Document QgmVMV5aBXQ9xo82EzZ4Rn6GE

PLAINTIFFS EXHIBIT CHR-11* IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: 95-10261 CA 42 TIMOTHY TINKER and ANN TINKER, his wife. Plaintiffs, -vsCHRYSLER CORPORATION, BEAVER DAM PRODUCTS CORPORATION formerly known as Chrysler Marine Corporation, et. al. CHRYSLER CORPORATION'S RESPONSES TO PLAINTIFF'S FIRST REQUEST TO PRODUCE Defendant, CHRYSLER CORPORATION, through undersigned counsel hereby files its responses to Plaintiffs' Request for Production as follows: 1. To the extent this request calls for the production of all documents related to the subject matter of this lawsuit, Chrysler Corporation objects on the grounds that this request is unduly burdensome, overly broad and lacks particularity. 2. Chrysler Corporation objects to this request on the grounds of lack of relevance, and because it is unduly burdensome, overly broad, lacks particularity and is premature. 3. Chrysler Corporation objects to this request on the grounds of lack of relevance, and because it is unduly burdensome, overly broad, and is premature. Case No.: 95-10261 CA 42 Tinker v. Chrysler Corp., et. al. 4. Chrysler Corporation objects to this request on the grounds that it is unduly burdensome, overly broad and makes improper assumptions. 5. Chrysler Corporation objects to this request on grounds of lack of relevance, and because it is unduly burdensome, overly broad, makes improper assumptions, and is premature. 6. Chrysler Corporation objects to this request on grounds of lack of relevance, and because it is unduly burdensome, overly broad, lacks particularity and is premature. 7. Chrysler Corporation objects to this request on grounds of lack of relevance, and because it is unduly burdensome, overly broad, lacks particularity and is premature. 8. Chrysler Corporation objects to this request because of lack of relevance and because it is unduly burdensome, overly broad, lacks particularity, contains improper assumptions and is premature. 9. Chrysler Corporation objects to this request on the grounds of lack of relevance, and because it is unduly burdensome, overly broad, lacks particularity and is premature. 10. Chrysler Corporation objects to this request on the grounds that it is unduly burdensome, overly broad, contains improper assumptions and lacks particularity. 2 Case No.: 95-10261 CA 42 Tinker v. Chrysler Corp., et. al. 11. Chrysler Corporation objects to this request on the grounds that it is unduly burdensome, overly broad, lacks particularity and may call for the production of the privileged information. 12. Chrysler Corporation objects to this request because of lack of relevance and because it is unduly burdensome, overly broad, lacks particularity, contains improper assumptions and is premature. 13. Chrysler Corporation objects to this request on grounds of lack of relevance, and because the request is unduly burdensome, overly broad, lacks particularity and may call for the production of privileged information. 14. Chrysler Corporation objects to this request on grounds that it is unduly burdensome, overly broad, lacks particularity and makes improper assumptions. 15. Chrysler Corporation objects to this request on the grounds that it is unduly burdensome, overly broad, lacks particularity and makes improper assumption. 16. Chrysler Corporation objects to this request on grounds of lack of relevance and because the request is unduly burdensome, overly broad, lacks particularity and makes improper assumptions. 17. Chrysler Corporation objects to this request on grounds of lack of relevance and because the request is unduly burdensome, overly broad, lacks particularity and is premature. 3 Case No.: 95-10261 CA 42 Tinker v. Chrysler Corp., et. al. 18. Chrysler Corporation objects to this request on grounds of lack of relevance and because the request is unduly burdensome, overly broad, lacks particularity and is premature. 19. Chrysler Corporation objects to this request on grounds of lack of relevance and because it is unduly burdensome, overly broad, lacks particularity and is premature. 20. Chrysler Corporations to this request on grounds of lack of relevance and because it is unduly burdensome, overly broad, lacks particularity and is premature. 21. Chrysler Corporation objects to this request on grounds of lack of relevance and because it is unduly burdensome, overly broad, lacks particularity and is premature. 22. Chrysler Corporation objects to this request on grounds of lack of relevance, and because it is unduly burdensome, overly broad, lacks particularity, makes improper assumptions, may call for the production of privileged information and is premature. 23. Chrysler Corporation objects to this request on grounds that it is unintelligible. To the extent request number 23 requests the creation of a document, such request is beyond the parameters of Florida Rule of Civil Procedure 1.350. Chrysler Corporation also objects to this request to the extent it calls for the creation of a privileged log on grounds that it is unduly burdensome, overly broad and premature at this stage of the discovery process. 4 Case No.: 95-10261 CA 42 Tinker v. Chrysler Corp., et. al. 24. Chrysler Corporation objects to this request on the grounds that it is unduly burdensome, overly broad, lacks particularity and may call for the production of privileged information. HERZFELD & RUBIN Suite 400 1901 W. Cypress Creek Road Fort Lauderdale, Florida 33309 (305) 772-3599 Attorneys for Chrysler Corporation and Beaver Dam Products Corporation 5 Case No.: 95-10261 CA 42 Tinker v. Chrysler Corp., et. al. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was this C* ~~~ day of October, 1 995, delivered to DAVID LIPMAN, ESQUIRE, Counsel for Plaintiffs, 5901 S.W. 74th Street, Suite 304, Miami, Florida. HERZFELD & RUBIN Suite 400 1901 W. Cypress Creek Road Fort Lauderdale, Florida 33309 (305) 772-3599 Attorneys for Chrysler Corp. and Beaver Dam Products Corp. /ID I. WEISS 'Bar No. 656976 6 PRELIMINARY INTERROGATORIES 1. Data Sources Please identify each person with whom you consulted or who provided information used in answering these Interrogatories on behalf of Defendant. Additionally, provide the subject matter category that each person provided information for from the following categories if appropriate: 1. Corporate History 2. Product Information 3. Warnings/Knowledge of Potential Danger/State of the Art/Testing/Medical or Scientific Identify each person's: A. Address; B. Position with the Defendant; Answer: The responses to these interrogatories are provided with assistance of counsel for Chrysler Corporation. Mr. Kelly's position with Chrysler Corporation is Parts Marketing Manager. Mr. Kelly is available through Herzfeld & Rubin, 801 Bricked Avenue, Suite 1501, Miami, Florida 33131. 2. Corporate Information Please state the following: A. This defendant's correct corporate name; Answer: Chrysler Corporation B. The state of your incorporation; Answer: Delaware C. The address of your principal place of business; Answer: 12000 Chrysler Drive Highland Park, Michigan 48288 ` D. The dates and time period during which defendant held a certificate of authority to do business in the state of Florida; Answer: Objection, overbroad without relation to the facts set forth in the Complaint. E. The dates and time period during which defendant regularly conducted business in Florida. Answer: Objection, overbroad without relation to the facts set forth in the Complaint. 3. Corporate History Describe in detail Defendant's complete corporate or business history for all associated business entities that were involved, in any manner, in the sale, manufacture, distribution, and/or mining of asbestos and/or asbestos containing products, including dates of incorporation, mergers, consolidations, reincorporations, and the like. Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs for all associated business entities that were involved, in any manner, in the sale, manufacture, distribution, and/or mining of asbestos and/or asbestos containing products. In addition: A. If defendant or any of its predecessors or subsidiaries at any time purchased or assumed any of the assets and/or liabilities of any corporation or entity which at any prior time engaged in the manufacturing or sale of asbestos-containing products, then please state the following as to each acquisition: Answer: 1. The name or description of each corporation, entity or assets acquired by Defendant, that entity's state of incorporation and principal place of business, its date of incorporation, and the name of Defendant at the time of acquisition; 2. The manner by which each such corporation, entity or interest therein, was acquired (e.g., merger consolidation, change of name, stock sale, transfer or purchase of assets or product line); 3. The date of each such acquisition; 4. The state in which each such acquisition was effected; 5. The state law governing each such acquisition if specified by contract and 6. How the business or financial interest in that corporation or entity ended, if it ended, (e.g. dissolved the company, sold all stock, placed subsidiary in bankruptcy, etc.) 7. List all states where entity is or was registered to do business, including the dates of registration for each state. Chrysler objects to this Interrogatory on the grounds that it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objection, Chrysler states that the current legal name under which it does business is Chrysler Corporation. Chrysler Corporation was incorporated on June 6, 1925. Chrysler Corporation is authorized to do business in every state of the United States. Chrysler Corporation has had many subsidiary corporations since 1925, none of which would have any bearing to this litigation. 4. Asbestos Mining Did Defendant, prior to 1980, engage in the mining, milling and/or subsequent sale of asbestos fiber? If so, please state? Answer: No. A. The date such activity began; Not applicable. B. The years during which such activity took place; Not applicable. C. If such activity was terminated; Not applicable. D. If such activity was terminated, the reason why; Not applicable. E. Within in the United States was there any geographic limitation which you claim was applicable to the sales of your asbestos (Yes or No)? Not applicable. F. Identify the organizational unit of Defendant so engaged. Not applicable. G. Type of asbestos mined. Not applicable. H. Managers of each mine and years of service. Not applicable. I. Identify sales and shipment records from each mine. Not applicable. 5. Asbestos/Manufacture Has Defendant at any time, engaged in the manufacture of any asbestos containing product which generic product type has been previously identified in exposure sheets in this circuit? If so, please state: A. The date such activity began; Answer: Objection. This question is unduly burdensome, vague and overbroad and harassing and is not likely to lead to admissible evidence. Notwithstanding this objection, Chrysler understands brake linings and clutch facings have contained asbestos. From 1959 to 1988 Chrysler Corporation manufactured brake linings at a Chrysler plant in addition to purchasing brake linings from other suppliers. Chrysler never manufactured clutch facings. B. The years during which such activity took place; Answer: See response to Interrogatory 5(a) above. Answer: C. If such activity was terminated; See response to Interrogatory 5(a) above. Answer: D. If such activity was terminated, the reason why; Chrysler discontinued manufacture of brake linings in 1988 for economic reasons and shut down a plant based upon a reduction of the work force and expenses. E. Within in the United States was there any geographic limitation which you claim was applicable to the sales of your asbestos (Yes or No)? Answer: Not applicable. Chrysler did not sell asbestos If Yes state the geographical area into which you claim your asbestos containing products were sold; and F. Identify the organizational unit of Defendant so engaged. Answer: Not applicable. Chrysler did not sell asbestos. 6. Asbestos/Sales Has Defendant at any time, engaged in the marketing and/or sale of any asbestos containing product which generic product type has been previously identified in exposure sheets in this circuit? If so, please state: A. The date such activity began; Answer: See response to Interrogatory 5(a) above. B. The years during which such activity took place; Answer: See response to Interrogatory 5(a) above. Answer: C. If such activity was terminated; See response to Interrogatory 5(a) above. Answer: D. If such activity was terminated, the reason why; See response to Interrogatory 5(a) above. E. Within in the United States was there any geographic limitation which you claim was applicable to the sales of your asbestos (Yes or No)? Answer: See response to Interrogatory 5(a) above. F. Identify the organizational unit of Defendant so engaged. Answer: See response to interrogatory 5(a) above. G. Identify all sales managers and the years during which they served. Answer: See response to Interrogatory 5(a) above. 7. Asbestos/Distributor Has Defendant at any time, engaged in the marketing and/or sale of any asbestos containing product, which generic product type has been previously identified in exposure sheets in this circuit, manufactured in whole or in part by an unrelated business entity? If so, please state: A. The name and address of the unrelated business entity; Answer: See response to Interrogatory 5(a) above. B. The product's trade and/or brand name; Answer: See response to Interrogatory 5(a) above. C. The years during which such activity took place; Answer: See response to Interrogatory 5(a) above. D. Identify the organizational unit of Defendant, or the associated business entity so engaged. Answer: See response to Interrogatory 5(a) above. E. Within the United States was there any geographic limitation which you claim was applicable to each distributor and/or wholesaler (Yes or No)? Answer: If Yes state the geographical area which you claim was applicable to each distributor and/or wholesaler; and See response to Interrogatory 5(a) above. F. Whether there was a written distributorship agreement;. Answer: See response to Interrogatory 5(a) above. G. Whether distributorship was exclusive; Answer: See response to Interrogatory 5(a) above. H. Identify all documents pertaining to the distributor or wholesaler relationship and the custodian thereof; Answer: See response to Interrogatory 5(a) above. Answer: The ratio of sales to distributors compared to direct sales to consumers. See response to Interrogatory 5(a) above. J. List of sales records or shipments to each distributor or wholesaler. Answer: See response to Interrogatory 5(a) above. 8. Has Defendant at any time, engaged in the rebranding of asbestos containing products, which generic product type has been previously identified in exposure sheets in this circuit, manufactured in whole or in part by an unrelated business entity? If so, please state: A. The name and address of the unrelated business entity; B. The product's original trade and/or brand name; C. Who performed the physical rebranding and where it was accomplished; D. The years during which such activity took place; E. Brand name and/or trade name after the product was rebranded; F. User or seller of the product after rebranding; G. Identify the organizational unit of Defendant so engaged. Answer: Objection to the Interrogatory as vague, overbroad and without reference to the allegations in the Complaint against Chrysler Corporation Without waiving this objection, this Defendant answers as follows: Products which were manufactured by entities other than Chrysler including brake linings and clutch facing were incorporated into Chrysler vehicles. Additionally, certain parts manufactured by entities other than Chrysler, would be packaged in after-market packages for sale to authorized dealers. 9. Asbestos/Sales to Manufacturer Has Oefendant at any time, engaged in the sale of asbestos containing products, which generic type has been previously identified in exposure sheets in this circuit, to an unrelated business entity that was engaged in the manufacture of asbestos containing products? If so, please state: A. The name and address of the unrelated business entity; B. The product's trade and/or brand name that was sold; C. The years during which such activity took place; D. Identify the organizational unit of Defendant so engaged. E. List each sales office of your asbestos-containing products and for each please state: (1) Name and address; (2) Geographical areas for which each sales office was responsible; (3) Identify all managers and the years during which they served; (4) Identify all sales personnel and the years during which they served, and describe each person's sales jurisdiction or responsibility; (5) Identify sales records or shipment records for each sales office and the custodian thereof. Answer: Objection, overbroad burdensome and harassing. Additionally, this Interrogatory requires Chrysler Corporation to engage in a massive review of each asbestos litigation file ever initiated in the 11th Judicial Circuit, Dade County, Florida. 