigation of
9
the facts relating to this case has not yet fully completed its discovery in this matter and has not
10
completed its preparation for trial All of the answers contained herein are based only upon such
11
and information and documents which are presently available to
12
specifically known to this
responding party and disclose only those contentions which presently occur to such responding
13
party It is anticipated that further discovery independent investigation legal research and
14
analysis will supply additional facts add meaning to the known facts as well as establish
15
entirely new factual conclusions and legal contentions all of which may lead to substantial
additions to changes in and variations from the contentions herein set forth
17
18
As Responding Party ceased the sale of asbestos cement pipe in 1975 and during the
19 ensuing 32 years potentially knowledgeable witnesses have left employ of the asbestos
20
cement pipe division of Kubota Corporation or have become deceased and through standard
222
company record destruction policies potentially responsive documents have been destroyed it
222
23
should be noted that Responding Party lacks sufficient information and belief to respond to many
24
of the requests for admissions These responses are made on behalf of Kubota Corporation only
with regard to information existing during the time asbestos cement pipe was exported to the
26
United States
27
28
2
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
2 The following responses are given without prejudice to Kubota Corporation's right to produce evidence of any subsequently discovered facts which this responding party may later 3
recall Kubota Corporation accordingly reserves the right to change any and all answers herein
4
as additional facts are ascertained analyses are made legal research is completed and
5
6 contentions are made
T 8 9
10
11
111 12 13
The answers contained herein are made in a good faith effort to supply as much factual
information and as much specification of legal contentions as is presently known but should in no way be to the prejudice of Kubota Corporation in relation to further discovery research or any answers to herein no admission of any nature whatsoever is to be implied or inferred The
fact that any request for admission herein has been partially answered should not be taken as an
admission to the entire request or that such answer constitutes evidence of any facts thus set
forth or assumed All answers must be construed as given on the basis of present recollection
Any request for admission deemed as continuing is objected to as oppressive over burdensome
improper and not in compliance with Code ofCivil Procedure Sections 2033 et seq and will
not be regarded as continuing in nature
RESPONSES AND OBJECTIONS TO REQUEST FOR ADMISSIONS
REQUEST FOR ADMISSION NO 1
Admit that you had an exclusive distribution agreement with VOSS under which VOSS
SOLD KUBOTA ASBESTOS CEMENT PIPE in California prior to 1965
RESPONSE TO REQUEST FOR ADMISSION NO 1
Admit for period beginning in 1962. However Voss did obtain asbestos cement pipe
24
from other manufacturers 222
222 REQUEST FOR ADMISSION NO 2
27
Admit that you had an exclusive distribution agreement with VOSS under which VOSS
SOLD KUBOTA ASBESTOS CEMENT PIPE in California in 1965
3
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
6078061 6078061
l RESPONSE TO REQUEST FOR ADMISSION NO 2
3
Admit However Voss did obtain asbestos cement pipe from other manufacturers
REQUEST FOR ADMISSION NO 3
4
5
Admit that you had an exclusive distribution agreement with VOSS under which VOSS
.6 SOLD KUBOTA ASBESTOS CEMENT PIPE in California in 1966
RESPONSE TO REQUEST FOR ADMISSION NO 3
8 manufacturers Admit However Voss did obtain asbestos cement pipe from other
9 REQUEST FOR ADMISSION NO 4
110 0
12
13
14TE
14
15
Admit that you had an exclusive distribution agreement with VOSS under which VOSS SOLD KUBOTA ASBESTOS CEMENT PIPE in California in 1967 RESPONSE TO REQUEST FOR ADMISSION NO 4
Admit However Voss did obtain asbestos cement pipe from other manufacturers REQUEST FOR ADMISSION NO 5
16
16EE
18
19
Admit that you had an exclusive distribution agreement with VOSS under which VOSS SOLD KUBOTA ASBESTOS CEMENT PIPE in Los Angeles County prior to 1965
RESPONSE TO REQUEST FOR ADMISSION NO 5
Admit for period beginning 1962. However Voss did obtain asbestos cement pipe from
other manufacturers
REQUEST FOR ADMISSION NO 6
Admit that you had an exclusive distribution agreement with VOSS under which VOSS
