Document NekDn8K36QE7YKrgKDQN07OoD

FILE NAME: WR Grace (WRG) DATE: September 1994 DOC#: WRG011 DOCUMENT DESCRIPTION: 1994 Legal - WR Grace answers and objections to interrogatories DISTRICT COURT, BOULDER COUNTY, COLORADO C ivil A ction No. 89 CV 2000 W .R . G RA CE & C O .--CO N N .'S ANSW ERS AND O BJECTIO N S T O PLA IN TIFF'S IN TERRO G A TO RIES AND REQ U ESTS FOR PRODUCTION O F DOCUM ENTS IN RE ASBESTOS CASES- BOULDER GENERAL OBJECTIONS W .R. Grace & C o .-C o n n ., form erly known as W .R. Grace & C o., ("Grace"), incorporates by reference its General Objections to its Amended Answers and Objections to P la in tiffs First Set o f Interrogatories and Request for Production o f Documents as if set forth in full herein. RESPONSES TO INTERROGATORIES 1. Please state the name, address and position o f employment o f the person signing responses to these discovery requests. RESPO N SE: John V. Port, C ontroller, LSG, W .R. Grace & C o.--C onn., One Town Center Road, Boca Raton, FL 33486. 2. Does the person identified in the response to Interrogatory No. 1, above, have personal knowledge o f any o f the inform ation supplied in response to these discovery requests? I f so, identify the inform ation o f w hich that person has personal knowledge. RESPONSE: No. 3. A m bros? D id W .R. Grace (as defined herein) ever have an employee named Otto RESPONSE: Grace objects to this interrogatory on the grounds that it is overly broad, unduly burdensom e, irrelevant, immaterial and not reasonably calculated to lead to the discovery o f adm issible evidence. Subject to this objection and the General Objections interposed above, Grace states that it has never had an employee named D r. Otto Ambros. 4. If the answer to Interrogatory No. 3 is affirm ative, state the following: a. The date that O tto Ambros was first employed by W .R . Grace. b. The date that O tto Ambros was last employed by W .R . Grace. c. Each job title o r position o f em ploym ent that Otto Am bros had w hile an em ployee o f W .R. Grace. d. The duties and responsibilities o f O tto Ambros during the tim e o f his em ploym ent with W .R . Grace. G race. e. The last known address o f O tto Am bros while an employee o f W .R. f. A fter the last date o f employment o f Otto Ambros by W .R. G race, did he receive a pension or other m onetary paym ent o r benefit on account o f his employment with W .R . Grace? g. If the answer to Interrogatory No. 4 .f. is affirm ative please state the address to which all such pension or other paym ents o r benefits were sent. RESPO N SE: Not applicable. 5. Did W .R. Grace ever pay Otto Ambros for consulting services, apart from any tim e that Otto Ambros was an employee o f W .R. Grace? RESPO N SE: Grace objects to this interrogatory on the grounds that it is overly broad, unduly burdensom e, irrelevant, im m aterial and not reasonably calculated to lead to the discovery o f adm issible evidence. Subject to this objection and the General Objections interposed above, G race states it did pay D r. Ambros for certain consulting services. 6. If the answer to Interrogatory No. 5 is affirm ative state the following: a. consultant. The date that O tto Ambros was first hired by W .R . Grace as a b. The date that Otto Ambros was last hired by W .R . Grace. - 2- c. Each job title or position o f employment that O tto Ambros had while an employee o f W .R. Grace. d. A description o f the duties and responsibilities o f O tto Ambros each time he was hired as a consultant by W .R. Grace. e. consultant. The last known address o f Otto Ambros when hired by W. R. Grace as a RESPONSE: Grace objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant, immaterial and not reasonably calculated to lead to the discovery o f admissible evidence. Subject to this objection and the General Objections interposed above, G race states the following: a. 1951; b. Upon inform ation and belief, D r. Ambros continued to provide services to Grace until his death in 1990; c. Dr. Ambros was never an employee o f G race, and was always referred to as a consultant; d. D r. Ambros provided general consulting services, prim arily in the field o f organic chem istry, as requested by Grace; e. D r. A m bros' address at the tim e o f his death was Kneibisstrasse 14, 6800 M annheim, Germany. 7. Did O tto Ambros ever own any stock o f W .R. Grace? RESPONSE: Grace objects to this interrogatory on the grounds that it is overly broad, unduly burdensom e, irrelevant, im material and not reasonably calculated to lead to the discovery o f admissible evidence. Subject to this objection and the General Objections interposed above, G race states that it has no record o f D r. Ambros ever being a Grace shareholder. 8. The nam e, address and position o f employment or job tid e o f the person who is the custodian o f Otto Ambros' com plete and unexpurgated W .R. G race employment or personnel file. - 3- R ESPO N SE: Grace objects to this interrogatory on the grounds that it is overly broad, unduly burdensom e, irrelevant, im m aterial and not reasonably calculated to lead to the discovery o f adm issible evidence. Subject to this objection and the General Objections interposed above, G race states that it has no payroll, employment o r personnel file on D r. A m bros. 9. The nam e, address and position o f employment or jo b title o f the person who is the custodian o f W .R . Grace payroll department, finance departm ent and o r W .R. Grace personnel departm ent records concerning Otto Ambros. RESPO N SE: See response to Interrogatory No. 8, above. REQUESTS FO R PRODUCTION O F DOCUM ENTS 1. Copies o f Otto Ambros' complete and unexpurgated employment or personnel file from W .R. G race. R ESPO N SE: Grace objects to this request on the grounds that it is overly broad, unduly burdensome, irrelevant, im m aterial and not reasonably calculated to lead to the discovery o f adm issible evidence. Subject to this objection and the General Objections interposed above, G race states that it has no such files. 2. Copies o f W .R. Grace payroll departm ent, finance departm ent and o r W .R. G race personnel departm ent records concerning O tto Ambros. R ESPO N SE: See answer to Response No. 1, above. DATED this MRMM2689.1 day o f Septem ber, 1994. PENDLETON & SABIAN, P .C . /7j Z7 By;--Alati'Cl Friedberg (6042) /O a n f M . Clexton (17419) Attorneys for Defendant W .R. Grace & Co.- ^Conn. 303 East 17th Avenue, Suite 1000 D enver, Colorado 80203 Telephone: (303)839-1204 Telefax: (303) 831-0786 - 5- TDTflL P .06