10. Asbestos/Sales to Government or Government Agencies Did this Defendant ever sell or cause to be sold any of its asbestos containing products, identified on exposure sheets filed in this circuit, to (1) the United States Government; (2) the United States Air Force; (3) Army Air Force; (4) United States Army; (5) United States Navy; (6) United States Marine Corps; (7) General Service Administration; (8) Department of Defense; or (9) or any other agency operated by the United States Government? If so, please provide the following: A. The names and last known address of the governmental agency; B. Whether there was a written contract or sales agreement; C. Identify all documents pertaining to the governmental contracts or agreements and custodian of said documents; D. Whether the formula used for the manufacture of the product was the same as the formula used for the manufacture, sale or distribution of the product to non-governmental customers; E. The extent to which sales to governmental agencies were handled through distributors or wholesalers as opposed to direct sales by Defendant; F. The extent to which the physical appearance of the product sold or distributed to a governmental agency differed from the physical appearance of the product sold or distributed to non-governmental customers; G. The extent to which the packaging and/or labeling of the product sold or distributed to a governmental agency differed from the packaging or labeling of the product sold or distributed to non governmental customers; H. Identify Sales and shipment records for each governmental agency and the custodian thereof. Answer: Objection, overbroad without reference to allegations in Plaintiff's Complaint where Plaintiff fails to allege facts indicating Timothy Tinker ever served in the military. 11. Asbestos/Sales Through Licensees If any of this Defendant's asbestos-containing products which generic product type has been previously identified in exposure sheets in this circuit, reached the consumer through licensees, please provide the following: A. The name and last known address of licensees; B. The years each licensee was licensed to sell, distribute or manufacture this Defendant's asbestos-containing products; C. Within the United States was there any geographic limitation which you claim was applicable to each licensee (Yes or No)? If Yes state the geographical areas for which each licensee was permitted to sell, manufacture or distribute this Defendant's asbestos-containing products; and D. Describe the terms and conditions of each licensee agreement entered into between this Defendant and licensee insofar as manufacture, sale, and distribution of asbestos-containing products; E. List of products each licensee was permitted to sell or manufacture; F. Identify all documents pertaining to the licensee relationship and the custodian thereof; G. Whether or not sales to consumers in each area were made exclusively through licensee. Answer: Objection. This interrogatory is ambiguous, overbroad, harassing, over burdensome and unintelligible in the use of the word "licensees." 12. Asbestos/Facilities For the period 1920 to date, or during the period that Defendant mined, manufactured, sold or distributed asbestos containing products, whichever period is less, state the following regarding each facility that was used by you as a mining, milling, manufacturing, processing, distribution or marketing facility for asbestos containing products: A. The name and address of the building, mine, mill or facility; B. The inclusive dates the facility was in operation; and, C. The function of the facility (e.g., manufacturing, warehousing, mine, sales office, etc.) D. Plant managers and years of management; E. Name and type of asbestos-containing products manufactured or processed at each facility; F. Identify shipment records for each facility and the custodian thereof; G. If asbestos was mined and sold to any other entity besides this Defendant, please provide list of those entities. Answer: Objection. This interrogatory is overbroad, harassing, burdensome and without reference to the facts alleged in the Complaint against Chrysler Corporation. 13. Answering Defendant's Asbestos Containing Products Using the format set out below, answer the following interrogatory. The main purpose of this interrogatory is to first, obtain basic information concerning asbestos-related products, which generic product type has been previously identified in exposure sheets in this circuit with which the answering defendant and its associated business entities were involved, and second, to identify the number of "Interrogatory Response Sheets" the answering defendant must complete. Provide the following information for each asbestos-containing product, which generic product type has been previously identified in exposure sheets in this circuit, with which this answering defendant was involved: A. The name of the associated business entity so involved; B. The Product Trade Name of the asbestos product(s) with which the entity was involved (See the definition of "Product Trade Name" at interrogatory number 14(B)); C. The Product Trade Name of the asbestos product(s) with which the entity was involved (See the definition of "Product Trade Name" at interrogatory number 14(B); D. Identify the inclusive years of each type of product involvement (e.g.. If the entity manufactured and distributed the product, list both types of involvement and the years that correspond to such involvement); Use the following format. Please work through all of the asbestoscontaining products with which one associated business entity was involved before working through all of the asbestos-containing products with which a different associated business entity was involved. Answer: Chrysler Corporation objects to the interrogatory as overbroad and burdensome. Upon information, Chrysler Corporation has never been required to serve answers to standard asbestos interrogatories in the Eleventh Judicial Circuit prior to this submission. The information sought requires Chrysler Corporation to conduct a complete product historical review of its records and files as pertains to a "generic" product list proffered by Plaintiff(s). This historical review poses great prejudice and significant burden to Chrysler Corporation, an atypical defendant party in Dade County asbestos litigation. Chiysler Corporation re-adopts the objections filed by Caterpillar, Inc.'s Motion to Strike or in the Alternative Objections to Plaintiffs' Master Preliminary Interrogatories and General Motors/Detroit Diesel's Motion to Strike Plaintiffs' Second Set of Interrogatories as pertains to be information sought by Plaintiff(s), herein. FORMAT (Repeat this format for each product with which each associated business entity was involved) (a) Associated Business Entity (b) Product Trade Name (c) Type(s) of Involvement (d) Years of Each Type of Involvement (a) Associated Business Entity Company Q (b) Product Trade Name Product E EXAMPLE (c) Type(s) of Involvement Manufacturer Distributor Labeler Rebrander (d) Years of Each Type of Involvement 1957-1973 1957-1973 1957-1973 1960-1965 (a) Associated Business Entity Company Q (b) Product Trade Name Product F (c) Type(s) of Involvement Rebrandee Labelee (d) Years of Each Type of Involvement 1953-1962 1957-1973 (a) Associated Business Entity Company R* (b) Product Trade Name Product E (c) Type(s) of Involvement Rebrandee (d) Years of Each Type of Involvement 1960-1965 * Note that if different entities are involved with the same asbestos-containing products the asbestos-containing product is to be addressed in the responses of each such business entity, including the answering defendant if applicable. 14. Product Information Following this page is a proposed "Interrogatory Response Sheet" and definitions, examples and instructions dealing with the completion of this question. For each and ever asbestos-containing product, which generic product type has been previously identified in exposure sheets in this circuit, with which you were involved, as previously identified in responding to the previous interrogatory, please answer the following. A separate response is to be provided to this question for each and every asbestos-containing product with which the responding defendant was involved. If different entities were involved with the same asbestos-containing products the asbestos-containing product is to be addressed in a response to this question for each such business entity, including the answering defendant if applicable. *For example if pipe covering is a generic product type that has been previously identified in exposure sheets filed in this circuit, then the answering defendant is to provide information regarding all types of pipe covering manufactured, sold and/or distributed by defendant regardless of whether a specific types of pipe covering /manufactured, distributed and/or sold by defendant has been identified in exposure sheets in prior litigation in this circuit. In contrast if ironing board covers are a product that have not been identified in exposure sheets filed in this circuit then the defendant need hot provide information regarding this product type. Answer: Chrysler Corporation objects to the interrogatory as overbroad and burdensome. Upon information, Chrysler Corporation has never been required to serve answers to standard asbestos interrogatories in the Eleventh Judicial Circuit prior to this submission. The information sought requires Chrysler Corporation to conduct a complete product historical review of its records and files as pertains to a "generic" product list proffered by Plaintiff(s). This historical review poses great prejudice and significant burden to Chrysler Corporation, an atypical defendant party in Dade County asbestos litigation. Chrysler Corporation re-adopts the objections filed by Caterpillar, Inc.'s Motion to Strike or in the Alternative Objections to Plaintiffs' Master Preliminary Interrogatories and General Motors/Detroit Diesel's Motion to Strike Plaintiffs' Second Set of Interrogatories as pertains to be information sought by Plaintiff(s), herein. INTERROGATORY RESPONSE SHEET A. Associated Business Entity B. Product Trade Name C. Product Generic Name D. Generic Product Type E. Product Involvement(s) F. (1) Approximate Asbestos Content By Weight Type of Asbestos by % (2) Approximate Asbestos Content By Volume Type of Asbestos bv % G. Product Years | H. Intended Uses 1. Manufacturing Sites | to to 1 i: 1 J. Sizesto K. Product Color(s) | 1 L. Product Packaging M. Geographic Limitation (Yes/No)? ___ If Yes, Shipments: Shipments: Northeast MA NH ME NY VT Rl CT Mideast OH VA WV KY Southeast FL NC SC TN AL GA MS Southwest TX CO NM UT AR AZ LA OK Midwest Ml IL IN MO Wl MN ND SD West CA NV OR ID WA MT HI AK East PA DE NJ MD DC Other vT GU PR N. Product Literature P. Package Picture(s) R. Trademark Name(s) S. Patent Numberlsl T. Product Alteration 0. Product Picture(s) Q. Product Sample KA IA A. Associated Business Entity Definition: The name of the business entity as identified in the previous Interrogatory that had any involvement (as defined in Subpart E) with the asbestos-containing product. Example: Associated Business Entity Associated Business Entity Associated Business Entity The Ruberiod Co. Baldwin-Hill Company None Instructions: Complete this.interrogatory with the name of an Associated Business Entity that corresponds to this product as disclosed in the previous Interrogatory. Where the answering defendant, rather than an Associated Business Entity, was involved with this asbestos-containing product, type "none" on this line. Product Trade Name Definition: The full name of the asbestos-containing product by which it was marketed. Generally, this would be the name of the product as it appeared on the product, its packaging or its promotional material. Where all, or part of the product name is trademarked, the name should be included in the product trade name. Instructions: Where a product trade name represents more than one product, or a line of products, complete separate "interrogatory Response Sheets" for each such product to the extent reasonable and necessary so as to provide as much information as possible regarding each such product or product line. Where information concerning more than one product or a product line is condensed on one "Interrogatory Response Sheet," explain, on a separate sheet of paper why you did so. Examples: Product Trade Name BEH Super Powerhouse Cement Product Trade Name Gold Bond Asbestone Economy 250 Product Trade Name K-Fac Insulation Blocks Product Trade Name Armstrong Accobest AS-8073 Product Trade Name Armstrong Accobest AS-474 Further Instructions: Where the product name is "generic." that is, it does not have a trade name by which it was sold, then list the product's generic name but preface the generic name with the name of the entity most closely associated with that generic. The entity most closely associated with that product would be the entity's name that would appear with the product, product package, or product promotional literature. If no such association exists, then the name of the /manufacturer of that generic product should be used. Further Examples: Product Trade Name Ruberoid Asphalt Saturated Asbestos Weatherproof Jacket Product Trade Name Amatex Asbestos Woven Tape Product Trade Name Armstrong Perforated Asbestos Board Product Trade Name Celotex Perforated Asbestos Board C. Product Generic Name Definition: The name by which this type or species of product was routinely called. Generally, this name would be the generic name of a product (without the name of the entity most closely associated with that generic product). Examples: Product Trade Name Carevstone Asbestos-Cement Siding Product Generic Name Asbestos Cement Siding Product Trade Name Gold Bond Asbestone Economy 250 Product Generic Name Corrugated Siding and Roofing Product Trade Name K-Fac Insulation Block Product Generic Name Insulation Block Product Trade Name Armstrong Perforated Asbestos Board Product Generic Name Perforated Asbestos Board D. Generic Product Type Definition: Product Generic Name Insulating Cement Product Category Cement Product Generic Name Corrugated Siding and Roofing Product Category Roofino/Sidino Product Generic Name Hi-temp Block Product Category Block Product Generic Name Perforated Asbestos Board Product Category Board Further Instructions: To the extent reasonable, the following categories of products should be used. Where a product fits as readily in one category as another (e.g., corrugated siding and roofing), both categories can be listed as is shown above. Adhesives Automotive Brake Automotive Clutch Block Board Boiler Cement Cable Cement Cement Sheets Cement Shingles Cloth Clothing Cord Cork Products Electrical Products Felts CATEGORIES Friction Gaskets Home Use Hot tops Lumber Millboard Non Automotive Brake Non Automotive Clutch Paper Pipe Covering Plaster Refractory Rollboard Roofing Rope Siding Talc Tape Textiles Wallboard Wall Covering Wick Wire Cement Board Cement Pipe Fiber Floor Tile Packing Paint Spray Materials Speckling If none of the above categories are appropriate, note "other" and use your own words to describe the category of product. Product Involvement(s) Definition: Any involvement, association, or relationship you had with an asbestoscontaining product as a miner of asbestos, manufacturer of an asbestoscontaining product, seller of an asbestos-containing product, distributor of an asbestos-containing product, rebrander of an asbestos-containing product, rebrandee of an asbestos-containing product, labeler of an asbestos-containing product, labelee of an asbestos-containing product, or some other relationship. Further Definitions: A miner of an asbestos-containing product is any entity that takes asbestos from the earth for commercial sale or distribution. A manufacturer of an asbestos-containing product is any entity that manufactures any product that incorporate asbestos into that product, or. who in any way processes or packages asbestos or an asbestoscontaining product. A distributor of an asbestos-containing product is any entity who ships or in any way directs shipments of an asbestos-containing product. A rebrander of an asbestos-containing product is any entity that manufacturers process, or packages asbestos or an asbestos-containing product but which places the name of another entity or the name of a product with which another entity is involved on that product or product package. A rebrandee of an asbestos-containing product is any entity for which asbestos or an asbestos-containing product is manufactured, processed, or packaged by another entity, which other entity places the name of the rebrandee or the name of a product with which the rebrandee is involved on the product or product package. A labeler of asbestos or an asbestos-containing