SOLD KUBOTA ASBESTOS CEMENT PIPE in Los Angeles County in 1965
RESPONSE TO REQUEST FOR ADMISSION NO 6
2 Admit However Voss did obtain asbestos cement pipe from other manufacturers REQUEST FOR ADMISSION NO 7 Admit that you had an exclusive distribution agreement with VOSS under which VOSS
4
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
1
SOLD KUBOTA ASBESTOS CEMENT PIPE in Los Angeles County in 1966
2
RESPONSE TO REQUEST FOR ADMISSION NO 7
3 Admit However Voss did obtain asbestos cement pipe from other manufacturers
4
REQUEST FOR ADMISSION NO 8
S
Admit that you had an exclusive distribution agreement with VOSS under which VOSS
6 SOLD KUBOTA ASBESTOS CEMENT PIPE in Los Angeles County in 1967
8 RESPONSE TO REQUEST FOR ADMISSION NO 8 -
9
Admit However Voss did obtain asbestos cement pipe from other manufacturers
10 10
REQUEST FOR ADMISSION NO 9
11
Admit that you had an exclusive distribution agreement with VOSS under which VOSS
12
SOLD KUBOTA ASBESTOS CEMENT PIPE in Carson California prior to 1965
13
14 RESPONSE TO REQUEST FOR ADMISSION NO 9
ms,
Admit for period beginning 1962. However Voss did obtain asbestos cement pipe from
16
other manufacturers
17 REQUEST FOR ADMISSION NO 10
18
19
20
|
2
Admit that you had an exclusive distribution agreement with VOSS under which VOSS
SOLD KUBOTA ASBESTOS CEMENT PIPE in Carson California in 1965
RESPONSE TO REQUEST FOR ADMISSION NO 10
-
22
Admit However Voss did obtain asbestos cement pipe from other manufacturers
23
REQUEST FOR ADMISSION NO 11
222
Admit that you had an exclusive distribution agreement with VOSS under which VOSS
SOLD KUBOTA ASBESTOS CEMENT PIPE in Carson California in 1966
RESPONSE TO REQUEST FOR ADMISSION NO 11
27
Admit However Voss did obtain asbestos cement pipe from other manufacturers
III
5
DEFENDANT KUBOTA CORPORATION'S AMENDED TO RESPONSES PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 I
REQUEST FOR ADMISSION NO 12
Admit that you had an exclusive distribution agreement with VOSS under which VOSS
SOLD KUBOTA ASBESTOS CEMENT PIPE in Carson California in 1967
RESPONSE TO REQUEST FOR ADMISSION NO 12
Admit
However Voss did obtain asbestos cement pipe from other manufacturers
|
REQUEST FOR ADMISSION NO 13
Admit KUBOTA ASBESTOS CEMENT PIPE was supplied to VOSS without any
|
printed warnings affixed to the pipe prior to 1965
RESPONSE TO REQUEST FOR ADMISSION NO 13
Admit for period beginning 1962
REQUEST FOR ADMISSION NO 14
Admit KUBOTA ASBESTOS CEMENT PIPE was supplied to VOSS without any
printed warnings affixed to the pipe in 1965
RESPONSE TO REQUEST FOR ADMISSION NO 14
Admit
REQUEST FOR ADMISSION NO 15
Admit KUBOTA ASBESTOS CEMENT PIPE was supplied to VOSS without any
printed warnings affixed to the pipe in 1966
RESPONSE TO REQUEST FOR ADMISSION NO 15 Admit
REQUEST FOR ADMISSION NO 16 Admit KUBOTA ASBESTOS CEMENT PIPE was supplied to VOSS without any
printed warnings affixed to the pipe in 1967
III
6 DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
6078061 6078061
i
oe
gte
RESPONSE TO REQUEST FOR ADMISSION NO 16 Admit
REQUEST FOR ADMISSION NO 17
Admit KUBOTA ASBESTOS CEMENT PIPE was supplied VOSS without any
4 printed warning materials prior to 1965 _
7 RESPONSE TO REQUEST FOR ADMISSION NO 17
8
Admit for period beginning 1962
9 REQUEST FOR ADMISSION NO 18
10
Admit KUBOTA ASBESTOS CEMENT PIPE was supplied to VOSS without any
11
printed warning materials in 1965
12
RESPONSE TO REQUEST FOR ADMISSION NO 18 13
Admit 14
15
REQUEST FOR ADMISSION NO 19
16
Admit KUBOTA ASBESTOS CEMENT PIPE was supplied to VOSS without any
17 printed warning materials in 1966
18
RESPONSE TO REQUEST FOR ADMISSION NO 19
19 _
Admit
20
REQUEST FOR ADMISSION NO 20
222
222
Admit KUBOTA ASBESTOS CEMENT PIPE was supplied to VOSS without any
222 printed warning materials in 1967
24
RESPONSE TO REQUEST FOR ADMISSION NO 20
25 Admit
26
REQUEST FOR ADMISSION NO 21
27
Admit that YOU knew prior to 1965 of the HAZARDS ASSOCIATED WITH
28
ASBESTOS EXPOSURE
7
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
KOTRAK 1
RESPONSE TO REQUEST FOR ADMISSION NO 21
2
Deny
3 REQUEST FOR ADMISSION NO 22
4 Admit that YOU knew in 1965 of the HAZARDS ASSOCIATED WITH ASBESTOS
EXPOSURE
6 RESPONSE TO REQUEST FOR ADMISSION NO 22
Deny
6 REQUEST FOR ADMISSION NO 23
10
Admit that YOU knew in 1966 of the HAZARDS ASSOCIATED WITH ASBESTOS
11 EXPOSURE
12
RESPONSE TO REQUEST FOR ADMISSION NO 23
13
14 Deny
em
15 REQUEST FOR ADMISSION NO 24
16
Admit that YOU knew in 1967 of the HAZARDS ASSOCIATED WITH ASBESTOS
17
EXPOSURE
18
19.
