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AOC*T A. IUNDA
Fuller & Henry
>200 CDiSON PLAZA
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TOLEDO OHIO 43fiQ3
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April 17, 1986
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Harold J. Fast, Esq. Senior Corporate Counsel
and Assistant Secretary The BFGoodrich Company Chemical Division 6100 Oak Tree Boulevard Cleveland, Ohio 44131 .
Lawrence D. Lenihan, Esq. Uniroyal, Inc. World Headquarters Middlebury, Connecticut
06749
Ronald Sandburg, Esq. Legal Department Conoco, Inc. P,p.. Box 2197 Houston, Texas 77252
James Rigrish, Esq. The Goodyear Tire and.
Rubber Company 1144 East Market Street Akron, Ohio 44305
John Endicott, Esq. Diamond Shamrock Chemicals Company 1351 Philips Court Irving, Texas 75015-2300
Robert M. Walter, Esq. Firestone Tire i Rubber Company 1200 Firestone Parkway Akron, Ohio 44310
Peter F. Davey, Esq. Law Department E-3 Union Carbide Corporation Old Ridgebury Road,
Sec. C-2 Danbury, Connecticut
06817
Robert D. Luss, Esq. Occidental Chemical Corporation Arm and Hammer Boulevard P.0. Box 699 Fottstown, PA 19464
Richard J. Lorenz, Esq. Tenneco Oil Company Tenneco Building P.O. Box 2511 Houston, Texas 77001
Res Herman A. Dendinger, et al. v. Chrysler Plastic Products Corporation, et al.;
Etta Wallace v. Chrysler Plastic Products Corporation, et al.
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045724
Fuller & Henry
TOLEDO, OHIO
Counselors:
I'm enclosing a copy of- interrogatories to the PVC manufacturers and requests for the production of documents directed to the PVC manufacturers in both the Dendinger and
Wallace cases.
Please review these enclosed pleadings and provide me
with the information required to respond to these discovery
requests. The requests were hand delivered by plaintiffs'
counsel at the pretrial of these cases on April 14, 1986. The
responses are due on or before May 14. .
,
Robert A. Bunda
RAB/mh
enclosure
3861-1
cc: Mr. Nelson R. Goodrich (#875ERB201697H; I875ERB201703A Mr. R. E. Wildey (#555 QN 115219-2; #555 QN 115218-2)
Mr. Prentice Hapgood (#048 L 72468; #048 KL 72467)
Ms. Pamela E. Thornton
Ms. Coyette Holley
Mr. J. Fred Turner
Louis E. Tosi, Esq.
Mr. Fred Conner
Mr. Lane King
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045725
.' | KJDB:sg 04/14/86
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION
ETTA WALLACE, personal representative of the Estate of Fred A. Wallace, et al..
Plaintiffs
INTERROGATORIES DIRECTED TO
All defendant PVC~HAnuTKCTDrers
CHRYSLER PLASTIC PRODUCTS CORPORATION, et al..
Defendants.
Case No.: C84-7864 Judge Nicholas J. Walinski
propound the following interrogatories to be answered in writing and under oath by each defendant PVC Manufacturer, within thirty (30) of the date of service. It is understood that these interrogatories shall be of a continuing nature and must be supplemented as soon as new or additional information is available.
INTERROGATORY NO. It Are you a manufacturer of polyvinyl chloride (PVC) resin?
ANSWER:
4ummay S Hum may
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PVC resin?
INTERROGATORY NO. 2: When did you first begin manufacturing ANSWER:
INTERROGATORY NO. 3: Have you manufactured PVC resin
continuously since the date.indicated, in your answer to interrogatory, number
2?
'' ' " ' ' - /
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ANSWER:
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INTERROGATORY NO. 4: Indicate the percentage of all PVC resin manufactured by you in calendar year 1967 that was the result of the following processes: (a) suspension; (b) emulsion; (c) bulk; or, (d) solution.
ANSWER:
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INTERROGATORY NO. 5: Indicate the extent to which the
percentages of your total PVC resin output attributed to any of the four processes identified in the prior interrogatory have changed since calendar
year 1967, by indicating the specific changes made and dates of all such
changes.