product is any entity that places its business name anywhere on an asbestos-containing product or package that it manufactures, distributes, sells or rebrands for itself or any entity. A labelee of asbestos or an asbestos-containing product is any entity for who its business name is placed anywhere on an asbestos-containing product or package that is manufactured, sold, or rebranded by any entity. Some other association or relationship with an asbestos-containing product other than as a miner, manufacturer, distributor, rebrander, rebrandee, labeler or labelee. Instructions: For each asbestos-containing product with which you were in any way involved, indicate the type or types of relationships you had at any time with that product, noting on line E the code ` or codes for such relationship. These involvements should be the same as were listed in the previous interrogatory. Use the following codes: Miner (Mr) Rebrander (Rr) Manufacturer (Mf) Rebrandee (Re) Labeler (Lr) Labelee (Le) Distributor (Dr) Other (To) Examples: Product Involvements Mf Rf Lr Dr Product Involvements Dr Some other association or relationship with an asbestos-containing product other than as a miner, manufacturer, distributor, rebrander, rebrandee, labeler or labelee. Instructions: For each asbestos-containing product with which you were in any way involved, indicate the type or tvoes of relationships you had at any time with that product, noting on line E the code or codes for such relationship. These involvements should be the same as were listed in the previous interrogatory. Use the following codes: Miner (Mr) Rebrander (Rr) Manufacturer (Mf) Rebrandee (Re) Examples: Product Involvements Mf Rf Lr Dr Product Involvements Dr Labeler (Lr) Labelee (Le) Distributor (Dr) Other (To) F. {1) Approximate Asbestos Content by Weightto Type of Asbestos by %_________________________________________ Definition: The usual weight of the asbestos in the product divided by the total weight of the product expressed as a percent. Additionally, provide a listing of all types of asbestos, including contaminants found in the product, as supplied to end users and for each type provide the percentage by weight of each type per unit of product. Instructions: Where the asbestos content has varied to any significant degree over time in a particular product, indicate the range of asbestos content in the appropriate section of the answer. If little change occurred over time, write "N/A" in those sections. In the first part of the answer, whether or not the asbestos content varied, indicate what you believe would be the usual, most representative content over time. In the second part of the answer, note the range of asbestos content over time. When stating the percent of asbestos by weight, exclude any water added as part of the formulation and in application of the product. Use the following two letter codes when responding to this interrogatory:? Cv for crysotile Am for amosite Cr for crocidolite Jr for tremolite lo for any other type of asbestos N/A for not applicable Example: Approximate Asbestos Content by weight 10% I N/A to N/A Approximate Asbestos Content by weight 10% I 3% to 12% Type of Asbestos by % Cv - 10%. Tr - 1 % (2) Appropriate Asbestos Content by Volume I to Type of Asbestos by %_____________________________________ Definition: The usual volume of the asbestos in the product divided by the total volume of the product expressed as a percent. Additionally, provide a listing of all types of asbestos, including contaminants found in the product as supplied to end users and for each type provide the percentage by volume of each type per unit of product. Product Years;_________________________________________________________________ Definition: Inclusive dates of all types of involvement with the asbestos-containing product, expressed in years. Instructions: Indicate in the first half of the space, the year you, or the relevant associated business entity first became involved with the asbestos-containing product. On the second half of the space, indicate the last year of involvement with that asbestos-containing product. If the involvement with the asbestos-containing product was not continuous through all years, use the additional spaces provided to represent such years of involvement. If the involvement with an asbestos-containing product lasted for only one year or part of one year, note the same year in both halves of the space. If the involvement continues to this time, note "P" for present in the appropriate space. Type: N/A I N/A (not applicable) on any unused spaces. Example: Product Years 1948 I 1972 1975 I 1975 N/A I N/A N/A I N/A Product Years 1936 I 1953 1955 I 1963 1966 I 1970 19721 P Intended Uses : Definition: Provide any limitations on the intended use of the product, including the temperature ranges for which the product was recommended. H. Intended Uses Definition: Provide any limitations on the intended use of the product, including the temperature ranges for which the product was recommended. I. Manufacturing Sites: Definition: All locations and time periods at and during which the product was manufactured during your involvement with the product. Instructions: On the first half of the line indicate the city and state, or city and province or the like, at which the product was manufactured. On the second half of the line, indicate the inclusive years of manufacture. Example: Manufacturing Sites Norfolk. VA I 1940-1970 Manufacturing Sites Milwaukee. Wl I 1962-1969 Peoria. 1L I 1967-1973 Manufacturing Sites Glendale. IL I 1967-1970 Glendale. IL I 1972 1976 Manufacturing Sites Conrad. UT | 1936-1942 Ida. IL I 1942-1950 Ida. IL I 1952-1969 J. Sizes to Definition: The generally produced sizes and shapes of the product as sold to the end user, noting the smallest to the largest standard sizes. Respond additionally to this interrogatory by providing information as to the packaging of the product when providing information regarding the product's size. (e.g. 25-75 lb. bags of cement, etc.) Instructions: In completing this information, note the smallest standard sizes or weights first, then the largest standard sizes or weights. Use the following abbreviations as appropriate. "C" for circumference "D" for diameter "G" for gauge "H" for height "L" for length "P" for pounds "T" for thickness "W" for width If the suggested abbreviations are inappropriate, type out the most useful size or weight description on the spaces provided or on a separate sheet of paper, identifying that entry as "Interrogatory Response (14)(J), Sizes" and attach that sheet to the Interrogatory Response Sheet. Examples: Sizes D2". LI 2". T1/2" to D24". L48". T2 Sizes 10 P sacks to 100 P sacks Product Color(s) _____I _____I ____ | _____I Definition: The basic color(s) of the product. Where the product line had the same basic product in a variety of colors, the five most popular colors or color combinations. Instructions: A piece of product may be single-colored or multi-colored. Different pieces of the same product may be designed to show different colors (e.g., floor tile) or the color may have changed from time to time. The above lines are to be completed as follows: - If the product was the one color, complete the first half of the first line only. Note: "N/A" on the second half of the lines, and N/A I N/A on all other lines. - If the product was one color, but that color changed from time to time, complete the first half of as many lines as there were color changes (up to five). Note: "N/A" on the second half of the lines, and N/A I N/A on all other lines. - If the product line included multi-colored pieces indicate the two most prominent colors by using both sides of the line. Up to five multi-colored products can be noted. - If there were more than five colors or five color combinations, note the most frequently made color(s). - Try to limit your responses by using the following colors. Use the twoletter codes provided. Generally, do not separately identify shades of the same color. If the following colors are inadequate to describe a product color, type in what you believe is the proper color name(s). Gray (Gy) Black (Bk) White (Wh) Red (Rd) Blue (Bl) Violet (Vt) Green (Gr) Pink (Pk) Brown (Br| Yellow (Yw) Orange (Or) Tan (Tn) Example: Product Color(s) Product Color(s) Product Color(s) GvlN/A BkIN/A WhIN/A N/AIN/A N/AIN/A GvIBk BkIN/A N/AIN/A N/AIN/A N/AIN/A WhjRd WhIBk WhIBI WhIYw WhlOr L. Product Packaging Definition: The most frequently used containers in which the product was packaged. Instructions: To the extent possible, use the following codes as set forth below in responding to this interrogatory. Where no code is applicable, type the kind of container or packaging. Provide up to five types of containers, listing where known, the most frequently used container first, second most frequently used container, next, etc. Type N/A on any unused line. Cardboard box (CB) Wooden box (WB) Plastic box (PB) Other box (OB) Bound bundles (BB) Wooden spools (WL) Other spools (OL) Metal drum (MD) Cardboard drum (CO) Plastic drum (PD) Other drum (OD) Pallets (PT) Paper spools (PL) Burlap sack (BS) Cloth sack (CS) Paper sack (PS) Plastic sack (KS) Other sack (OS) Plastic spools (PL) Example: Product Packaging CB Product Packaging CD Product Packaging CS WB N/A N/A N/A N/A N/A N/A N/A KS PS OS N/A N/A M. Within the United States was there any geographic limitation which you claim was applicable to the sale of this product (Yes or No)? Geographic Limitation (Yes/No)? _____ If Yes, state the geographical area which you claim was applicable to this product. Shipments: Northeast __ __ __ __ __ __ __ MA NH ME NY VT Rl CT Mideast __ __ __ __ OH VA WV KY Southeast __ __ __ __ __ __ __ FL NC SC TN AL GA MS Southwest __ __ __ __ __ __ __ __ TX CO NM UT AR AZ LA OK Midwest __ __ __ __ __ __ __ __ __ __ __ __ Ml IL IN MO Wl MN ND SD WY NB KA IA West __ __ __ __ __ __ __ __ CA NV OR ID WA MT HI AK East __ __ __ __ __ PA DE NJ MD DC Other __ __ ___ VI GU PR Definition: Identify those states, possessions, etc. to which your product was ever shipped, was never shipped or it is unknown to you as to whether your product was ever shipped there, if you claim a geographical limitation. Instructions: Identify those areas to which you know any product was ever shipped by marking an X on the appropriate line for that state, territory, etc. Identify those areas to which you know any product was never shipped by marking an O on the appropriate line for that state, territory, etc. Identify those areas about which you have no information as to whether any product was ever shipped by marking a "?" on the appropriate line for that state, territory, etc. "Other" means any geographical area not identified by the prior abbreviations. Example: Shipments: Northeast Mideast Southeast Southwest Midwest West East Other X X X X X XX MA NH ME NY VT Rl CT X X _X_ _X_ OH VA wv KY XXXXXXX FL NC sc TN AL GA MS XXXXXX? X TX CO NM UT AR AZ LA OK 0 0 0 0 7 7 7 7 0 0 00 Ml IL IN MO Wl MN ND SD WY NB KA A O000007 7 CA NV OR ID WA MT HI AK XXXX7 PA DE NJ MD DC _0_ _0_ _0_ X VI GU PR OTHER N. Product Literature Definition: Whether or not you have any product literature of any sort (e.g., promotional literature, ads, catalogue entries, books, etc.) that describes or pictures this product, yes or no. Examples: Product Literature Yes Product Literature No Product Picture(s) Definition: Whether or not you have care, custody or control over any depictions of this product, and if so, the type of depiction(s). Instructions: If you have no depictions of this product, answer "no" in the space provided. If you do have depictions of this product, indicate the types of depictions you have. Use the following codes and indicate for each type of depiction whether it is a: - Color Picture (CP) - Color Sketch (CS) - Black & White Sketch (BS) - Blueprint (BT) Black & White Picture (BW) Photocopy (PC) Other (TO) Examples: Product Picture(s) No Product Picture(s) BT Product Picture(s) CP BT BW PC TO P. Package Picture(s) Definition: Whether or not you have any depictions of the product packaging and if so, the type of depictions. Instructions: If you have no depictions of this product, answer "no" in the space provided. If you do have depictions of this product, indicate the types of depictions you have. Use the following codes and indicate for each type of depiction whether it is a: - Color Picture (CP) - Black & White Picture (BW) - Color Sketch (CS) - Photocopy (PC) - Black & White Sketch (BS) - Other (TO) - Blueprint (BT) Examples: Product Picture(s) No Product Picture(s) BT Product Picture(s) CP BT BW PC TO Product Sample Definition: Whether or not you have one or more samples of the asbestos-containing products, yes or no. Example: Product Sample Yes Product Sample No R. Trademark Name(s) Definition: The name of any trademark(s) in any way associated with the product, product packaging, or product literature. instructions: If more than one Trademark is associated with the name of a product (e.g.. Gold Bond Ripple-Tone Panels), provide the requested information for each trademark. Type N/A on any unused lines. Examples: Trademark Name(s) Perf-A-Tape N/A Trademark Name(s) Gold Bond Ripple Tone S. Patent Number(s) Definition: The Patent Number(s) of any product or process in any way related to the product itself. Instructions: To the extent more than one patent is involved with the product itself, or the manufacture, sale, processing, development, etc. of the product, note the additional patent number on the additional line provided. Type N/A on any unused lines. Examples: Patent Number(s) 3.660.148 N/A Patent Number(s) 2.573.659 2.529.175 Product Alteration Definition: State whether the product has been altered in chemical composition since first being made. If so, please state as to each such alteration: i. The date of the alteration; ii. The nature of the alteration; iii. The reason for the alteration; iv. Identify the person(s) recommending or approving such alteration;and v. Whether there are any studies, evaluations or tests made in connection with the alteration, and if so, identify each such study. 1 5. Asbestos Free Products For each asbestos containing product whose trade name is listed in Answer No. 14, state: A. Was the product, or a substitute for that product, ever manufactured and/or sold by you without asbestos; if so, when did the sale of the product commence; B. Brand name of the asbestos free product; C. The reason product was manufactured without asbestos; D. Was the asbestos-containing counterpart of said product sold while the asbestos-free counterpart was being manufactured; if so, provide the time periods; Answer: Chrysler Corporation objects to the interrogatory as overbroad and burdensome. Upon information, Chrysler Corporation has never been required to serve answers to standard asbestos interrogatories in the Eleventh Judicial Circuit prior to this submission. The information sought requires Chrysler Corporation to conduct a complete product historical review of its records and files as pertains to a "generic" product list proffered by Plaintiff(s). This historical review poses great prejudice and significant burden to Chrysler Corporation, an atypical defendant party in Dade County asbestos litigation. Chrysler Corporation re-adopts the objections filed by Caterpillar, Inc.'s Motion to Strike or in the Alternative Objections to Plaintiffs' Master Preliminary Interrogatories and General Motors/Detroit Diesel's Motion to Strike Plaintiffs' Second Set of Interrogatories as pertains to be information sought by Plaintiff(s), herein. tt 16. Product Development/Design For each asbestos product referred to in Answer No. 14, or which was sold to any other defendant, state separately: A. Was the product manufactured or sold to any entity prior to its being placed on the commercial market; B. The date and place where the product was designed and developed; C. The identity and last known address of the person or persons responsible for the design or development of the product; D. Was she product ever tested prior to its being sold for use by the consumer? If so, provide the identity and present location of all records dealing with these tests (including testing concerning use, application, durability, toxicity, etc.) and the custodian of said records. Answer: Chrysler Corporation objects to the interrogatory as overbroad and burdensome. Upon information, Chrysler Corporation has never been required to serve answers to standard asbestos interrogatories in the Eleventh Judicial Circuit prior to this submission. The information sought requires Chrysler Corporation to conduct a complete product historical review of its records and files as pertains to a "generic" product list proffered by Plaintiff(s). This historical review poses great prejudice and significant burden to Chrysler Corporation, an atypical defendant party in Dade County asbestos litigation. Chrysler Corporation re-adopts the objections filed by Caterpillar, Inc.'s Motion to Strike or in the Alternative Objections to Plaintiffs' Master Preliminary Interrogatories and General Motors/Detroit Diesel's Motion to Strike Plaintiffs' Second Set of Interrogatories as pertains to be information sought by Plaintiff(s), herein. 