20
|
RESPONSE TO REQUEST FOR ADMISSION NO 24
Deny
REQUEST FOR ADMISSION NO 25
22
22
Admit that KUBOTA ASBESTOS CEMENT PIPE that YOU SOLD TO VOSS
3232
CONTAINED CROCIDILITE prior to 1965
3232 RESPONSE TO REQUEST FOR ADMISSION NO 25
3232
Admit for period beginning 1962
26 REQUEST FOR ADMISSION NO 26
KUBOTA 2.8 Admit that 28
ASBESTOS CEMENT PIPE that YOU SOLD TO VOSS
CONTAINED CROCIDILITE in 1965
8
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
l
RESPONSE TO REQUEST FOR ADMISSION NO 26
2 Admit
3
REQUEST FOR ADMISSION NO 27
4
Admit that KUBOTA ASBESTOS CEMENT PIPE that YOU SOLD TO VOSS S
CONTAINED CROCIDILITE in 1966 6
7 RESPONSE TO REQUEST FOR ADMISSION NO 27
8
Admit
9 REQUEST FOR ADMISSION NO 28
1010 Admit that KUBOTA ASBESTOS CEMENT PIPE that YOU SOLD TO VOSS 11 CONTAINED CROCIDILITE in 1967
14 1515
17
18
1819
20
RESPONSE TO REQUEST FOR ADMISSION NO 28
Admit
REQUEST FOR ADMISSION NO 29
Admit that YOU did not warn VOSS of the HAZARDS ASSOCIATED WITH
ASBESTOS EXPOSURE prior to 1965 RESPONSE TO REQUEST FOR ADMISSION NO 29
|
Deny REQUEST FOR ADMISSION NO 30
-
2 2 Admit that YOU did not warn VOSS of the HAZARDS ASSOCIATED WITH |
222
ASBESTOS EXPOSURE in 1965
RESPONSE TO REQUEST FOR ADMISSION NO 30
222 Deny
2 28 | REQUEST FOR ADMISSION NO 31 Admit that YOU did not warn VOSS of the HAZARDS ASSOCIATED WITH ASBESTOS EXPOSURE in 1966
9
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
KOTRAK 1
RESPONSE TO REQUEST FOR ADMISSION NO 31
Deny
REQUEST FOR ADMISSION NO 32
4 Admit that YOU did not warn VOSS of the HAZARDS ASSOCIATED WITH
S 6 ASBESTOS EXPOSURE in 1967
7 RESPONSE TO REQUEST FOR ADMISSION NO 32
8
Deny
9 REQUEST FOR ADMISSION NO 33
10
Admit that YOU knew that consumers were cutting KUBOTA ASBESTOS CEMENT
11
PIPE with powered saws prior to 1965
12
RESPONSE TO REQUEST FOR ADMISSION NO 33
13
14.
Objection vague and ambiguous as to use of words consumers cutting and
15 powered saws Without waiving these objections Responding Party responds as follows
16
Admit that KUBOTA knew that consumers like VOSS would require various persons to
that 17
perform occasional cutting of pipes outdoors in small amounts but KUBOTA did not know
18
such consumers would require one person to cut pipes eight hours a day five days a week for
19
3-4 month period continuously for any reason but especially because of totally unforeseeable
20
damage to an entire shipment of pipes resulting from a storm at sea
21
22 REQUEST FOR ADMISSION NO 34
23
Admit that YOU knew that consumers were cutting KUBOTA ASBESTOS CEMENT
|
24
PIPE with power saws in 1965
25 RESPONSE TO REQUEST FOR ADMISSION NO 34
26
Objection vague and ambiguous as to the use of words consumers cutting and
22
powered saws Without waiving these objections Responding Party responds as follows
28
10 DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
K0780K 1
Admit that KUBOTA knew that consumers like VOSS would require various persons to
perform occasional cutting of pipes outdoors in small amounts but KUBOTA did not know that
such consumers would require one person to cut pipes eight hours a day five days a week for a
3-4 month period continuously for any reason but especially because of totally unforeseeable
damage to an entire shipment of pipes resulting from a storm at sea
6
7
REQUEST FOR ADMISSION NO 35
Admit that YOU knew that consumers were cutting KUBOTA ASBESTOS CEMENT
9 PIPE with powered saws in 1966
10
RESPONSE TO REQUEST FOR ADMISSION NO 35
11
Objection vague and ambiguous as to the use of words consumers cutting and
12
powered saws Without waiving these objections Responding Party responds as follows
13
Admit that KUBOTA knew that consumers like VOSS would require various persons to
14
15
perform occasional cutting of pipes outdoors in small amounts but KUBOTA did not know that
16
such consumers would require one person to cut pipes eight hours a day five days a week for a
17 3-4 month period continuously for any reason but especially because of totally unforeseeable
18
damage to an entire shipment of pipes resulting from a storm at sea
19
REQUEST FOR ADMISSION NO 36
20
Admit that YOU knew that consumers were cutting KUBOTA ASBESTOS CEMENT
21
PIPE with Powered saws in 1967 222
222
RESPONSE TO REQUEST FOR ADMISSION NO 36
222
Objection vague and ambiguous as to the use of words consumers cutting and
powered saws Without waiving these objections Responding Party responds as follows
26
Admit that KUBOTA knew that consumers like VOSS would require various persons to
22
perform occasional cutting of pipes outdoors in small amounts but KUBOTA did not know that
28
11
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
KOTROK 1
1
such consumers would require one person to cut pipes eight hours a day five days a week for a
3-4 month period continuously for any reason but especially because of totally unforeseeable
damage to an entire shipment of pipes resulting from a storm at sea
4 REQUEST FOR ADMISSION NO 37
S
S Admit that prior to 1965 YOU knew that when consumers cut KUBOTA ASBESTOS CEMENT PIPE with powered saws that asbestos fiber would be released into the air
