Document QMMKwzoy19Xw4759v831OKbmL
FILE NAME: Shell (SHEL)
DATE: 0000
DOC#: SHEL001
DOCUMENT DESCRIPTION: Excerpt - Defendant's Response to Interrogatories
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1 SEDGWICK, DETERT, MORAN & ARNOLD STEPHEN JONES (Bar No. 040884)
2 SERRIDGE R. MARSH (Bar No. 077304) HOLLY A. HARRIS (Bar No. 132336)
3 One Embarcadero Center, 16th Floor San Francisco, California 94111-3765
4 Telephone: (415) 781-7900
5 Attorneys for Defendant SHELL OIL COMPANY
6
7
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
10
11 IN RE: COMPLEX ASBESTOS LITIGATION
) NO. 828684 )
12
) RESPONSE OF DEFENDANT SHELL OIL
) COMPANY TO PLAINTIFFS' STANDARD
13
) ASBESTOS CASE INTERROGATORIES TO
) ALL DEFENDANTS
14 -- ..... ... ................. _)
15
16 PROPOUNDING PARTY:
PLAINTIFFS
17 RESPONDING PARTY:
SHELL OIL COMPANY
18 SET NUMBER:
GENERAL ORDER 129
19
Defendant SHELL OIL COMPANY (hereinafter 11Shell")
20 provides the following objections and responses to San Francisco
21 Superior Court General Order No. 129 Plaintiffs' Standard
22 Interrogatories to All Defendants as follows
23
24
25
26
27 sYcc wiciT
C T g K T . MQttAUK Q & A K M Q L 0 ___
ine 'EnktitiM lrtv Cerner Sixteenth Floor
** F n n c i t t t , C alifornia 9*111-3765
Tel. 4 lS .7 8 1 .7 9 0 0
PRELIMINARY STATEMENT Defendant's responses are based upon as diligent and complete an inquiry as possible as of this date and are subject to corrections for errors, mistakes or omissions. Defendant anticipates that additional discovery, investigation, and analysis may supply additional facts, add meaning to known facts,
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INTERROGATORY NO, 2 :
State the date of first employment with YOU, and the
dates and titles of each job position the person verifying these
interrogatories has held while employed by YOU.
RESPONSE TO INTERROGATORY NO. 2 :
6
Ms. Johnson has been employed at the Martinez facility
7 since 1962. Her current job title is Senior Office Assistant,
8 Human Resources, Legal Support.
9 INTERROGATORY NO. 3 :
10
11 state:
State whether or not YOU are a corporation, and if so,
12
A. YOUR correct corporate name;
13
B. YOUR state of incorporation;
14
C. The date of YOUR incorporation;
15
D. The address of YOUR principal place of business;
16
E. Whether or not YOU have ever held a certificate of
17 authority to do business in the State of California, and if so,
-18 the inclusive dates of any certificate,-
19
R If YOU are wholly owned or the majority interest of
20 YOUR company is owned by another business entity, state the
21 entity's name and principal place of business;
22
G. Whether YOU have any business offices in
23 California, and, if so, YOUR principal place of business in
24 California.
25 RESPONSE TO INTERROGATORY N O . 3 .
26
Yes.
27
A. Shell oil Company.
B. Delaware.
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1
C. September 30, 1949 ;
2
D.
3 Texas 77002.
One Shell Plaza, 910 Louisiana Street, Houston,
4
E. Shell has been certified to do business in the
5 State of California continuously since September 30, 1 9 4 9 .
6
F. SPNV Holdings, Inc., a Delaware corporation.
7
G. Shell does not maintain a principal business office
$ m California. its address for service of process is CT
9 Corporation System, 818 West Seventh Street, Los Angeles,
10 California 90017.
11 INTERROGATORY T40 A
12
Have YOU ever been identified, known, or done business
13 under any other name in the state of California?
14 SggPQNSE TO INTER ROGATORY Tvrn a
15
Yes.
16 INTERROGATORY Mn s .
17 If your answer to Interrogatory No. 4 is in the
.18 affirmative, please state such name or names and the time period
19 during which THIS d e f e n d a n t was so known or identified. 20 BfiSPQNSE TO i n t e r r o g a t o r y NO. tj.
21
Shell Company of Californi. U911 to ls22) . SJm11 ^
22
011 Corp" * n < " 23 1949) .
i,,,,,
Shell oil Company. lno. (1939 to -----
24 INTERROGATORY NQ c
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27 _r Scoc Wic It.
EmbarcedtM Cdtu? Floor
Cvliforaia *4111-37*5 TftL 4 1 5 .7 f t ,7 999
etc.) . ///
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If YOU are not a corporation, what is YOUR business (partnership, joint venture, sole proprietorship,
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L. No.
M. No.
N. NO.
O. Yes .
k l.3 .
P . No .
Q- N o . R. No.
S . No .
T. No.
10
u. No.
12
V. Shell
12 various business groups and associations, but Shell is unable to 13 identify at this time all of the groups and associations that may 14 be relevant to this Interrogatory.
15
(w) Unknown. Shell is aware that certain of its
16 personnel attended conferences and meetings of various
17 organizations in an attempt to learn of potential hazards in the
18 workplace, including its former Industrial Hygienist, Howard
19 Kusnetz, who attended American Petroleum Institute meetings.
20 INTERROGATORY NO. 14-
21
For each organization, association or other entity
22 identified in y o u r Response to Interrogatory No. 1 3 , please
23 state:
24
A. The dates during which THIS DEFENDANT was a member;
25
B. The name(s) of any publication(s) received by THIS
26 DEFENDANT from such association or organization;
27 > / /
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C.
The name of any committee or subcommittee of w
THIS DEFENDANT was a member, and the dates of such committee or
subcommittee membership.
RESPONSE TO INTERROGATORY NO. 14:
A. American Petroleum Institute - approximately 1949 (the limit of API's records) to present.
National Safety Council - December 1943 to present. Industrial Hygiene Foundation - approximately 1972 to approximately 1977.
The dates of Shell's memberships in other organizations
listed in response to Interrogatory No. 13 are presently unknown.
B. Shell is currently unaware of the title (s) of any
publications it may have received from the organizations listed
m its response to Interrogatory No. 13. The records of those 23.tions rrisy co.nfc3.i.n fcliJLs info3rrn3.txozi,
C. Shell has been a member of the American Petroleum 17 [nstitute's Medical Advisory Committee since approximately 1972 18 (the limit of Shell's records). Membership in other committees 19 md/or subcommittees is unknown at this time. 2 0 INTERROGATORY NO . 16
21
Had THIS DEFENDANT prior to 1973 received any DOCUMENTS
22 containing results or conclusions of any studies and/or tests
23 inducted by Bonsib for Standard Oil of New Jersey relating to
24 sbestos exposure in the workplace or the human health
25 onsequences of exposure to asbestos? if so:
26
A. Either (i) attach all DOCUMENTS evidencing the
2 7 nformation sought in this Interrogatory and its subparts to your
428 nswers to these Interrogatories, or (2) attach disks containing
*r
it
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