17. Sales Documents Please state whether you have any documents of any kind indicating or reflecting past sales of one or more asbestos-containing products listed in response to interrogatory 14, including, but not limited to, invoices, orders, purchase records, sales records, confirmations, bills of lading, annual or other periodic summaries of sales or orders, accounts payable or accounts receivable records, etc. If so, describe in detail the different types of documents that you have for each such asbestos-containing product, and state the following as to each type of document: A. The items of information contained on it (e.g., date of sale, product, quantity, purchaser, shipment location, price, etc.); B. The years of sale encompassed by documents still in existence; C. The current location of the documents; D. Identify the current custodian of the documents, as well as the current employee most familiar with the codes or system used on the documents. Answer: Chrysler Corporation objects to the interrogatory as overbroad and burdensome. Upon information, Chrysler Corporation has never been required to serve answers to standard asbestos interrogatories in the Eleventh Judicial Circuit prior to this submission. The information sought requires Chrysler Corporation to conduct a complete product historical review of its records and files as pertains to a "generic" product list proffered by Plaintiff(s). This historical review poses great prejudice and significant burden to Chrysler Corporation, an atypical defendant party in Dade County asbestos litigation. Chrysler Corporation re-adopts the objections filed by Caterpillar, Inc.'s Motion to Strike or in the Alternative Objections to Plaintiffs' Master Preliminary Interrogatories and General Motors/Detroit Diesel's Motion to Strike Plaintiffs' Second Set of Interrogatories as pertains to be information sought by Plaintiff(s), herein. 18. Sales Office Did you ever have any sales offices in Florida that were responsible for distribution and/or sales of asbestos and/or asbestos containing products listed in responding to interrogatory 14? If so, please state as to each such sales office; A. Its address and years of operation; B. Identify all managers from 1930 through the present and the years during which they were served; Answer: Objection. This interrogatory is overbroad without reference to the allegations against Chrysler Corporation. Without waiving said objections, Chrysler Corporation has submitted to the personal jurisdiction of this Court with regard to this litigation. * c* 1 9. Fiber Purchases l Please state the name and address of each business entity from whom the Defendant, Defendant's predecessors. Defendant's subsidiaries have ever bought or received raw asbestos fiber. Answer: Chrysler did not design and/or develop all brake linings that it sold from 1959 to 1988. In addition to manufacturing brake linings, Chrysler purchased brake linings from other manufacturers. Subject to and without waiving the foregoing objections, Chrysler manufactured brake linings starting 1959. Chrysler also purchased brake linings from the following manufacturers during the years indicated: 1958 - 1961 Johns-Manville ABEX 1962 Bendix (Allied Signal Corp.) t_Johns-Manville 1963-1964 Bendix (Allied Signal Corp.) 1965-1968 Johns-Manville ABEX Bendix (Allied Signal Corp.) '20* ' .r % t* 20. Insurance For all policies of insurance affording general liability or product liability coverage, including primary policies, excess policies, policies of reinsurance, program of self-insured retention (SIR) and/or policies in which defendant was additionally insured, applicable to injuries allegedly caused by exposure to asbestos and/or asbestos containing products state: A. Insurer: Specify exactly as named in the insurance policy or other evidentiary document coverage. B. Insured: The insured named in the policy. C. Policy Period: Refer to the actual period for which the insurance policy is and/or was in effect. D. Policy Type: Specify whether primary, excess or self-insured, etc. E. Per Occurrence/ Accident Limits: Refer to the limit for any one occurrence or any one accident. F. Products Aggregate: Refer to the aggregate limit applicable to products bodily injury liability coverage. Certain insurance policies may contain combined aggregate for bodily injury, property damage and other covered perils; if so, refer to the combined limit and so indicate. G. Products Aggregate Consumption: The function of the Aggregate Consumption Summary is to track the consumption of total products liability aggregate limits claims. List such consumption. If applicable the date upon which the policy limits were paid out in full or exhausted. H. Policy Number: Specify exactly as contained on the insurance policy or other evidential document of coverage the policy number. Additionally provide the custodian of the policy and/or document. 1. Insurer Objection: Specify the bases upon which the relevant insurer refuses to fully pay claims upon demand. If the insurer has not objected to payment or is paying, note N/A. Answer: Objection. The Interrogatory is overbroad and without reference to facts set forth in Plaintiff's Complaint. Without waiving its objection, Chrysler Corporation is presently self-insured and has been for years. These may however be certain concurrent coverage with Hartford Insurance Company. Chrysler has been self-insured by the Hartford Insurance Company from 1926 until 1971. There were separate policies each year. From 1972 to the present, Chrysler is largely self-insured. *0 21. Asbestos Consultant Has any person ever served as a consultant (excluding experts retained during the time of litigation), full or part-time, to defendant in any manner regarding the potential medical, toxicological, or industrial hygiene aspects of asbestos or any asbestos containing product? (the term consultant is meant to include any specialist in the above areas who was at least in part retained for his expertise and opinions in other than a full-time salaried position). If so, please state the following as to each such person; A. Identify the person; B. The beginning date, ending date, and period of service for the person; C. The job duties and/or responsibilities for the person, as well as a summary of the work performed; D. The plant address, office address, or duty assignment location for the person for each part of the consultancy; E. The reason for retaining the person; F. Identify the company official responsible for retaining the person, as well as identify the company officials with whom the person met during the period of the employment of consultancy; and, G. State whether the documents relating to the employment or consultancy in any way, including contracts, correspondence, publications, reports, status reports, studies, etc., exist and whether or not said documents mention asbestos. Additionally if said documents exist provide the name of the records custodian of said documents. Answer: Objection. This Interrogatory is overbroad, burdensome and without reference to the facts set forth in Plaintiff's Complaint. Without waiving its objection, Chrysler states as follows: Chrysler has retained an industrial hygienist since the mid 1930's. The industrial hygienist was hired since Chrysler felt it was necessary to establish an industrial hygiene department. The industrial hygiene department is located in Highland Park. Presently the industrial hygiene department reports to the manager of occupational safety, health and worker's compensation. 4& 22. Physician/Consultant 1. Please state whether or not Defendant ever employed, engaged or retaining any physician as a consultant, plant physician or otherwise (excluding experts retained during the course of litigation), in connection with asbestos-related business activities. If so, please state the following as to each such physician. A. Identify the physician and give complete dates and places of employment or service; B. State the physician's duties and responsibilities; C. Identify the company person to whom the physician reported; D. State the purpose for which the physician was employed, engaged or retained; and , E. State whether documents pertaining to the physician's professional activities involving asbestos and/or individuals exposed to asbestos exist and the custodian of said documents. Answer: Objection. This Interrogatory is overbroad, vague and without reference to the facts set forth in Plaintiff's Complaint. The term "physician as a consultant" is not defined. 23. Safety Consultant Please state whether or not any industrial hygienist, toxicologist, safety director, occupational medical director, physician or consultant in any of the foregoing areas previously identified (excluding experts retained during the course of litigation), ever made at any time any statements, recommendations and/or suggestions to the Defendant pertaining to or relating to asbestos or health hazards from dust or any product. If so, state the following as to each such occasion; A. Identify who made the recommendation and/or suggestion; B. State the date of the recommendation and/or suggestion; C. Identify all company officials who receive the recommendation and/or suggestion; D. State the substance of the recommendation and/or suggestion; and, E. State whether any documents and/or records of oral conversations embodying or pertaining to the recommendation and/or suggestion exist and if so the custodian of said records. Answer: Objection. This Interrogatory is overbroad, vague and without reference to the facts set forth in Plaintiff's Complaint. The term "physician as a consultant" is not defined. 24. Tests/Asbestos Please state whether Defendant ever conducted or caused to be conducted any tests (whether laboratory or field tests) on any of their or anyone else's asbestos-containing products, including measurements of exposure levels during installation, removal and/or after installation after they had degenerated or decomposed from use, to determine potential or likely asbestos exposure levels during conditions of intended use of the product. If so, please state the following as to each such test; A. Identify the person who directed that the test and/or measurement be made and/or conducted; B. Identify the person or organization who conducted the test and/or measurement; C. Identify where, when and for how long the test and/or measurement was conducted, including the department of the plant or facility involved, as well as its owner and operator; D. State the product(s) tested and describe the conditions of the test, including the measurement methodology; C. E. Describe whatever efforts, if any, were used in the test to simulate the various conditions of possible or probable use of the product, such as in confined spaces or tunnels; F. State the asbestos exposure levels measured including the ranges measured, median measurement and average measurement; G. Identify to whom the test results were reported; and, H. Identify all documents pertaining to the test and the custodian thereof. Answer: Objection. This Interrogatory is vague, ambiguous and overbroad. Notwithstanding this objection based on available corporate records, Chrysler Corporation has not done direct testing. 25. Financial Support/Measurement/Tests Has Defendant ever conducted, caused to be conducted or financially supported through at least a 10% contribution toward s the total cost, any asbestosrelated epidemoiolic, toxicologic, animal, medical, scientific tests, reviews, investigations, analysis, research or studies of any king (hereinafter termed "studies")? If so, please state as to each such study: A. Identify who directed or authorized that the study be done; B. Identify the person or organization that conducted the study; C. State the dates and over what time period the study was done; D. Describe the study design and protocol; E. State the complete results of the study, including any conclusions or recommendations contained therein; F. Identify all company officials who received notice of the existence of the study and/or its results; G. Identify all documents relating to the study and the custodian L. thereof; and H. State whether the study was ever published, and if so, state the study title and citation. Answer: See Answer to Interrogatory Number 24. '3c*t \,.r. \ v* 26. Literature Review Has Defendant ever conducted, caused to be conducted, or financed through at least a 10% contribution towards the total cost, any effort to monitor or review the professional literature regarding the clinical, epidemiologic, toxicologic, industrial hygiene, medical and/or scientific aspects of asbestos and/or products containing asbestos (excluding for the purposes of litigation)? If so, please state the following as to each effort: A. Identify who directed or authorized that the effort be done; B. Identify the person or organization that conducted the effort; C. State the dates and over what time period the effort was done; D. Describe the effort design and protocol; E. State the complete results of the effort, including any conclusions or recommendations contained therein; F. Identify all company officials who received notice of the existence of the effort and/or its results; G. Identify all documents relating to the effort and the custodian thereof; and, H. State whether the effort was ever published, and if so, state the effort title and citation. Answer: Objection. Objection to this Interrogatory on the ground that it is vague, irrelevant, overbroad not properly limited as to time. Subject to and without waiving the foregoing objection, Chrysler Corporation states that it has not undertaken or financed such studies. "2* 0 27. Specific Studies/Participation Did Defendant at any time in any way participate in any of Metropolitan Life insurance Company's studies of asbestos (conducted approximately between 1929-1940), any Trudeau Foundation/Saranac Lake studies (between 19291960), or any Industrial Hygiene Foundation studies (between 1938-1968)? If so, identify each such study in which you were involved and state as to each: A. What role or action you took in regard to the study; B. Identify all documents related to your involvement in the study and the custodian thereof; C. Identify each of your facilities in which any part of the study was conducted and reference your facility to the data reported in the study; and, D. Identify each of your officers, supervisors, managers or employees who assisted, participated in or directed your involvement in the study. Answer: See Answer to Interrogatory Number 26. * ct* 28. Asbestos Hazard/Notice ( Did Defendant at any time prior to 1980 receive, have notice of, acquire or possess any advice, publication, statement, warning, order, directive, letter, memorandum, recommendation or document, written or oral, in any way related to asbestos and health hazards, or which implicitly or explicitly refers to asbestos and health issues. If so, state the following as to each such document and oral conversation, and each such occasion prior to 1980: A. When any of this knowledge was first acquired, how it was acquired, identify by whom it was acquired, and state the substance of the knowledge acquired. B. Identify all documents pertaining to the advice, publication, statement, warning, order, directive, letter, memorandum, or recommendation and the custodian thereof; C. Identify all company officials and directors who received notice of the existence of the document or oral conversation. For each such oral conversation state the approximate date of said conversation and the parties to said conversation; and, D. What action, if any, was taken by you as a consequence of the document or oral conversation. Answer: Objection. Chrysler Corporation objects to this Interrogatory as overbroad, burdensome and calls for a scientific and/or medical conclusion that Chrysler is not available to provide. This interrogatory improperly assumes that there is or might be adverse health effects associated with the use of chrysotile asbestos. Consequentially, answering Defendant cannot respond to the interrogatory in its present form. Additionally, the interrogatory is designed to elicit a response that maybe used in a misleading manner at the time of trial rather than the discovery factual information. Chrysler does not acknowledge a causal relationship between exposure to brake dust or clutch facing dust and any diseased illness. Chrysler was, however, aware in the 1930's that certain types of raw asbestos could cause pulmonary disease when inhaled in large quantities. Notably, chrysotile asbestos used in friction products is a different type of asbestos than the types involved in insulation products. *"SB. 29. Knowledge/Asbestosis Please state whether Defendant obtained, prior to 1980, any knowledge concerning the association, if any, between the inhalation of asbestos fibers and a lung disease known as asbestosis, in users, consumers and/or persons exposed to asbestos and/or asbestos containing products. If so, please state: Answer: A. When any of this knowledge was first acquired, how it was acquired, identify by whom it was acquired, and state the substance of the knowledge acquired; B. As to each such occasion thereafter in which your knowledge as to asbestosis increased either relative to the types of exposures (i.e. trades and occupations, etc.) and/or types of products which became associated with the development of asbestosis state: (1) when was this additional knowledge acquired; (2) how was this additional knowledge acquired; (3) identify by whom it was acquired; (4) state the substance of the additional knowledge acquired; C. Identify all documents relevant to your acquisition of knowledge concerning the disease asbestosis and the custodian thereof; and, D. If any of the foregoing knowledge was acquired through an oral conversation, identify each such oral conversation, the approximate date of said conversation and the parties to said conversation. See Answer to Interrogatory Number 28. < tt 30. Knowledge/Lung Cancer Please state whether Defendant, prior to 1980, ever obtained any knowledge concerning the association, if any, between the inhalation of asbestos fibers and lung cancer, in users, consumers and/or persons exposed to asbestos and/or asbestos containing products. If so, please state: A. When any of this knowledge was first acquired, how it was acquired, identify by whom it was acquired, and state the substance of the knowledge acquired. B. As to each such occasion thereafter in which your knowledge as to lung cancer increased either relative to the types of exposures (i.e. trades and occupations, etc.) and /or types of products which became associated with the development of lung cancer state: (1) when was this additional knowledge acquired; (2) how was this additional knowledge acquired; (3) identify by whom it was acquired; (4) state the substance of the additional knowledge acquired; C. Identify all documents relevant to your acquisition of knowledge concerning lung cancer and the custodian thereof; and, D. If any of the foregoing knowledge was acquired through an oral conversation, identify each such oral conversation, the approximate date of said conversation and the parties to said conversation. Answer: See Answer to Interrogatory Number 28. se. * <*. 