8 RESPONSE TO REQUEST FOR ADMISSION NO 37
9
Objection vague and ambiguous as to the use of words consumers cut powered
10
saws and released into the air Without waiving these objections Responding Party responds
11 as follows
12
Admit 13
REQUEST FOR ADMISSION NO 38
14
15
Admit that in 1965 YOU knew that when consumers cut KUBOTA ASBESTOS
16
CEMENT PIPE with powered saws that asbestos fiber would be released into the air
17
RESPONSE TO REQUEST FOR ADMISSION NO 38
18
Objection vague and ambiguous as to the use of words consumers cut powered
19
saws and released into the air Without waiving these objections Responding Party responds
20
as follows 21
Admit 22
2
REQUEST FOR ADMISSION NO 39
24
Admit that in 1966 YOU knew that when consumers cut KUBOTA ASBESTOS
25
CEMENT PIPE with a powered saw that asbestos fiber would be released into the air
26 ij RESPONSE TO REQUEST FOR ADMISSION NO 39
27
Objection vague and ambiguous as the use of words consumers cut powered
28
12
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
saws and released into the air Without waiving these objections Responding Party responds
as follows Admit
REQUEST FOR ADMISSION NO 40
4
Admit that in 1967 YOU knew that when consumers cut KUBOTA ASBESTOS S
6
CEMENT PIPE with a powered saw that asbestos fiber would be released into the air
7 RESPONSE TO REQUEST FOR ADMISSION NO 40
8
Objection vague and ambiguous as to use of consumers cut powered saws
9 and released into the air Without waiving these objections Responding Party responds as
10 follows
11 Admit
12
REQUEST FOR ADMISSION NO 41
13
14
Admit that printed warnings regarding asbestos dust were on the bags of JOHNS-
15
MANVILLE asbestos fiber you were supplied by TOKYO KOGYO BOEKI SHOKAI for the
16 production of KUBOTA ASBESTOS CEMENT PIPE prior to 1965
17
RESPONSE TO REQUEST FOR ADMISSION NO 41
18
Deny
19 REQUEST FOR ADMISSION NO 42
20
21 Admit that printed warnings regarding asbestos dust were on the bags of JOHNS-
22
MANVILLE asbestos fiber you were supplied by TOKYO KOGYO BOEKI SHOKAI for the
23
production of KUBOTA ASBESTOS CEMENT PIPE in 1965
24 RESPONSE TO REQUEST FOR ADMISSION NO 42
25
Deny
26
REQUEST FOR ADMISSION NO 43
27
warnings Admit that printed
regarding asbestos dust were on the bags of JOHNS-
28
13
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
MANVILLE asbestos fiber you were supplied by TOKYO KOGYO BOEKI SHOKAI for the
3 production of KUBOTA ASBESTOS CEMENT PIPE in 1966 RESPONSE TO REQUEST FOR ADMISION NO 43
4
Deny
S
REQUEST FOR ADMISSION NO 44 6
7
Admit that printed warnings regarding asbestos dust were on the bags of JOHNS-
8
MANVILLE asbestos fiber you were supplied by TOKYO KOGYO BOEKI SHOKAI for the
9 production of KUBOTA ASBESTOS CEMENT PIPE in 1967
10
RESPONSE TO REQUEST FOR ADMISSION NO 44
11
Deny
12
REQUEST FOR ADMISSION NO 45 13
14
Admit that VOSS stamped KUBOTA ASBESTOS CEMENT PIPE with a logo that
15 consisted of Voss on triangle and Kubota underneath the triangle prior to 1965
16
RESPONSE TO REQUEST FOR ADMISSION NO 45
17
Deny
REQUEST FOR ADMISSION NO 46 19
that Admit that VOSS stamped KUBOTA ASBESTOS CEMENT PIPE with a logo
22
a consisted of Voss on triangle and Kubota underneath the triangle in 1965
22
222 RESPONSE TO REQUEST FOR ADMISSION NO 46
222
Deny
24
REQUEST FOR ADMISSION NO 47
that 25 Admit that VOSS stamped KUBOTA ASBESTOS CEMENT PIPE with a logo
26
consisted of Voss on a triangle and Kubota underneath the triangle in 1966
27
4
RESPONSE TO REQUEST FOR ADMISSION NO 47
28
Neon
Deny
14
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5 607806 1
1
REQUEST FOR ADMISSION NO 48
2
Admit that VOSS stamped KUBOTA ASBESTOS CEMENT PIPE with a logo that 3
consisted of Voss on a triangle and Kubota underneath the triangle in 1967 4
RESPONSE TO REQUEST FOR ADMISSION NO 48
S
6
Deny
7 REQUEST FOR ADMISSION NO 49
8
Admit that YOU SOLD KUBOTA ASBESTOS CEMENT PIPE to VOSS prior to 1965
9 RESPONSE TO REQUEST FOR ADMISSION NO 49
10
Admit for period beginning in 1962
REQUEST FOR ADMISSION NO 50
Admit that YOU SOLD KUBOTA ASBESTOS CEMENT PIPE to VOSS in 1965
10 RESPONSE TO REQUEST FOR ADMISSION NO 50 Admit
REQUEST FOR ADMISSION NO 51
16 Admit that YOU SOLD KUBOTA ASBESTOS CEMENT PIPE to VOSS in 1966
18
RESPONSE TO REQUEST FOR ADMISION NO 51
2 2222
Admit 222
REQUEST FOR ADMISSION NO 52 ~
Admit that YOU SOLD KUBOTA ASBESTOS CEMENT PIPE to VOSS in 1967
2 2 RESPONSE TO REQUEST FOR ADMISSION NO 52 Admit REQUEST FOR ADMISSION NO 53
26
Admit that YOU did not warn users of KUBOTA ASBESTOS CEMENT PIPE to use
28 RESPIRATORY PROTECTION when working with KUBOTA ASBESTOS CEMENT PIPE
prior to 1965
15 DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
LOTENG 1
'
1
RESPONSE TO REQUEST FOR ADMISSION NO 53
2
Objection vague and ambiguous as to use of the word working Without waiving 3
these objections Responding Party responds as follows
4
Deny 5
6 REQUEST FOR ADMISSION NO 54
7
Admit that YOU did not warn users of KUBOTA ASBESTOS CEMENT PIPE to use