ANSWER:
INTERROGATORY NO. 6: Did you sell any PVC. resin to Chrysler during calendar year (a) 1967; (b) 1968; (c) 1969; (d) 1970; {e) 1971; (f)
1971; (g) 1972; (h) 1973; (i) 1974; (j) 1975; (k) 1976; (1) 1977; (m) 1978;
(n) 1979; and, (o) 1980.
rt AMSWER:
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(b)
(c)
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(h)
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(k) (l)
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INTERROGATORY NO. 7: If your answer to the preced ing
interrogatory Is, in any part, yes," Indicate the total volume of PVC sold to Chrysler during every year that you sold PVC resin to Chrysler.
ANSWER:
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INTERROGATORY HO. 8: For every calendar year between 1967 and 1980, inclusive, that you sold PVC resin to Chrysler, Indicate the percentage of such resin which was manufactured by the following processes: (a) suspension; (b) emulsion; (c) bulk; and, (d) solution.
ANSWER:
MuftMAY C Mukmay eev*> a * Hoiinokt4 4aCt*T|o><
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INTERROGATORY NO. 9: Did you at any time conduct any testing to determine the concentration of vinyl chloride monomer contained in your PVC resin at any time following manufacturing?
ANSWER:
INTERROGATORY NO. 10: If your answer to the preceding,
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interrogatory Is "yes," indicate: (a) what testing was done; (b) when such
testing was done; (c) who conducted the testing; and, (d) what the results
were.
ANSWER:
INTERROGATORY NO. 11: For every calendar year in which you sold PVC resin to Chrysler, Indicate what percentage of the PVC resin sold was: (a) homopolymer; (b) copolymer; or, (c) terpolymer.
ANSWER:
LIRMAV & MUftWAV CO ,L A A
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INTERROGATORY NO. 12: With respect to every sale of PVC resin from you to Chrysler, indicate the date on which such resin was manufactured and the date on which such resin was shipped to Chrysler.
ANSWER:
INTERROGATORY NO. 13: Did you. at any time, notify Chrysler
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of any studies indicating that vinyl chloride monomer was: (a) hazardous to
human health or (b) that vinyl chloride monomer was a suspected carcinogen?
ANSWER:
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INTERROGATORY NO. 14: If your answer to the prior interrogatory is "yes,* state in full, the date and substance of every such notification to Chrysler.
ANSWER:
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INTERROGATORY NO. 15: When did you first become aware of any study indicating that vinyl chloride monomer was a suspected carcinogen; or, (b) hazardous to human health?
ANSWER:
-I-N--T-E--R--R-O--G---A-T--O--R--Y- NO1 .1 16: What steps were taken by you prior ti o, t
or during the course of, your sales of PVC resin to Chrysler to determine the
concentration of residual vinyl chloride monomer in said resin.
AMSWER:
INTERROGATORY NO. 17: What steps were taken by you prior to, or during the course of, your sales of PVC resin to Chrysler, to determine whether any component of that resin was an actual or potential carcinogen?
ANSWER:
4UMRAY C MuttWAY M IM
-7-
INTERROGATORY NO. IS: Did Chrysler, at any time, ever ask you whether you were aware of any studies Indicating that exposure or overexposure to vinyl chloride monomer posed any actual or potential human
health hazard? ANSWER:
INTERROGATORY NO. 19: Describe the steps taken by you
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subsequent to January, 1967 to reduce the concentration of residual virfyl
chloride monomer in PVC resin manufactured by you.
ANSWER:
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INTERROGATORY HO. 20: State the full name, home address and business address of your employee who Is most knowledgeable concerning the residual concentrations of vinyl chloride monomers In the PVC resins manufactured by you between January 1, 1967 and December 31, 1980.
ANSWER:
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Kirk J. Delii Bovi HURRAY & HURRAY CO., L.P.A. 300 Central Avenue Sandusky, Ohio 44870 Telephone: (419) 627-9700 Attorneys for Plaintiffs
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