31. Knowledge/Mesothelioma I Please state whether Defendant, prior to 1980, ever obtained any knowledge concerning the association, if any, between the inhalation of asbestos fibers and mesothelioma, in users, consumers and/or persons exposed to asbestos and/or asbestos containing products. If so, please state: A. When any of this knowledge was first acquired, how it was acquired, identify by whom it was acquired, and state the substance of the knowledge acquired. B. As to each such occasion thereafter in which your knowledge as to mesothelioma increased either relative to the types of exposures (i.e. trades and occupations, etc.) and/or types of products which became associated with the development of mesothelioma state: (1) when was this additional knowledge acquired; (2) how was this additional knowledge acquired; (3) identify by whom it was acquired; (4) state the substance of the additional knowledge acquired; C. Identify all documents relevant to your acquisition of knowledge concerning mesothelioma and the custodian thereof; and, D. If any of the foregoing knowledge was acquired through an oral conversation, identify each such oral conversation, the approximate date of said conversation and the parties to said conversation. Answer: See Answer to Interrogatory Number 28. 2*. * 32. Knowledge/Cancer of the Gastrointestinal Tract Please state whether Defendant ever obtained any knowledge concerning the association, if any, between the inhalation of asbestos fibers and cancer of the gastrointestinal tract (i.e. colon, stomach, etc.), in users, consumers and/or persons exposed to asbestos and/or asbestos containing products. If so, please state: A. When any of this knowledge was first acquired, how it was acquired, identify by whom it was acquired, and state the substance of the knowledge acquired. B. As to each such occasion thereafter in which your knowledge as to cancer of the gastrointestinal tract increased either relative to the types of exposures (i.e. trades and occupations, etc.) and/or types of products which became associated with the development of cancer of the gastrointestinal tract state: (1) when was this additional knowledge acquired; (2) how was this additional knowledge acquired; (3) identify by whom it was acquired; (4) state the substance of the additional knowledge acquired; C. Identify all documents relevant to your acquisition of knowledge concerning cancer of the gastrointestinal tract and the custodian thereof; and, D. If any of the foregoing knowledge was acquired through an oral conversation, identify each such oral conversation, the approximate date of said conversation and the parties to said conversation. Answer: See Answer to Interrogatory Number 28. :*se. * 33. Warning/Description ( Please provide the following information as to each caution, warning or hazard statement or explanation involving asbestos alleged to have been placed on the products or packaging or asbestos containing products by you? A. What was its precise wording; B. Where was it located on the product or packaging, and what was the size and color of the lettering; C. Has the wording or its presentation ever been altered, and if so, how and when; D. The years during which each version of a caution, warning or hazard statement appeared on each individual product identified in responding to interrogatory 14; E. Identify all company officers and/or committees who participated in the decision to affix each version of the caution, warning or hazard statement to a product or its packaging, and in particular, identify the prime decision-maker, if any; and F. Identify all documents related in any way to each caution, warning or hazard statement and the custodian thereof. Answer: Objection. This interrogatory is not specific as to a time period, it is irrelevant, overbroad and burdensome. Furthermore, Chrysler has sold motor vehicles with brakes and clutch parts allegedly installed in these automobile vehicles and are generally not shipped in packages with respect to after-market products. They are shipped in cardboard cartons of various sizes. These products may also have been distributed as components incorporated into motor vehicles of various sizes and descriptions. However, notwithstanding these objections, for purposes of discovery, the Chrysler service manual contained warnings (See attached 1973 and 1984 Service Manual regarding warnings). Warnings have been incorporated in Service Manuals consistently since 1984. sc*t. V* s ` 34. Warning/Insert Has Defendant ever placed any form of package insert or informative brochure in a container of an asbestos-containing product, listed in response to interrogatory 14, explaining the hazards of asbestos? If so, state as to each such insert or brochure: A. When was it first placed in containers and for what years thereafter? B. What products had the insert or brochure included; C. Describe the size, shape, color and text of the insert or brochure; D. Identify all persons involved in the decision to include the insert or brochure; and E. Identify all company officers and/or committees who participated in the decision to include an insert or brochure, and in particular, identify the prime decision-maker, if any; and F. Identify the insert and/or brochure itself and the custodian thereof. W Answer: See Answer to Interrogatory Number 33. < s*. .r \ V 35. Warning/Customer State whether you published and/or otherwise provided any of your distributors and/or customers with any instructions in regard to the asbestos hazards, if any, presented by use of Defendant's asbestos-containing products, other then inserts or labels (i.e. promotional pamphlets, product manuals, specification sheets, sales brochures, etc.) If so, please state: A. When such instruction were first given; B. By whom and when were these instructions made; C. State the specific instructions provided; and D. Identify all oral communications and documents related to these instructions. If oral identify the approximate date of said communication and the parties involved, if written provide the custodian of said documents. Answer: Objection. This Interrogatory is burdensome and overbroad. Without waiving this objection, the repair manuals were available from Chrysler Corporation with respect to repairs on Chrysler motor vehicles. Repair manuals have been in existence for decades. Notwithstanding this objection, warnings have been placed in the service repair manual continually since 1984 and have been on all new asbestos containing after market brake or clutch products since 1983. (See attached 1973 and 1984 Service Manual regarding Warnings). * *  36. Warning/Mask 1 Has Defendant ever placed any form of disposable face mask or respiratory in a container of an asbestos-containing product for later use by persons who would handle and/or be exposed to the product? If so, please state: A. The products covered by the practice; B. The year this practice began in the years it was implemented; C. Describe the type of face mask or respirator included in the container; and D. Identify all oral communications and documents related to this practice. If oral identify the approximate date of said communication and the parties involved, if written provide the custodian of said documents. Answer: Objection. This Interrogatory is vague, ambiguous and not likely to lead to the discovery of relevant evidence. :`3S" *0 SECONDARY PRIMARY RETURN RETURN ANCHOR' SpR|N SPRING PLATE \ SHOE TAB (3) CABLE GUIDE SHOE RETAINERS. SPRING AND NAIL ASSEMBLIES PRIMARY SHOE RETURN SPRING TAB OF ANTI-RATTLE SPRING DRUM BRAKES 5*9 SPECIAL TOOL 'REMOVING AND INSTALLING) SECONDARY SHOE RETURN SPRING 4 PARKING BRAKE LEVER AUTOMATIC ADJUSTER SPRING SUPPORT PLATE / ADJUSTER SCREW ASSEMBLY LEFT REAR SECONDARY SHOE AND LINING LEVER SPRING OVERLOAD SPRING PF4J2 rig. 5--Eleven Inch Brake Assembly--(Rear) slikr>< contact across the entire width, extending from heil to toe. Shoes showing contact only on one side should be replaced. Shoes having sufficient lining but lack of contact at toe and heel should be measured for proper grind. Clean the support, using a suitable solvent, then PRIMARY RETURN SPRING ANTI-RATTLE SPRING ANCHOR PLATE LOCK SECONDARY RETURN SPRING PARKING BRAKE LEVER STRUT SHOE TAB (3) ADJUSTER SPRING ADJUSTING LEVER NU3A3A fig. 7--Removing Shorn Return Spring*--(Left RearJ inspect for burrs. Remove if necessary. Clean and inspect the adjusting screws for pulled or stripped threads, then apply a thin film of lubricant to the threads, socket and washer (Fig. 91. Replace adjuster screw if corrosion of any pan inhibits very free opera tion. New brake shoe return springs and hold down springs should be installed where the old springs have been subjected to overheating or if their strength is questionable. Spring paint discoloration or distorted end coils would indicate an overheated spring. GRINDING AND REFACING RECOMMENDATIONS Brake Shoe Lining--New lining should be mea sured and ground .060 in. to .080 in. (maximum under the drum diameter). When replacing brake shoe and lining assemblies, always check them in the drum SECONDARY SHOE AND LINING ^ TAB OF ANTI. RATTLE SPRING "^'BEHIND SHOE WEB) .UPPORT PLATE SHOE RETAINERS. SPRING AND NAIL ASSEMBLY AOJUSTER SCREW ASSEMBLY AOJUSTER (STAR WHEEL) LOCK SPRING LIFT o?AB PFaa3 fig. 6--tleven Inch Brake Assembly--(Without Automatic Adjusters/--(R^^r) SPECIAL TOOL tilt PRIAAARY SHOE ANO LINING RETAINER NUJ44 fig. 6--Removing or Installing Shoe Retainers, Snrinnt '' 5*10 DRUM BRAKES SOCKET SCREW THREADS SUTTON NUT fig. 9--AdjvHer Screw Atiwnbly PBJ10 they are to be used with to insure that they have the recommended radius grind. This grind, which should provide at least .004 inch heel and toe clearance, is necessary for proper lining to drum contact during brake sppiicauon. CAUTION: When resurfacing or refacing brake shoes follow manufacturing recommendations for proper use of their eo.uipment. Whatever equipment is used, ensure that proper ventilation is provided to remove asbestos dust, which can be detrimental to' health. Orum Refacing--Measure the drum runout and di ameter with an accurate gauge. There should be no iriation in the drum diameter greater than .002 h. Drum runout should not exceed .006 inch out of und. If the drum runout or diameter variation ex ceed these values the drum should be refaced. Re move only as much material as is necessary to clean up the drum. It is recommended the front drums be refaced with the wheel and tire mounted. Do not reface more than .060 inch over the standard drum diameter. NOTE: All drums will show markings of maximum allowable diameter iFig. 101. For example, a nine inch drum will have a marking of MAX. DIA. 9.090". This marx;r.g includes .030" for allowable drum wear be yond the recommended .060" of drum refacing. BRAKE SHOE INSTALLATION Installing Front Brake Shoes Lubricate with a thin film the shoe tab contact area (6 places) on support plate with Chrysler Parts Multi- Purpose Grease, Part number 2932524 or equivalent (Pig. ii). -"*%** fl) Match a primary with a secondary brake shoe and place them in their relative position on a work bench. <21 Install adjusting star wheel assembly between or' and secondary shoes, with a star wheel next o ndary shoe (Fig. 1). 1 <eft star wheel adjusting stud end is stamped indicating us oosition on the vehiclei and is also aamturn puied. The nght star wheel is black, and the PFU4 Fig. TO--Nine inch Drum--Maximum Oiomefer Identification adjusting stud end is not stamped. (3) Install adjuster spring in primary shoe and hook other end in web of secondary. Install adjusting lever spring over pivot pin on shoe web. Install adjust ing lever under spring and over pivot pin. Slide lever slightly rearward to lock in position (Fig. 1). (4) Spread anchor ends of brake shoe to hold star adjusting wheel assembly in position. (5) Hoiding brake shoes firmly, place assembly on support plate, and at the same time engage shoe webs with wheel cylinder pistons (Fig. 121. (6) Using Tool C-1070, install shoe retaining nails, springs and retainers. (Fig. 6). (7) Install anchor plate over anchor. fig. 11 -- Sho# C*- '(on lf* - PRIMARY shoe RETURN SPRING TAB OF ANTIRATTI; SPRING DRUM BRAKES 5-11 ANCHOR PIATE ADJUSTER CABLE STRUT fig. 12--installing Brake Shoes--'left front/ <81 Slide "eye" of adjusting cable over anchor and against anchor plate. Engage end of primary shoe return spring in shoe tveb and install other end over anchor, using Tool C-3785. Install cable guide in secondary shoe web. Holdfi. ide in position, engage secondary shoe return igri^ through guide and into web. Install other end brer Anchor, using Tool C-3785. (Be sure cable guide remains flat against shoe web, and that secondary tpring overlaps primary) (Fig. 1). Using pliers, 'queeze ends of spring loops (around anchor) until parallel. . (10) Thread adjuster cable over guide and hook nd oi overload spring in lever iFig. 1). (Be sure eye" of cable is pulled tight against anchor and in a traignt line with guide). i nslalling Rear Brake Shoes .Lubricate with a thin film the shoe tab contact area tplacesi on support plate with Chrysler Parts Multiurpose Grease. Part number 2932524 or equivalent Ig. Ill .(1) Install parking brake lever on inner side of condary shoe web after lubricating pivot with supirt plate lubricant Secure with wave washer and /rseshoe clip. (2) Engage parking brake lever with cable, then de secondary shoe against support plate, and at the me time engage shoe web with push rod. (if so uippeal and against anchor. P de parking brake strut behind hub and into t rking brake lever. Slide anti-rattle spring er end of strut (Fig. 131 On ten inch brakes, sure spnng ub is pointing rearward and up on '.side of shoe web (Left Brake), ana pointing frontrd ana down behind shoe web iRieb* Brake) (Fig. PRIMARY SHOE AND LINING PARKING RAKE CABLE NU245 fig. 13--Removing or installing Perking Brake Strut and Spring--(Leit Reart 13). On eleven inch brakes, be sure spring tab is pointing forward, down and inside of shoe web (both Left and Right Brake) (Fig. 5). (4) Slide primary shoe into position and engage with push rod (if so equipped) and free end of strut. Install anchor plate over anchor, then install eye of adjuster cable over anchor (Fig. 14). (5) Engage primary shoe return spring in web. of shoe and install free end over anchor, using Tool C-3785. (Fig. 7). (6) Install cable guide in secondary shoe* webT Holding in position, engage secondary shoe return spring through guide and into web. Install other end over anchor, using Tool C-3785. (Be sure cable guide remains flat against shoe web and that secondary spring overlaps primary) (Fig. 1). Using pliers, squeeze ends of spring loops (around anchor) 'until parallel. "'* PRIMARY SHOE RETURN SPRING TAB OF ANTI-RATTIE SPRING ANCHOR PLATE wave, washer HORSESHOE CUP PRIMARY SHOE AND LINING fig. M-lni(o/li'nr ft- JJUSTER 5CABLE SECONDARY SHOE AND LINI-NwG< NU347 5-12 MASTER CYLINDER i?) Install adjusting star wheel assembly between primary and secondary shoes, with star wheel next to secondary shoe iFig. 11. The left star wheel adjusting stud end is stamped "L" (indicating its position on the vehicle i and is also cadium plated. The right star wheel is black, and the adjusting stud end is not stamped. Install adjuster spring between shoes iFigs. 