8 RESPIRATORY PROTECTION when working with KUBOTA ASBESTOS CEMENT PIPE in 9 1965
10
RESPONSE TO REQUEST FOR ADMISSION NO 54 Objection vague and ambiguous as to use of the word working Without waiving
13 these objections Responding Party responds as follows
Deny
|
REQUEST FOR ADMISSION NO 55
1134 RESPIRATORY 17
Admit that YOU did not warn users of KUBOTA ASBESTOS CEMENT PIPE to use
PROTECTION when working with KUBOTA ASBESTOS CEMENT PIPE in
19 1966
RESPONSE TO REQUEST FOR ADMISSION NO 55
22
Objection vague and ambiguous as to use of the word working Without waiving
these objections Responding Party responds as follows
Deny
REQUEST FOR ADMISSION NO 56
Admit that YOU did not warn users of KUBOTA ASBESTOS CEMENT PIPE to use
2
RESPIRATORY PROTECTION when working with KUBOTA ASBESTOS CEMENT PIPE in
|
1967
16
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
ENTROK I
RESPONSE TO REQUEST FOR ADMISSION NO 56
2 Objection vague and ambiguous as to use of the word working Without waiving
3 these objections Responding Party responds as follows
4 Deny
S
REQUEST FOR ADMISSION NO 57
6
Admit that YOU did not warn users of KUBOTA ASBESTOS CEMENT PIPE to use 7
8 RESPIRATORY PROTECTION when cutting KUBOTA ASBESTOS CEMENT PIPE prior to
9
1965
10
11
RESPONSE TO REQUEST FOR ADMISSION NO 57
Objection vague and ambiguous as to the word cutting
Without waiving these
12
1014
65
objections Responding Party responds as follows Deny
REQUEST FOR ADMISSION NO 58 Admit that YOU did not warn users of KUBOTA ASBESTOS CEMENT to use
RESPIRATORY PROTECTION when cutting KUBOTA ASBESTOS CEMENT PIPE in 1965
18 RESPONSE TO REQUEST FOR ADMISSION NO 58
Objection vague and ambiguous as to the word cutting Without waiving these
21 objections Responding Party responds as follows
-
Deny
2 2 NO REQUEST FOR ADMISSION
59
Admit that YOU did not warn users of KUBOTA ASBESTOS CEMENT PIPE to use
KUBOTA RESPIRATORY PROTECTION when cutting
ASBESTOS CEMENT PIPE in 1966
222 RESPONSE TO REQUEST FOR ADMISSION NO 59
22
Objection vague and ambiguous as to the word cutting Without waiving these
17 DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
aN,
stains
1 objections Responding Party responds as follows
2 Deny
3 REQUEST FOR ADMISSION NO 60
4
Admit that YOU did not warn users of KUBOTA ASBESTOS CEMENT PIPE to use
5
6 RESPIRATORY PROTECTION when cutting KUBOTA ASBESTOS CEMENT PIPE in 1967
7 RESPONSE TO REQUEST FOR ADMISSION NO 60
Objection vague and ambiguous as to the word cutting
9 i objections Responding Party responds as follows
10
Deny
11
REQUEST FOR ADMISSION NO 61
Without waiving these
Admit that YOU did not tell VOSS to warn users of KUBOTA ASBESTOS CEMENT
PIPE to use RESPIRATORY PROTECTION when working with KUBOTA ASBESTOS
.
CEMENT PIPE prior to 1965
1 RESPONSTEO REQUEST FOR ADMISSION NO 61 Objection vague and ambiguous as to use of the word working Without waiving
these objections Responding Party responds as follows
922
Deny
REQUEST FOR ADMISSION NO 62
-
Admit that YOU did not tell VOSS to warn users of KUBOTA ASBESTOS CEMENT
PIPE to use RESPIRATORY PROTECTION when working with KUBOTA ASBESTOS
CEMENT PIPEin 1965
RESPONSE TO REQUEST FOR ADMISSION NO 62
Objection vague and ambiguous as to use of the word working Without waiving these objections Responding Party responds as follows
Deny
18 DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
REQUEST FOR ADMISSION NO 63
2 Admit that YOU did not tell VOSS to warn users of KUBOTA ASBESTOS CEMENT
3 PIPE to use RESPIRATORY PROTECTION when working with KUBOTA ASBESTOS
4
CEMENT PIPE in 1966 5
RESPONSE TO REQUEST FOR ADMISSION NO 63
6
7
Objection vague and ambiguous as to use of the word working Without waiving
|
8 these objections Responding Party responds as follows -
9
10
REQUEST FOR ADMISSION NO 64
11
Admit that YOU did not tell VOSS to warn users of KUBOTA ASBESTOS CEMENT
12
PIPE to use RESPIRATORY PROTECTION when working with KUBOTA ASBESTOS
13
CEMENT PIPE in 1967 14
RESPONSE TO REQUEST FOR ADMISSION NO 64
16
Objection vague and ambiguous as to use of the word working Without waiving
17 these objections Responding Party responds as follows
18
Deny
19 REQUEST FOR ADMISSION NO 65
20
Admit that YOU did not tell VOSS to warn users of KUBOTA ASBESTOS CEMENT 21
22
PIPE use RESPIRATORY PROTECTION when cutting KUBOTA ASBESTOS CEMENT PIPE
23 prior to 1965
24
RESPONSE TO REQUEST FOR ADMISSION NO 65
25
Objection vague and ambiguous as to use of the word cutting Without waiving these
222
objections Responding Party responds as follows
222
Deny
28
19
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
K07806 1
REQUEST FOR ADMISSION NO 66
Admit that YOU did not tell VOSS to warn users of KUBOTA ASBESTOS CEMENT
3
PIPE use RESPIRATORY PROTECTION when cutting KUBOTA ASBESTOS CEMENT PIPE
4 in 1965
5
RESPONSE TO REQUEST FOR ADMISSION NO 66 6
7
Objection vague and ambiguous as to the use of the word cutting Without waiving
8 these objections Responding Party responds as follows
9
Deny
10
REQUEST FOR ADMISSION NO 67
11
12.