1. 4 and 5). (Engage primary shoe firsts. (Eleven inch brakes, install adjuster spring with coil forward, op posite adjuster lever. Fig. 51. 3) Install adjusting lever spring over pivot pin on shoe web. Install adjusting lever under spring and over pivot pin. Slide lever slightly rearward to lock in position. (9) Using Tool C-4070. install shoe retaining nails, retainers and springs (Fig. 81. TO) Thread adjuster cable over guide and hook end of overload spring in lever (Fig. 11. (Be sure eye of cable is pulled tight against anchor and in a straight line with guide). BRAKE DRUM INSTALLATION Installing Front Brake Drums <11 Lubricate wheel bearings and install brake drum and adjust wheel bearing to proper preload. (2) Adjust brakes as described under "Service Ad justments" at front of this Group. Installing Rear Brake Drums (1) Install brake drum. Reinstallation of retaining clips is not necessary. Install wheel and tire assembly. (2) Adjust brakes as described under "Service Ad justments" at front of this Group. MASTER CYLINDER INDEX Page Bleeding Master Cylinder ...................................... 15 Cleaning and Inspection........................................ 14 Disassembling Master Cylinder......................... 12 neral Information ............................................... 12 ..stalling Master Cylinder...................................... 15 Master Cylinder Identification Chart........;............ 13 Page Master Cylinder Removal ................................... 12 Master Cylinder--Special Tools.............................. 89 Reassembling Master Cylinder................................ 14 Testing Master Cylinder........................................... 15 Tool identification Picture................................1 89 GENERAL INFORMATION The vehicle identification number on the instrument warning switch tee and the front brakes. This system panel starts with a capital letter which indicates the is referred to as PRIMARY (marked F). The master carline or sales name of vehicle (see Introduction of cylinder used on a vehicle not equipped with a power this manual). These code tetters are also used to in brake unit is serviced in the same manner as the mas dicate the vehicle to which the service information ter cylinder with a power brake unit with one excep-. applies. tion, the master cylinder for power brakes does not The tandem master cylinder (Fig. 1) Is of the com include the pushrod. pensating type with the reservoirs cast integrally. The disc brake master cylinder is different from the The front outlet tube from the master cylinder is drum brake master cylinder in reservoir, cover, bail, connected to the hydraulic system warning switch and gasket size, and only THE SECONDARY OUTLET tee and then to the roar brakes. This system is re HAS RESIDUAL PRESSURE VALVE AND SPRING ferred to as SECONDARY (marked R). The roar outlet (Fig. 1). tube from the master cylinder is also connected to the i '. .L -- SERVICE' PROCEDURES uTs snricsatc'4 MASTER CYLINDER REMOVAL a l\) Disconnect primary and secondary brake tubes lmm master cylinder (residual pressure valves will cylinder from draining the drum brake master twinder). Install a plug in the rear outlet of the disc brake master cylinder. (2) Remove nuts that attach master cylinder to cowl panel and/or power brake unit (f so equipped). (3) Disconnect pedal push rod (manual brakes) from brake pedaL (4) Slide master cylinder straight 6ut?(rom cowl panel and/or power brake unit (if so equipped). DISASSEMBLING MASTER CYLINDER To disassemble the master cylinder, (Fig. 1) clean outside of master cy ler thorougnly. 37. Sales Material Has Defendant at any time, published and/or distributed any sales brochures, promotional pamphlets, product manuals, specification sheets or other written sales materials or documents of any kind or character? If so, please: A. Identify each such document and the custodian thereof; B. State for what period of time you published and/or distributed sales brochures, promotional pamphlets, product manuals, specification sheets, or other written sales material or documents without any form of warnings, cautions, hazard statements or explanations concerning asbestos. Answer: See Answer to Interrogatory Number 33. t 38. Advertisement If you advertised any of your asbestos-containing products, listed in your response to interrogatory 14, in newspapers, magazines, or other publications at any time from 1930 to the present, please state for each such advertisement that contained a warning regarding your products: A. The name of the publication in which it appeared, including the date and page number; B. A complete transcript of the advertisement and a description of any pictures accompanying it; C. The name and address of the person or agency that was responsible for approving each such advertisement; D. The name and address of whoever has current custody of the above-described advertising literature; and E. Identify all documents relating to such advertisements and the custodian thereof. Answer: See Objection to Interrogatory Number 14 incorporated herein. *. 39. Product Usage/Documents Has any written material of any kind or character been prepared by Defendant or its agents indicating how your asbestos-containing products should be used and/or maintained (other then information in regards to the hazards, if any, presented by use of the defendant's asbestos containing products)? If so, please state as follows: A. Identify all such material and the custodian thereof; B. The name, address and job classification of each person who prepared same; and; C. The dates and manner in which said material was distributed to purchasers of Defendant's products. Answer: See Answer to Interrogatory Number 33. 2*. 40. Notice/Asbestos Injury Did Defendant receive notice, prior to 1975, that any person was claiming injury as a result of using asbestos-containing products mined, manufactured, sold and/or used by you? If so, please state as to each such claim. A. The name of the claimant; B. The date of notice of the claim; C. A description of the claim including the type of exposure experienced by the claimant (e.g., mining, milling, manufacturing, insulating, etc.); D. The type of injuries allegedly sustained; E. The caption and court, address of the court or workers' compensation file number of the claim; F. Identify all documents relating to the claim and the custodian thereof. Answer: Objection. Chrysler objects to this Interrogatory on the grounds that it is irrelevant, overbroad, not properly limited as to time and unduly burdensome.* * ir 41. Please state whether the Defendant has ever been a member of the following business groups (or group with similar name), and if so, answer the following as to each group; (1) The address of the group; (2) The years during which you were a member; (3) Identify all documents in your possession relating in any way to the group, including documents before, during and after the period of your membership and the custodian thereof. A. Industrial Health Foundation (or one of its predecessors); B. Asbestos Textile Institute; C. Asbestos`Information Association of North America; D. National Mineral Wool Producers Association; E. Asbestos Cement Pipe Producers Association; F. Magnesia Insulation Manufactures Association; G. American Industrial Hygiene Association; H. Brake Lining Manufactures Association; I. Friction Materials Standards Institute, Inc.; J. Asbestos Brake Lining Manufactures Institute; K. Quebec Asbestos Mining Association; L. Institute of Occupational and Environmental Health of Quebec Asbestos Mining Association; M. American Society for Testing and Materials; N. Grinding Wheel Institute; O. Trudeau Foundation; P. National Safety Council; Q. National Insulation Manufacture Association; and R. The Refractories Institute; Answer: Objection. Chrysler objects to this Interrogatory on the grounds that it is overbroad, unduly burdensome and not properly limited as to time. Answering this Interrogatory would require making inquiry of thousands of Chrysler employees, past and present, which would be unduly burdensome. Without waiving these objections, Chrysler or Chrysler employees, or both, have had memberships in the American Industrial Hygienist Association, The Friction Material Safety Institute, The Industrial Hygiene Foundation, The American Academy of industrial Hygienist. National Safety Council, The Motor Vehicle Manufactures Association, The Battery Council International, The Society of Automobile Engineers, and The Engineering Society of Detroit. It is St^p known that Chrysler in the past, has belonged to The Friction Materials Safetytfnstitute and The Motor Vehicle Manufacturers Association. 42. Library Please state whether Defendant ever maintained any form of library or collection of books and publications. If so, state the following as to each such library; A. The original location of the library, including the building in which it was located; B. The years during which the library was in operation; C. The offices, plant facilities, departments or other organizational units serviced by the library; D. Identify each custodian of the library or librarian as well as the years of his service as librarian Answer: Objection. Chrysler objects to this Interrogatory on the ground that it is irrelevant, overbroad, unduly burdensome, not properly limited as to time and not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding and without waiving these objections, the Industrial Hygiene Department and Medical Department at Chrysler maintains reference libraries. * it STATE OF MICHIGAN COUNTY OF ) ss: BEFORE ME, the undersigned authority, PAUL KELL Y, duly sworn, deposes and says that he is the Parts Marketing Manager for CHRYSLER CORPORATION, in the matter of Tinker v. Chrysler Corporation, et. a/., who is to me personally known and who did take an oath; that he has read the foregoing Responses to Plaintiffs' First Set of Interrogatories; that the foregoing Responses of CHRYSLER CORPORATION, is based on information communicated to him by personnel of CHRYSLER CORPORATION, and information obtained from books and records of CHRYSLER CORPORATION, and he believes the foregoing Responses to be true and correct to the best of his knowledge, information and belief. SWORN TO AND SUBSCRIBED before me this 1995. of . My Commission Expires: MICHAEL J.WEISE NOTARY PUeUC - MACOMB COUNTY. MICH. MY CGMi.iwSiCN EXriScS 2-11-97 NOTARY PUBLIC A/ ' c H A t=. L- ->. KJ/c /5c Notary's Printed Name :-253f. ( it 7 ORUM BRAKES 1984 SERVICE MANUAL DRUM BRAKES INOEX Page Brake Orum Removal................................................ 12 Brake Shoe Removal................... 12 Brake Drum Installation .......................................... 15 crake Shoe installation............................................ 14 Cleaning ana Insoection ...................... .................. 12 Drum Refacing Recommenaations......................... 13 General Information .................................................... Installing Brake Supports .......................................... Removing Brake Supports.......................................... Service Oiagnosis ...................................................... Special Tools......................................... 12 15 15 7 GENERAL INFORMATION All drum brake applications are two shoe, internal expanding brakes with application adjusters. The lower ends of the brake shoes are connected by a tubular star wheel adjusting screw iFigs. 1 and 21. CAUTION: When servicing brake assemblies or com* portents, do not create dust by sanding, grinding or by cleaning brake parts with a dry brush or with com* pressod air. A water -dampened cloth should be used. Many brake components contain asbestos fibers which can become airborne if dust is created during service operations. Breathing dust which contains asbastos fibers can cause serious bodily harm. SERVICE PROCEDURES BRAKE DRUM REMOVAL ill Remove rear plug from brake adjusting access .r ^ Insert a thin screwdriver into brake adjusting hole and hold adjusting lever away from notches of adjusting screw. ,(3) Insert Tool 0-3784 into brake adjusting bole and engage notches of brake adjusting screw. Release brake by prying down with adjusting tooL (4) Remove rear wheel and clips from wheel studs that holds drum on axle. Discard clips. Remove drums. (5) Inspect brake lining for wear, shoe alignment, or contamination from grease or brake fluid. BRAKE SHOE REMOVAL (7) Remove parking brake lever from secondary shoes. Remove shoes. (8) Disengage parking brake lever from parking brake cable. CLEANING AND INSPECTION Wipe or brush clean (dry) the metal portions of ANCHOR PLATE SHOE TAB CD PRIMARY SHOE ANO UNING RETURN ANTI RATTLE SPRING CABLE GUIDE SHOE RETAINERS. AND SPRING NAIL ASSEMBLY (1) Remove rear wheel, and drum retaining clips. Remove drum. (2) Using Tool C-3785, remove brake shoe return springs (Fig. 3). (Note how secondary shoe return spring overlaps primary shoe return spring) (Figs 1 or 2). (3) Slide eye of automatic adjuster cable off an chor and then unhook from adjusting lever. Remove cable, overload spring, cable guide and anchor plate. (4) Disengage adjusting lever from spring by slid- forward to clear pivot, then working out from er spring. Remove spring from pivot. Remove shoe to shoe spring from secondary shoe web and disengage from primary shoe web. Remove spring. (5) Disengage primary and secondary shoes and re- .nove adjusting star wneei assemoiy trom snoes. (6) Remove brake shoe retainers, springs and nails usinr Tool (''.4070 rrs^ -- --------- STRUT PRIMARY SHOE ANO LINING SHOE TO SHOE SPRING PARKING BRAKE LEVER SECONDARY -SHOE ANO UNING LEVER SPRING ERLOAO SPRING ADJUSTER LEVER left rear RK2Z3 3 i iHOE RETURN SPRING ANCHOR ROTE SHOE RETURN SPRING SHOE RETAINERS. SPRING ANO NAIL ASSEMBLIES DRUM BRAKES 5-13 ANTI. RATTLE SPRING i STRUT SUPPORT SLATE PARKING brake lever SECONDARY SHOE ANO LINING SHOE TO SHOE SPRING AOJUSTER SCREW ASSEMBLY LEVER SPRING OVERLOAD SPRING LEFT REAR RK224 fig. 2--Eleven Inch Brake Assembly the brake shoes. Examine the lining contact pattern to determine if the shoes are beat The lining should show contact across the entire width, extending from heel to toe. Shoes showing contact only on one side should be replaced. Shoes having sufficient lining but lack of contact at toe and heel may be improperly ground. Clean the support, using a suitable solvent then inspect for rough or rusted shoe contact areas. Clean and inspect the adjusting screws for damaged threads, then apply a thin film of lubricant to the threads. SHOE RETURN SPRING TAB Of ANTI-RATTLE SPRING SPECIAL TOOL (REMOVING ANO INSTALLING) SHOE RETURN SPRING fig. 4--Ammoving or Installing Shorn Retainers, Springs end Nails socket and washer (Pig. 5i. Replace adjuster screw assembly if corrosion of any part inhibits very tree operation. Install new brake shoe return springs and hold down springs where the old springs have been sub jected to overheating or if their strength is question able. Spring paint discoloration or distorted end coils indicate a spring that had been overheated. DRUM REFACING RECOMMENDATIONS Drum Refacing--Measure the drum runout and di ameter with an accurate gauge. There should be no variation in the drum diameter greater than .002 inch. Drum runout should not exceed .006 Inch out of round. If the drum runout or diameter variation ex ceed these values the drum should be refaced. For best results in eliminating the irregularities that cause brake roughness and surge, the amount of material removed during a single cut should be lim ited to .005 inch. When the entire braking surface has been cleaned a final cut of .001 Inch will assure a good drum surface providing the equipment used is capa ble of giving the precision required for resurfacing brake drums. Deeper cuts are permissible for the sole purpose of removing deep score marks. Do not reface more than .060 Inch over the standard drum diameter. All drums will show markings of maximum allow* WASHER SOCKET SHOE TO SHOE ..'RING LEVER SPRING DJUST1NG LEVER RH22S fig. 3--Removing Shoe Return Springs Fio. 5- <--- 5-14 DRUM BRAKES ftg. 6--Ten Inch Drum-Maximum Diameter Identification ble diameter (Fig. 6). For example, a ten inch drum will have a marking of MAX. DIA. 10.090 inch. This marking includes .030 inch for alowable drum wear beyond the recommended .060 inch of drum refacing. BRAKE SHOE INSTALLATION Lubricate the six shoe tab contact pads on support plate with a thin film of MOPAR Multi-Purpose Lubri cant. Part number 2932524 or equivalent (Fig. 7). (1)Engage parking brake lever with cable. Install parking brake lever into rectangular hole of second ary brake shoe. (21 Slide secondary shoe against support plate, at fig. B--Removing or Installing Parking Brake Strut and Spring the same time engage shoe web with push rod and against anchor. (31 Slide parking brake strut behind axle flange and into slot in parking brake lever. Slide anti-rattle spring over free end of strut (Fig. 8). On ten inch brakes, be sure spring tab is pointing rearward and up on outside of shoe web (Left Brake), and pointing . frontward and down behind shoe web (Right Brake). (4) Slide primary shoe into position and engage with push rod Of so equipped) and free end of strut Install anchor plate over anchor, then install eye of adjuster cable over anchor (Fig. 9). (5) Engage primary shoe return spring in web of shoe and install free end over anchor, using Tool C-3785. (6) Insert protruding hole rim of cable guide into hole in secondary shoe web. Holding guide in posi tion. engage secondary shoe return spring through fig. 7--Shoe Contact Pads on Support fig. 9--tntlalling Brake Shoes MASTER CYLINDER 5-15 coi.v hole n guide, and hole in web. Using Tool C2735. install soring over anchor. Be sure cable guide remains dat against shoe web and that secondary prine overlaps primary) (Fig. 11. Using pliers, squeeze ends of spring loops (around anchori until parallel. .71 Install adjusting star wheel assembly between primary and secondary shoes, with star wheel next to secondary shoe (Fig. 11. The left star wheel adjusting stud end is stamped "L" (indicating its position on the vehiciei and the star wheel is cadmium plated. The nght star wheel is black and the adjusting stud end is stamped "R**. Insult shoe to shoe spring be tween shoes (Figs. 1 and 2). (Engage primary shoe first). (Eleven inch brakes, install shoe to shoe spring with coil forward, opposite adjuster lever. Fig. 2). i8l Insull adjusting lever spring over pivot pin on shoe web. Install adjusting lever under spring and over pivot pin. Slide lever slightly rearward to lock in position. <91 Using Tool C-4070. install shoe retaining nails, retainers and springs (Fig. 41. (10) Thread adjuster cable over guide and hook end of overload spring in lever (Fig. IV. (Be sure eye of cable is pulled tight against anchor and in a straight line with guide). , BRAKE ORUM INSTALLATION (1) Install brake drum. Reinstallation of reUining clips is not necessary. Install wheel and tire assembly as described under "Wheel Stud Nut T5 ghtening". (2) Adjust brakes as described under "Service Ad justments" at front of this Group. REMOVING BRAKE SUPPORT (1) With wheel and brake drum removed, remove brake shoe assemblies and disconnect brake cable. (2) Using a suiUble tool such as an aircraft type hose clamp compress the flared legs of cable retainer fig. 10--Removing Brakm CabU from Support Plato and pull brake cable out of support plate (Fig. 10). (3) Disconnect hydraulic brake tube from wheel cylinder. (4) Remove support to wheel cylinder attaching nuts and washers. (5) Remove rear axle shaft and retainer. Refer to "Rear Axle," Group 3. (6) Remove brake support from rear axle housing. INSTALLING BRAKE SUPPORT (1) Install support plate onto rear axle housing. (2) Insert rear axle shaft and retainer into hous ing and install axle retainer nuts and washers. Refer to "Rear Axle," Group 3. (3) Install wheel cylinder and attach hydraulic brake tube. (4) Insert parking brake cable into support plate and attach cable to parking brake lever. (5) Install brake shoes on support plate. (6) Install brake drum and wheeL Adjust and bleed brakes. MASTER CYLINDER Bleeding Master Cylinder ... General Information ............ Installing Master Cylinder ... ENERAL INFORMATION INDEX Page 17 15 . 17 page Master Cylinder Removal......................................... 16 Reservoir Replacement .................. -- *................. 16 Special Tools ............................................. 39 The body of the two piece master cylinder (Fig. 1). !s marie r: end the reservoir is maae of nylon. The two compartments of the reservoir are inter connected to oermit equalization of the fluid level. However, a sufficient quantity of fluid is retained in the reservoir of the unaffected system to permit operation of lbs* " sbestos turning Label :983 1987 CAUTION "HIS PRODUCT CONTAINS ASBESTOS. AVOID CREATING DUST. BREATHING ASBESTOS MAY RESULT IN SERIOUS BODILY HARM. bes*cs turning Label 1987 - Present DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD Service & Parts Operations Chrysler Motors Hay 12. 1988 * zt V' GTCWfc* PACKAGE ENGINEERING DEPARTMENT -nVICc PARTS PROCESSING & PACKAGING SPECIFICATION r* 07 iiRT SAU( j ^ar. "<c *. :::-.-c . .*r ,:.i ::sc . aat no j o-unz^cc \Q " Tma* <| ( *r uNA*cK*ciC MAieriai. i-j* stc. .if Gil liU! 2 . I VENDOR NO NO 2TK c f.*G 1 05-003 IZZ AT:.*:*l "r *i. CONTAINER* S;P I-SuSTANOARO "NTA.NCR/yv. .-V, * r'-} J CESCRlPY'CNOr CONTAINER ; ;CNTA..tA ,*. CLOSURE. SEE NOTE t u;rr ^CNTainCA nC ;CNTArfotft Size. I CESCRlPTIQN Of CONTAINER 1 j CLOSURE. SEE NOTE I CCNTANea NO CCNTaihCR SI2I. > zescpiptign or CONTAINER 1 1CLOSURE. SEE NOTE 1 allET LCAO HEIGHT . *r :NCLbClNG ?AuT 57D. PALLET SIZE *2' a a- UNLESS DEVIATION AUTHORIZED PALLET NO: PALLET DESCRIPTION: - * MACHINE COOt OS HAf%NTNC l.A&CI UCO ' R ISSU&.O.BY_*>. rr%bp lruf~r. nI iMiin.iii ~o/c mqcuui yutt K e;un.yci mtt* lamst tin cr >uul twscontihocnct s twf )uri>( iiroNSWurr NOTE I AU. CO*UOAT(0 CAAYON CLOSURES TO ( m ACCSROAMCI with >uiC <i or th< uMiroau raciOMT classimcation. mctmoo is optional unless otnerwise spccineo. IP TORS own.' . PACKAGE ENGINEERING DEPARTMENT aVICE PARTS PROCESSING & PACKAGING SPECIFICATION '00/25 .>AAT UAUl j 2:iOE < lin : RT Hill. disc PAAT NO *002: ?RC lO. H*n OENT OF UNPACHAGEO MATERIAL PER 1-04 STO. J VENOOR NO. | 2/A Z6H3 ft*G J FART TYRE CCCE. j 05 003-003 ATlC'iC* RAPS :~ntainrs per i-io stanoaro ;-:sNTAiNeR/M>,,-'\j D07 ESCRIPT'ON OF COMBINER ICNTAINER SIZE. i T.ZZ'X 75 s r uN CLCSUAfc. SEE HOTE I Alt ~T'f jCCNTAINER NO. DESCRIPTION Of CONTAINER. ICNTAinER s-ze. CLOSURE SEE NOTE 1 rv CCNTAiNtA/tua..I.-T---r-i.DnOeR DESCRIPTION OF CONTAIMER: ?srs CONTAINER SIZE. CLOSURE SEE NOTE \ IF *7 .ZAO HEIGHT 4J* INCLUDING PALLET. STO. PALLET SIZE 42* * aE* UNLESS OEVIATION AUTHORIZED Tj PALLET NOuj-yi ^jjQ^ PALLET OESCRIFTION: INC CARTON 5.25'X 1.5* X 7.73* MACHINE COOE: f.TN 13.75'X 5.5* X C.!5* RSC. 3T0S MARKING 1 A3CI. REQUIRED. < 04 73-07 > ,SSU?Ptt POWELL i*G MAIfRiAi.S. ixOiO* MOCUSU MUST ( mCOUMANCI WIHUTIST CAT* OF ISSUE. TM| CONTINGENCY IS THE SUFRE* FESPONSIEILlTY rs-in NOTE I AU. CORRUGATED CARTON CLOSURES TO If m ACCORDANCE with RUtt l OF TMC UNIFORM FRCIOmT classification UCTMOO S OFTIONAI unless otherwise SFEOFIEO. 1973 SERVICE MANUAL DRUM BRAKES 5-5 (3) Place proper spacer gauge on pedal blade or push rod. (41 Slide switch assembly toward pedal blade or push rod until switch plunger is fully depressed against spacer gauge ion heavy duty or stop light/ speed control switches, depress plunger until switch body contacts spacer gaugei. (51 Re-tighten switch bracket screw to 95 inch pounds. i6) Remove spacer. DRUM BRAKES INOEX Page Brake Drum Removal.................................................. 7 Front Brake Drums...................."......................... 7 Rear Brake Drums.................................................... 7 Brake Shoe Removal................................................... 7 Front Brake Shoes.............................................. 7 Rear Brake Shoes ....................................... 8 Brake Drum Installation............................................ 12 Front Brake Drums.............................................. 12 Rear Brake Drums .............................................. 12 Page Brake Shoe Installation.......................................... .10 Front Brake Shoes.............................. 10 Rear Brake Shoes............................................... 11 Cleaning and Inspection........................................ 8 Drum Brake--Special Tools.................................. 88 General Information .................................. 5 Grinding and Refacing Recommenaations............. 9 Service Diagnosis ................................................... 5 Tool Identification Picture ...'............................... 88 GENERAL INFORMATION Front drum brakes are used on certain V*L models only. All drum brake applications are two shoe, in ternal expanding brakes with application adjusters. The lower ends of the brake shoes are connected by a tubular star wheel adjusting screw (Figs. 1, 4 and 5). DRUM BRAKES Condition PEDAL GOES TO FLOOR SPONGY BRAKE PEDAL BRAKES PULLING SQUEALING BRAKES SERVICE DIAGNOSIS Possible Cause Correction (a) Fluid low in reservoir. (b) Air in hydraulic brake system. (c) Improperly adjusted brake. (d) Leaking wheel cylinders. (e) Loose or broken brake lines. (0 Leaking or worn master cylinder, (g) Excessively worn brake lining. (a) Fill and bleed master cylinder. (b) Fill and bleed hydraulic brake sys tem. (c) Repair or replace self-adjuster as re quired. (d) Recondition or replace wheel cylinder and replace both brake shoes. (e) Tighten all brake fittings or replace brake line. (0 Recondition or replace master cylinder and bleed hydraulic system. (g) Reline and adjust brakes. (a) Air in hydraulic system. i) Fill master cylinder and bleed hy draulic system. (b) Improper brake fluid (low boiling >) Drain, flush and refill with brake point). fluid. ....... * : (c) Excessively worn or cracked brake drums. (d) Broken pedal pivot bushing. (d) Replace nylon pivot bushing. (a) Contaminated lining. (b) Front end out of alignment (c) Incorrect brake adjustment. (d) Unmatched brake lining. (e) Brake shoes distorted. If) Restricted brake hose or line, (g) Broken rear spring. (a) Replace contaminated brake lining. (b) Align front end. (c) Adjust brakes and check fluid. (d) Match primary, secondary with same type of lining on alfwjfcels. (e) Reolace faulty brake shoes. (f) Replace plugged hose or brake line. (g) Replace broken spring. (a) Glazed brake lining. (b) Saturated brake lining. (a) Cam grind or replace brake lining. (b) Replace saturated lining. 5*6 DRUM BRAKES Condition Possible Cause Correction (c) Weak or broken brake shoe retaining (cJ Replace retaining spring. spring. (d) Broken or weak brake shoe return (d) Replace return spring. spring. (e) Incorrect brake lining. (e) Install matched brake lining. (f) Distorted brake shoes. (0 Reoiace brake shoes. (g) Bent support plate. (g) Reoiace suoport plate. (h) Dust in brakes or scored brake arums. (h) Blow out brake assembly with com* pressed air and reface brake drums. CHIRPING BRAKES (a) Out of round drum or eccentric axle (a) Repair as necessary, and lubricate flange pilot support plate contact areas (6 plac es). DRAGGING BRAKES (a) Incorrect wheel or parking brake ad* (a) Adjust brakes and check fluid. justment (b) Parking brakes engaged. (b) Release parking brakes. (c) Weak or broken brake shoe return c) Replace brake shoe return spring. soring. ' (d) Brake pedal binding. (d) Free up and lubricate brake pedal and linkage. (e) Master cylinder cup sticking. (e) Recondition master cylinder. (f) Obstructed master cylinder relief (f) Use compressed air and blow out re port. lief port (g) Saturated brake lining. (g) Replace brake lining. (h) Bent or out of round brake drum. (h) Reface or reoiace faulty brake drum. (i) Incorrect stop light switch adjust (i) Adjust stop light switch. ment. HARD PEDAL I (a) Brake booster inoperative. (b) Incorrect brake lining. (c) Restricted brake line.or hose. (d) Frozen brake pedal linkage. (a) Replace brake booster. (b) Install matched brake lining. .(c) Clean out or replace brake line or hose. (d) Free up and lubricate.brake.(inkage. WHEEL LOCKS (a) Contaminated brake lining. (b) Loose or torn brake lining. (c) Wheel cylinder cups sticking. (d) Incorrect wheel bearing adjustment. (a) Reline both front or rears of all four brakes. (b) Replace brake lining. (c) Recondition or replace wheel cylin* der. id) Clean, pack and adjust wheel bear ings. BRAKES FADE (HIGH SPEEO) (a) Incorrect lining. (b) Overheated brake drums. (c) Incorrect* brake fluid (low temperature). (d) Saturated brake lining. (a) Replace lining. (b) Inspect fordragging brakes. (c) Drain flush, refill and bleed hydraulic brake system. (d) Reline both front or rear or all four brakes. SURGE Below...15 M* PH. . , CHATTER 80 to 40 MPH . (a) Bent or out of round rear brake drum, (a) Reface or replace brake drum. .*. ... . . <( * . (a) Bent or out of round front brake drum, (a) Reface or replace brake drum. SHOE KNOCK (a) Machine grooves in contact face of (a) Sand, reface or replace brake drum, brake drum. (b) Weak hold down springs. (b) Replace hold down s^rin^s. AKES DO NOT SELF aOJUST (a) Adjuster screw frozen in thread. (a) Clean and free-up all thread areas. (b) Adjuster screw corroded at thrust (b) Clean threads and replace thrust washer. washer if necessary. (c) Adjuster lever does not engage star (c) Repair, free up or replace adjuster as wneel. required. " (d) Adjuster installed on wrong wheel. (d) Install correct adjuster parts. DRUM BRAKES 5-7 SERVICE PROCEDURES The eleven inch brakes used on taxi vehicles. (Fig. 6) ire equipped with manual adjusters. The service procedures covering these brakes are identical to the passenger car. with the exception of reference to ap plication adjusters. Illustrations of the various service procedures will not always show any one specific brake. BRAKE DRUM REMOVAL Removing Front Brake Drums--{Nine inch brake only) To aid in brake drum removal loosen brake star adjusting wheel. d) Remove rear plug from brake adjusting access hole. (2) Insert a thin screwdriver into brake adjusting hole and push adjusting lever away from star adjust ing wheel. Care should be taken not to bend adjust ing lever. (3) Insert Tool C-3784 into brake adjusting hole and engage notches of brake adjusting star wheel. 'elease brake adjustment by prying down with ad'fisting tooL . (4) Remove wheel cover, grease cap, cotter pin, ANCHOR WHEEL CYLINDER DUST BOOT ANCHOR PLATE lock, adjusting nut. outer wheel bearing and remove wheel and drum assembly from spindle to expose brake linings iFig. 11. <51 Inspect brake lining for wear, shoe alignment, or contamination from grease or brake fluid. Removing Rear Brake Drums (1) Remove rear plug from brake adjusting access hole. (2) Insert a thin screwdriver into brake adjusting hole and hold adjusting lever away from notches of adjusting screw. (3) Insert Tool C-3784 into brake adjusting hole and engage notches of brake adjusting screw. Release brake by prying down with adjusting tooL (4) Remove rear wheel and clips from wheel studs that holds drum on axle. Discard clips. Remove drums. (5) Inspect brake lining for wear, shoe alignment or contamination from grease or brake fluid. BRAKE SHOE REMOVAL Removing Front Brake Shoes (1) Using Tool C-378S remove brake shoe letuin ANCHOR PLATE PRIMARY RETURN SPRING SHOE TABS (31 SHOE CABLE GUIDE SHOE RETAINERS. SPRING AND NAIL ASSEMBLY PRIMARY RETURN SPRING CABLE GUIDE ANTI-RATTLE SPRING STRUT PRIMARY SHOE AND UNING c; r--1 *>' i: . - SECONDARY SHOE AND UNING AUTOMATIC ADJUSTER SPRING SUPPORT PLATE PRIMARY SHOE AND LINING LEVER SPRING SUPPORT PLATE ADJUSTING LEVER AOJUSTER SCREW ASSEMBLY (STAR WHEEL) LEFT fRONT SUPPORT PLATE AUTOMATIC AOJUSTER SPRING LEFT REAR Fig. I--Nine inch Brake Atsembllet PARKING BRAKE LEVER SHOE RETAINERS, 'SPRING AND' NAIL Y AOJUSTER OVERLOAD ..SPRING - SECONDARY SHOE ANO UNING ADJUSTING LEVER SyjEfORT PLATE AOJUSTER SCREW'* ASSEMBLY .'STAR WHEEL) P8S0& i * * onar\c springs (Fig. 2). (Note how secondary spring over-, laps primary spring), (Fig. i). i"\ Slide eve of automatic adjuster cable n:f an chor ar.d unhook from adjusting lever. Kemcve cable, overload spnr.s. cable guide and anchor plate. 31 Disengage adjusting lever from spring by slid ing forward to clear pivot then working cut from under spring. Remove spring from pivot Remove au tomatic adjuster spring from secondary shoe web and disengage from primary shoe tveb. Remove spring. 41 Remove brake shoe retainers, springs and nails, using Tool C-4070. *Fig. 31. .51 Remove primary and secondary shoes from sup port Remove adjusting star wheel screw assembly from shoes. .:...>..-.r..p>"isso:u:r=i * . ,,.* Iv*' * *. Removing Rear Brake Shoes (1) Remove rear wheel, and drum retaining clips. Remove drum. 21 Using Tool C-3785. remove brake shoe return springs `Fig. 7). (Note how secondary spring over laps primary spring) (Fies. 1. 4. 5 or 61. 