13
Admit that YOU did not tell VOSS to warn users of KUBOTA ASBESTOS CEMENT
PIPE to use RESPIRATORY PROTECTION when cutting KUBOTA ASBESTOS CEMENT
PIPE in 1966 14
oo
15 RESPONSE TO REQUEST FOR ADMISSION NO 67
16
Objection vague and ambiguous as to use of the word cutting Without waiving these
17 objections Responding Party responds as follows
18
Deny
19
REQUEST FOR ADMISSION NO 68
20 Admit that YOU did not tell VOSS to warn users of KUBOTA ASBESTOS CEMENT
21
22 PIPE to use RESPIRATORY PROTECTION when cutting KUBOTA ASBESTOS CEMENT
23
PIPE in 1967
24 RESPONSE TO REQUEST FOR ADMISSION NO 68
22
Objection vague and ambiguous as to use of the word cutting Without waiving these
26
objections Responding Party responds as follows
27
Deny
28
20
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
REQUEST FOR ADMISSION NO 69
2
Admit that YOU did not require VOSS to warn users of KUBOTA ASBESTOS
3 CEMENT PIPE to use RESPIRATORY PROTECTION when working with KUBOTA
4
ASBESTOS CEMENT PIPE prior to 1965
A
6 RESPONSE TO REQUEST FOR ADMISSION NO 69
7
Objection Calls for a legal conclusion and assumes facts not in evidence Without
8
9
10
11
waiving these objections Responding Party responds as follows
Deny REQUEST FOR ADMISSION NO 70
Admit that YOU did not require VOSS to warn users of KUBOTA ASBESTOS
CEMENT PIPE to use RESPIRATORY PROTECTION when working with KUBOTA
15 11 7
19
222
ASBESTOS CEMENT PIPE in 1965
RESPONSE TO REQUEST FOR ADMISSION NO 70 Objection Calls for a legal conclusion and assumes facts not in evidence Without
waiving these objections Responding Party responds as follows Deny
REQUEST FOR ADMISSION NO 71 Admit that YOU did not require VOSS to wam users of KUBOTA ASBESTOS
CEMENT PIPE to use RESPIRATORY PROTECTION when working with KUBOTA
ASBESTOS CEMENT PIPE in 1966
RESPONSE TO REQUEST FOR ADMISSION NO 71
Objection Calls for a legal conclusion and assumes facts not in evidence Without
22
waiving these objections Responding Party responds as follows Deny
21
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
K0780K 1
REQUEST FOR ADMISSION NO 72
acne 2
Admit that YOU did not require VOSS to warn users of KUBOTA ASBESTOS
3 CEMENT PIPE to use RESPIRATORY PROTECTION when working with KUBOTA
4
ASBESTOS CEMENT PIPE in 1967
5
6 RESPONSE TO REQUEST FOR ADMISSION NO 72
7
Objection Calls for a legal conclusion and assumes facts not in evidence Without
8 waiving these objections Responding Party responds as follows
9
Deny
10 REQUEST FOR ADMISSION NO 73
11
Admit that YOU did not require VOSS to warn users of KUBOTA ASBESTOS
12
CEMENT PIPE to use RESPIRATORY PROTECTION when cutting KUBOTA ASBESTOS
CEMENT PIPE prior to 1965
1 RESPONSE TO REQUEST FOR ADMISSION NO 73
1516 Objection vague and ambiguous as to use of the word cutting assumes facts not in
17
18
20
evidence and calls for a legal conclusion Without waiving these objections Responding Party responds as follows
Deny
REQUEST FOR ADMISSION NO 74
-
2 2 ASBESTOS Admit that YOU did not require VOSS to warn users of KUBOTA ASBESTOS CEMENT
PIPE to use RESPIRATORY PROTECTION when cutting KUBOTA
CEMENT
PIPE in 1965
24 RESPONSE TO REQUEST FOR ADMISSION NO 74 Objection vague and ambiguous as to use of the word cutting assumes facts not in
.
28 evidence and calls for a legal conclusion Without waiving these objections Responding Party
22
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'SPLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
responds as follows
2 Deny
3
REQUEST FOR ADMISSION NO 75
4
Admit that YOU did not require VOSS to warn users of KUBOTA ASBESTOS CEMENT S
PIPE to use RESPIRATORY PROTECTION when cutting KUBOTA ASBESTOS CEMENT
6 PIPE in 1966
8 RESPONSE TO REQUEST FOR ADMISSION NO 75
9
Objection vague and ambiguous as to use of the word cutting assumes facts not in
10 evidence and calls for a legal conclusion Without waiving these objections Responding Party
responds as follows
Deny
REQUEST FOR ADMISSION NO 76
1133 CEMENT Admit that YOU did not require VOSS to warn users of KUBOTA ASBESTOS
16
18
222
20
;
22
22
PIPE to use RESPIRATORY PROTECTION when cutting KUBOTA ASBESTOS CEMENT
PIPE in 1967
RESPONSE TO REQUEST FOR ADMISSION NO 76
Objection vague and ambiguous as to use of the word cutting assumes facts not in
evidence and calls for a legal conclusion Without waiving objections Responding Party responds as follows
Deny
24
REQUEST FOR ADMISSION NO 77
25 Admit that YOU do not know the SYSTEM OF DISTRIBUTION VOSS used to distribute
26
KUBOTA ASBESTOS CEMENT PIPE in Orange County California from 1965 until 1968
27
RESPONSE TO REQUEST FOR ADMISSION NO 77
28
Deny
23
DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
GOTROK 1
REQUEST FOR ADMISSION NO 78
2
Admit that YOU do not know the SYSTEM OF DISTRIBUTION VOSS used to
3 distribute KUBOTA ASBESTOS CEMENT PIPE in Los Angeles County California from 1965
4
until 1968
S
RESPONSE TO REQUEST FOR ADMISSION NO 78
6
7
Deny
8 REQUEST FOR ADMISSION NO 79
-
9
Admit that YOU do not know the WORKSITES where VOSS distributed KUBOTA
10
ASBESTOS CEMENT PIPE from 1965 until 1986 sic
RESPONSE TO REQUEST FOR ADMISSION NO 79
12
Admit
REQUEST FOR ADMISSION NO 80
Admit that YOU knew VOSS SOLD KUBOTA ASBESTOS CEMENT PIPE in Los
15 Angeles County prior to 1965
RESPONSE TO REQUEST FOR ADMISSION NO 80
18
Admit for period beginning 1962
19
REQUEST FOR ADMISSION NO 81
Admit that YOU knew VOSS SOLD KUBOTA ASBESTOS CEMENT PIPE in Los
Angeles County in 1965
RESPONSE TO REQUEST FOR ADMISSION NO 81
Admit
REQUEST FOR ADMISSION NO 82
Admit that YOU knew VOSS SOLD KUBOTA ASBESTOS CEMENT PIPE in Los
Angeles County in 1966
24 DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
RESPONSE TO REQUEST FOR ADMISSION NO 82
Admit
REQUEST FOR ADMISSION NO 83
4
Admit that YOU knew VOSS SOLD KUBOTA ASBESTOS CEMENT PIPE in Los
|
5 Angeles County in 1967
RESPONSE TO REQUEST FOR ADMISSION NO 83
7.8 Admit
10
Dated November 20 , 2007
12
WILSON ELSER MOSKOWITZ EDELMAN &
DICKER LLP
13
14
Howard Halm
Aide Ontiveros
15
Attorneys for Defendant
KUBOTA CORPORATION
16
17
18
22
20
21
232
232
24 22 26 22 28
25 DEFENDANT KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS NOS 1-5
607806 1
' a
metin
VERIFICATION STATE OF CALIFORNIA COUNTY OF LOS ANGELES I have read the foregoing DEFENDANT KUBOTA CORPORATION'S AMENDED
RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS SET NOS 1-5 and know its
contents
am Kunio Suwa Legal Department for KUBOTA CORPORATION a party to this
action entitled Chris Webber A.H. Voss et al LASC Case No. BC 368967 and am authorized
to make this verification for and on its behalf and I make this verification for that reason I am
document informed and believe and on that ground allege that the matters stated in the foregoing .
are true
Executed on November 20 2007 at Osaka Japan _
I declare under the penalty of perjury under the laws of the State of California that the
foregoing is true and conect
26
"
DEFENDANT KUBOTA CORPORATION'S AMENDED PLAINTTO IPLFAINFTI'FFS'S REQUEST FOR NOS ADMISSIONS 1-5
PROOF OF SERVICE
1013a CCP 2
3 STATE OF CALIFORNIA COUNTY OF LOS ANGELES
age 4
I am employed in the County of Los Angeles State of California am over the
of 18
and not a party to the within action my business address is 555 South Flower Street 29th Floor
5
Los Angeles California 90071
6 On November 20 2007 I caused the foregoing document described as DEFENDANT
7 KUBOTA CORPORATION'S AMENDED RESPONSES TO PLAINTIFF'S REQUEST
FOR ADMISSIONS SET NOS 1-5 to be served on the interested parties in this action 8
SEE ATTACHED SERVICE LIST
9
the 10 XX By placing X the true copy [
original thereof enclosed in sealed envelopes
addressed as follows
.
11
XX BY MAIL I caused such envelope fully prepaid to be placed in the United States
12
Mail at Los Angeles California I am readily familiar with the firm's practice of
collection and processing correspondence or mailing Under that practice it would
13
deposited with the U.S. postal service on that same day with postage thereon fully
14 prepaid at Los Angeles California in the ordinary course of business I am aware that on motion of the party served service is presumed invalid if postal cancellation date on
15
postage meter date is more than one day after date of deposit for mailing in affidavit
16 -
17
I BY OVERNIGHT EXPRESS caused said document to be picked
by U.S. Federal Express Services for overnight delivery to the offices of the addressees
listed on the Service List
18
fl
19
20
I BY HAND PERSONAL SERVICE caused said document to be
personally delivered by a attorney service to the addressee as noted on the Service
-
list
FACSIMILE XX BY
I caused said document to be telephonically transmitted to each
21
addressee's telecopier Fax number as noted Said service shall be deemed personal
22
service pursuant to the Court's Trial Setting Order dated 10/24/07
22
I declare under penalty of perjury under the laws of the State of California that the above
is true and correct
24
Executed on November 20 2007 at Los Angeles California
25
26
27
00
562615.1
Karina Ramirez
1 PROOF OF SERVICE
SERVICE LIST Chris Webber v KUBOTA CORPORATION et al
Case No BC368967
Our File No 00495.06826
7
9
1010
12
1214
115 5
16
18 19 20
Jeffrey A. Kaiser Esq
Scott Hendler Esq
Raymond D. Mueller Esq
HendlerLaw
LEVIN SIMES KAISER & GORNICK LLP | 816 Congress Avenue
44 Montgomery Street 36th Floor
Suite 1230
San Francisco California 94104
Austin TX 78701
415 646-7160 Telephone 415 981-1270 Facsimile Attorneys for Plaintiff CHRIS WEBBER
Tel 512 439-3200 Fax 512 439-3201
Attorneys for Plaintiff CHRIS WEBBER
RECORD TRAK
675 South Arroyo Parkway
Suite 320
Pasadena CA 91105 Tel 626 685-2878 Fax (626)685-2877 Email nvento@recordtrak.com Designated Defense Counsel
JoannaMacQueen Esq
JACKSON & WALLACE
Suite
14727 Ventura Boulevard Suite 1210
Sherman Oaks California 91404
Tel 818 379-4700 Fax 818 379-4702 Attorneys for Defendant KAISER GYPSUM
COMPANY INC
Email jmacqueen@jacksonwallace.com
jstepp@jacksonwallace.com
Randall Bernard Esq WILSON ELSER MOSKOWITZ
EDELMAN & DICKER LLP
525 Market Street 17th Floor
San Francisco California 94105 Tel 415 433-0990 Fax 415 434-1370 Attorneys for Defendant A.H. Voss and
Kubota Corporation
22
24 25 26 27 28
562615.1
2 PROOF OF SERVICE
ite
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L VOSS / 1966
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L VOSS /1967
,, " ' " ' " ' Carson KU BOTA ,, ,,
,, / <L' < VOSS L
"L"
L "L L" No.13 - :
1965
/
L >printed warnings
KUBOTA ,, ,, ,, ,, ,, ,, VOS/ S
L No.13 - fl >
1962
L "L"
"
L "NLo".14:
1965
Lfi > printed warnings
KUBOTA ,, ,, ,, ,, ,, ,, / /VOSS
L No.14 - fl :
>
"
L No.15 : -
1966 fi/ L > printed warnings
KUBOTA ,, ,, ,, ,, / / VOSS
L "L" L No.-15 fl fl
L " L"
>
"
L "L" L No.1-6 :
Privileged & Confidential
1967
,, / /
L>p rinted warnings
KUBOTA ,, ,, ,, ,, V/ OSS
L No.16 - fl : >
"
L : No.17 -
1965
KUBOTA ,, ,, ,, ,,
L "LL" - No.17 fl : >
L printed warning materials " "
VOS/ S
"
1962
|
L No.1No.188 : -
1965
L> printed warning materials " KU BOTA fi
,, ,, V /OSS
"
L No.18 No.18 - fl : >
L No.19 : -
1966 L> printed warning materials " KU BOTA fi
,, ,, V/OSS
"
L " L L N- o" .19 :fl
L " L"
L No.20 : -
1967
,, L>printed warning materials " KU BOTA fi
,,
V/OSS ,,
"
L No.20 - fl : >
L " L"
1965
L / fl ,, ,, ,, ,,
"
L No.21 - fl : >
L"
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L No.22 : -
1965
,, L / fl
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,, - " L ,, "L"
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L"
LNo "LL. "2-3:
1966
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No.24 :
1967 L / fl ,, ,, ,, ,,
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L "NoL .25" :
1965
L VO/ SS L' KU BO TA ,, ,,
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1962 ,,
L No.26 : -
1965
,, L VO/ SS L' KU BO TA ,, ,, ,, ,,
L No.26 - fl : >
" "
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" No.2L 7 :"
1966
,, L VO/ SS L' KU BOTA ,, ,, ,, ,, ,,,,
"
L No.27 - fl
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1967
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Privileged & Confidential
1965
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L "NLo." 30 :
1965 L /fl
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L L -No.30 - fl :
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1966 L / VflOSS fl ,, ,, ,, ,, -L">
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1967 L /fl
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L L" LL-"No- .33 :
1965
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1965
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L No.34 - fl :
ana
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1967
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1965
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1966 L /fl KULB OT A ,, ,, ,, ,, /
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1965
KUBOTA ,, ,, ,, ,, / T OKYO
10
Privileged & Confidential
KOGYO BOEKI SHOKAI
L ,, L No.41 - fl : >
L"
MANVI LLE fi ,, ,,,,
L > ,, L " "L "
>
L No.42 : -
1965
,, KU BOTA ,, ,, ,, ,, / TO KYO
KOGYO BOEKI SHOKAI L / MANVILLE ,, ,,,, ,,,,
L ,, ,, ,, "
L No.42 - fl : >
>
L No.43 : -
1966
,, KU BOTA ,, ,, ,, ,, / TO KYO
KOGYO BOEKI SHOKAI L MANVILLE/ fi ,, ,, ,, L ,, ,, ,, L > " L No.43 - fl : >
L"
>
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1967 KU BOTA ,, ,,
,, ,,
/ TO KYO
KOGYO BOEKI SHOKAI L / MANVILLE fi ,, ,, ,,
,, ,, ,, ,,
"
L "L L" No.44 - fl : >
L"
>
1965
VOSS Voss
, , L, L fiL K ubota
, L
KUBOT... A ,, ,, ,,fl ,,
"
L " No.L 45 " fl
> ,, /
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1965
,, VOS S Voss
, L > fi Kubota
L ... fl KU...B OTAfl ,, ,, ,, ,,
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2007 ,,11 20
WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP By Howard Halm
Aide Ontiveros
Attorneys for Defendant
KUBOTA CORPORATION
19
Privileged & Confidential
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