3) Slide eye of automatic adjuster cable off an chor and then unhook from adjusting lever. Remove cable, overload spring, cable guide and anchor plate. (4) Disengage adjusting lever from spring by slid ing forward to clear pivot then working out from under spring. Remove spring from pivot Remove au tomatic adjuster spring from secondary shoe web and ngage from primary shoe web. Remove spring. ~\5) Disengage primary and secondary shoes from push rods (if so equipped) and remove adjusting star wheel assembly from shoes. (6) Spread anchor ends of primary and secondary shoes and remove parking brake lever strut and anti- rattle spring (Fig. i 3). (7) Remove brake shoe retainers, springs and nails. Using Tool C-4070, (Fig. 8), and remove from *** f r ADJUSTER SPRING LEVR SPRING PfUO fig. 3--Removing or Installing Shoo Retainers, Spring end Noils (Right front) support. (8) Disengage parking brake cable from parking brake lever. CLEANING AND INSPECTION Wipe or brush clean (dry) the metal portions of the brake shoes. Examine the lining contact pattern to determine if the shoes are bent The lining should PRIMARY ANCHOR PLATE RETURN SECONDARY SPRING RETURN SPRING PRIMARY SHOE AND UNING ANTI RATTtE SPRING STRUT SHOE TAB (3) CABLE GUIOE SHOE RETAINERS, AND SPRING NAIL ASSEMBLY fig. 3--Removing Shoe Return Springs iLcit frond SO//- PRIMARY SHOE AND LINING AUTOMATIC ADJUSTER SPRING SUPPORT PLATE PARKING BRAKE LEVER SECONDARY SHOE AND UNING ADJUSTER SCREW LEVER SPRING ASSEMBLY ADJUSTER `STAR WHEEL) LEVER OYERIOAO SPRING ,E*T Pfill fig. p--7en Inch erako Assembly--(Rear) - 5-S DRUM BRAKES---------------------------------------- ies (Fig. 21. (Note how secondary spring over laps primary spring). iFig. 1). <2) Slide eye of automatic adjuster cable off an chor and unhook from adjusting lever. Remove cable, overload spring, cable guide and anchor plate. 3) Disengage adjusting lever from spring by slid ing forward to clear pivot, then working out from under soring. Remove spring from pivot. Remove au tomatic adiuster spring from secondary shoe web and disengage from primary shoe web. Remove spring. i4) Remove brake shoe retainers, springs and nails, using Tool C-1070. (Fig. 3). <51 Remove primary and secondary shoes from sup port. Remove adjusting star wheel screw assembly from shoes. Removing Rear Brake Shoes <11 Remove rear wheel, and drum retaining clips. Remove drum. 21 Using Tool C-3785. remove brake shoe return springs (Fig. "1. (Note how secondary spring over laps primary spring) (Figs. 1. 4. 5 or 61. (3) Slide eye of automatic adjuster cabl.e off an chor and then unhook from adjusting lever. Remove cable, overload spring, cable guide and anchor plate. Disengage adjusting lever from spring by slid ing rward to clear pivot, then working out from undpr spring. Remove spring from pivot Remove au tomatic adjuster spring from secondary shoe web and disengage from primary shoe web. Remove spring. (5) Disengage primary and secondary shoes from push rods (if so equipped) and remove adjusting star wheel assembly from shoes. i6) Spread anchor ends of primary and secondary shoes and remove parking brake'lever strut and anti.attle spring (Fig. 13). (7) Remove brake shoe retainers, springs and Tails. Using Tool C-4070, (Fig. 8), and remove from fig. 3--Removing or installing Shoe Rotainen, Spring and Neils (Right frontI support. (8) Disengage parking brake cable from parking brake lever. CLEANING AND INSPECTION Wipe or brush clean (dry) the metal portions of the brake shoes. Examine the lining contact pattern to determine if the shoes are bent. The lining should PRIMARY ANCHOR PLATE RETURN SECONDARY SPRING RETURN SHOE SPRING TAB (3) PRIMARY LOCK / /CABLE GUIDE SHOE AND LINING ANTI RATTLE SPRING SHOE RETAINERS. AND SPRING NAIL ASSEMBLY STRUT fig. 3--Removing Shoe Return Sprir' * (Left front) PRIMARY SHOE AND LINING AUTOMATIC AOJUSTER SPRING SUPPORT PLATE PARKING BRAKE LEVER SECONDARY SHOE rf^O LINING AOJUSTER SCREW LEVER SPRING ASSEMBLY AOJUSTER (STAR WHEEU LEVER OVERLOAD SPRING LEFT REAR PFU1 fig. 4--Ton Inti "rake Auembly--(Rear) 5-10 DRUM BRAKES SOCKET SCREW THREAOS SUTTON NUT fig. 9-Adjrtf Screw Aiumbly PBJ10 they are to be used with to insure that they have the recommended radius grind. This grind, which should provide at least .004 inch heel and toe clearance, is necessary for proper lining to drum contact during brake application. ACTION: When resurfacing or refacing brake shoes follow manufacturing recommendations for proper use of their equipment. Whatever equipment is used, ensure that proper ventilation is provided to remove asbestos dust, which can be detrimental to health. Drum Refacing--Measure the drum runout and di ameter with an accurate gauge. There should be no 'ariation in the drum diameter greater than .002 inch. Drum runout should not exceed .006 inch out of rbund. If the drum runout or diameter variation ex ceed these values the drum should be refaced. Re move only as much material as is necessary to clean up the drum. It is recommended the front drums be refaced with the wheel and tire mounted. Do not reface more than .060 inch over the standard drum diameter. NOTE: AH drums will show markings of maximum allowable diameter (Fig. 101. For example, a nine inch drum will have a marking of MAX. DIA. 9.090". This mart:;r.g includes .030" for allowable drum wear be yond the recommended .060" of drum refacing. BRAKE SHOE INSTALLATION Installing Front Brake Shoes Lubricate with a thin film the shoe tab contact area (6 places) on support plate with Chrysler Parts Multi- Purpose Grease, Part number 2932524 or equivalent (Fig. li). W -W (1) Match a primary with a secondary brake shoe and place them in their relative position on a work bench. <21 Install adjusting star wheel assembly between "^mary and secondary shoes, with a star wheel next :ondary shoe (Fig. 1). The left star wheel adjusting stud end is stamped indicating us position on the vehicle) and is also '.aamium pisted. Thenght star wheel is black, and the FF444 fig. 10--Nine Inch Drum--Maximum Diameter Identification adjusting stud end is hot stamped. (3) Install adjuster spring in primary shoe and hook other end in web of secondary. Instill adjusting lever spring over pivot pin on shoe web. Install adjust ing lever under spring and over pivot pin. Slide lever slightly rearward to lock in position (Fig. 1). (4) Spread anchor ends of brake shoe to hold star adjusting wheel assembly in position. (5) Holding brake shoes firmly, place assembly on support plate, and at the same time engage shoe webs with wheel cylinder pistons (Fig. 121. (6) Using Tool C-4070, install shoe retaining nails, springs and retainers. (Fig. 6). (7) Install anchor plate over anchor. fig. f I--Shoe C-'lort Area on Support PRIMARY SHOE RETURN Sr RING IAS Of anti. RATTl! SPRING ORUM BRAKES 5-11 ANCHOR plate AOJUSTEft CABLE STRUT fig. 12--Installing Broke Shoes--(left frontl (8) Slide -eye'' of adjusting cable over anchor and against anchor plate. Engage end of primary shoe return spring in shoe web and install other end over anchor, using Tool C-3785. '*(9) Install cable guide in secondary shoe web. Hold- guide in position, engage secondary shoe return -a airing, through guide and into web. Install other end cnrer inchor, using Tool C-3785. (Be sure cable guide .Jjjemaim flat against shoe web. and that secondary ` spring overlaps primary) (Fig. 1). Using pliers, squeeze ends of spring loops (around anchor) until parallel. . (10) Thread adjuster cable over guide and hook end of overload spring in lever (Fig. 1). iBe sure feye" oi cable is pulled tight against anchor and in a straight line with guide). Installing Rear Brake Shoes ^Lubricate with a thin film the shoe tab contact area (( places) on support plate with Chrysler Parts Multi- Purpose Grease. Part number 2932524 or equivalent (Fig. ll). , '.(1) Install parking brake lever on inner side of secondary shoe web after lubricating pivot with sup- .port plate lubricant Secure with wave washer and '* horseshoe clip. (2) Engage parking brake lever with cable, then slide secondary shoe against support plate, and at the same time engage shoe web with push rod. (if so equipped) and against anchor. Slide parking brake strut behind hub and into .i parking brake lever. Slide anti-rattle spring over free end of strut (Fig. 13). On ten inch brakes, be sure spring ub is pointing rearward and up on outside of shoe web (Left Brake), ana pointing front ward ana down behind shoe web (Rich* Brakei (Fig. PRIMARY SHOE ANO LINING NU245 fig. 13--Removing or Installing Parking Brake Strut and Spring--t Loft Heart 13). On eleven inch brakes, be sure spring tab is pointing forward, down and inside of shoe web (both Left and Right Brake) (Fig. 51. (4) Slide primary shoe into position and engage with push rod (if so equipped) and free end of strut. Install anchor plate over anchor, then install eye of adjuster cable over anchor (Fig. 14). (5) Engage primary shoe return spring in web. of shoe and install free end over anchor, using TooL C-3785. (Fig. 7). (6) Install cable guide in secondary shoe* web! Holding in position, engage secondary shoe return spring through guide and into web. Install other end over anchor, using Tool C-3785. (Be sure cable guide remains flat against shoe web and that secondary spring overlaps primary) (Fig. 1). Using pliers, squeeze ends of spring loops (around anchor) until parallel. * PRIMARY SHOE RETURN SPRING ANCHOR PLATE WAVJ. WASHER HORSESHOE TAB Of ANTI-RATTIE) spring; PRIMARY SHOE ANO LINING fig. M--Installing ADJUSTER CABLE RETAINING NAIU____ ;l^ 'secondly SHOE ANO LINING 'WST ake Shoes--/Left Rear) % - 5-12 MASTER CYLINDER----------------------------- <7) Install adjusting star wheel assembly between primary and secondary shoes, with star wheel next to secondary shoe (Fig. 11. The left star wheel adjusting stud end is stamped "L" (indicating its position on the vehicle) and is also cadium plated. The right star wheel is black, and the adjusting stud end is not stamped. Install adjuster spring between shoes iFigs. 1. 4 and 5i. lEngage primary shoe first). (Eleven inch brakes, install adjuster spring with coil forward, op posite adjuster lever. Fig. 5). 8) Install adjusting lever spring over pivot pin on shoe web. Install adjusting lever under spring and over pivot pin. Slide lever slightly rearward to lock in position. (9) Using Tool C-4070. install shoe retaining nails, retainers and springs (Fig. 81. 10) Thread adjuster cable over guide and hook end of overload spring in lever iFig. 11. (Be sure eye of cable is pulled tight against anchor and in a straight line with guide). BRAKE DRUM INSTALLATION Installing Front Brake Drums (1) Lubricate wheel bearings and install brake drum and adjust wheel bearing to proper preload. (2) Adjust brakes as described under "Service Ad justments'* at front of this Group. Installing Rear Brake Drums (1) Install brake drum. Reinstallation of retaining clips is not necessary. Install wheel and tire assembly. (2) Adjust brakes as described under "Service Ad justments" at front of this Group. MASTER CYLINDER INDEX Page Bleeding Master Cylinder...................................... 15 Cleaning and Inspection........................................ 14 Disassembling Master Cylinder............................. 12 General Information ............................................... 12 Installing Master Cylinder...................................... 15 Master Cylinder Identification Chart........:............ 13 Page Master Cylinder Removal ....................................... 12 Master Cylinder--Special Tools.............................. 89 Reassembling Master Cylinder................................ Id Testing Master Cylinder........................................... 15 Tool identification Picture........................... ....1 89 GENERAL INFORMATION The vehicle identification number on the instrument warning switch tee and the front brakes. This system panel starts with a capital letter which indicates the is referred to as PRIMARY (marked F). The master carline or sales name of vehicle (see Introduction of cylinder used on a vehicle not equipped with a power this manual). These code letters are also used to in brake unit is serviced in the same manner as the mas dicate tr.e vehicle to which the service information ter cylinder with a power brake unit with one excep-. applies. tion. the master cylinder for power brakes does not The tandem roaster cylinder (Fig. 1) is of the com include the pushrod. pensating type with the reservoirs cast integrally. The disc brake matter cylinder is different from the The front outlet tube from the ratr cylinder is drum brake master cylinder in reservoir, cover, bait, connected to the hydraulic system warning switch and gasket size, and only THE SECONDARY OUTLET tee and then to the roar brakes. This system is re HAS RESIDUAL PRESSURE VALVE AND SPRING ferred to as SECONDARY (marked R). The roar outlet (Fig. 1). tube from the master cylinder is also connected to the i. SERVICE PROCEDURES oio onffcaa-ro'4 MASTER CYLINDER REMOVAL (1) Disconnect primary and secondary brake tubes 'om master cylinder (residual pressure valves will .ep cylinder from draining the drum brake master cylinder). Install a plug in the rear outlet of the disc brake master cylinder. (2) Remove nuts that attach master cylinder to cowl panel and/or power brake unit (if so equipped). (3) Disconnect pedal push rod (manual brakes) from brake pedal. (4) Slide master cylinder straight out from cowl panel and/or power brake unit (if so equipped). DISASSEMBLING MASTER CYLINDER To disassemble the master cylinder. (Fig. 1) dean outside of master cy ter thoroughly. IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: 95-10261 CA 42 TIMOTHY TINKER and ANN TINKER, his wife. Plaintiffs, -vs- CHRYSLER CORPORATION, BEAVER DAM PRODUCTS CORPORATION formerly known as Chrysler Marine Corporation, et. al. Defendants . _________________________ L NOTICE OF SERVICE OF DEFENDANT'S, CHRYSLER CORPORATION. RESPONSES TO MASTER PRELIMINARY INTERROGATORIES Defendant, CHRYSLER CORPORATION, through undersigned counsel hereby gives Notice of Service of its Responses to Master Preliminary Interrogatories dated June 29, 1995. HERZFELD & RUBIN Suite 400 1901 W. Cypress Creek Road Fort Lauderdale, Florida 33309 (305) 772-3599 Attorneys for Chrysler Corporation and Beaver Dam Products Corporation *- Case No.: 95-10261 CA 42 Tinker v. Chrysler Corp., et. al. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was thisgP7^ day of October, 1995, delivered by mail to DAVID LIPMAN, ESQUIRE, Counsel for Plaintiff, 5901 S.W. 74th Street, Suite 304, Miami, Florida 33143. HERZFELD & RUBIN Suite 400 1901 W. Cypress Creek Road Fort Lauderdale, Florida 33309 (305) 772-3599 Attorneys for Chrysler Corp. and Beaver Dam Products Corp. I. WEISS Jar No. 656976 'cTU 2 T MYRON SHAPIRO JEFFREY B. SHAPIRO * 1CHAELO. LOZOFF FREOO J. MARQUEZ-STERUNG V aVIOI. WEISS LUIS R. FK5UEREOO STEPHEN E. NAGIN OAVID M. KRAUSECAROLYN A PICKARD ALICE E. WARWICK DANIEL L. KOCH MITCHELL R. KATZ LARRY E. METZ FELICIA M. WITT BRIAN KEITH McOUFFIE JEFFREY M. BELL BRIAN S. ADLER LAUREN S. BERMAN ROBIN I. WILLNER KENNETH O. BAXTER KATHLEEN M. McOONOUGH DONALD R. SIMPSON TERESA J. URDA ALSO ADMITTED IN NEW YORK - ALSO ADMITTED IN COLORADO LAW OFFICES OF Herzfeld & Rubin QULF ATLANTIC CENTER 1901 WEST CYPRESS CREEK RO. SUITE 400 FT. LAUDERDALE. FLORIDA 33309 TELEPHONE: (305) 772-3599 TELEFAX: (305) 772-2469 October 2, 1995 MIAMI OFFICE 801 BRICKELL AVENUE SUITE 1501 MIAMI. FLORIOA 33131 (305)361-7999 TAMPA OFFICE BARR. MURMAN. TONELU HERZFELD 4 RUBIN 201 EAST KENNEDY 6LVO.. SUITE 901 tampa. Florida 33602 (813)223-3951 ORLANDO OFFICE DC)CCIO. HERZFELD 6 RUBIN 20 NORTH ORANGE AVE.. SUITE 807 ORLANDO. FLORIDA 32901 (407)641-6391 JACKSONVILLE OFFICE BULLOCK. CHILDS. PENDLEY. REED. HERZFELD 4 RUBIN BLACKSTONE BUILDING 233 EAST BAY STREET. SUITE 711 JACKSONVILLE. FLORIOA 32202 (904) 3S4-0286 OF COUNSEL MARVIN I. WIENER. P.A. BRIAN E. INGALLS GREGORY J. RITTER TO ALL COUNSEL: RE: Tinker v. Chrysler Corporation et. al Our File No.: 0303.8112__________ On this date Chrysler Corporation served its Responses to Master Preliminary Interrogatories and Request for Production. If you would like a copy of these responses, please telephone the offices of the undersigned in order to receive same. Very truly yours, DlW/nr Enclosures DAVID I. WEISS HERZFELO 4 RUBIN P.C 40 WALL STREET NEW YORK. NEW YORK 10005 TELEPHONE (212) 344-5500 HERZFELD i RUBIN 1925 CENTURY PARK EAST LOS ANGELES. CALIFORNIA 90067 TELEPHONE (310) SS344S1 HANLON. LAVTGNE. TOPCHIK. HERZFELD A RUBIN 10 PARSONAGE ROAD EDISON. NEW JERSEY 06637 TELEPHONE MQ.oiw' SERVICE LIST David M. Lipman, Esquire David M. Lipman, P.A, 5901 S.W. 74th Street Miami, Florida 33143 Attorney for Plaintiffs Matthew Kennedy, Esquire Hardy, Bissett & Lipton 2201 Corporate Boulevard N.W. Suite 205 Boca Raton, Florida 33431 Attorneys for GM/Detroit Deisel David H. Pollack, Esquire Barnett Bank Building 420 Lincoln Road Suite 335 Miami Beach, Florida 33139 Attorneys for Plaintiffs Virginia Johnson, Esquire Broad & Cassel 3000 Miami Center 201 South Biscayne Boulevard Miami, Florida 33131 Attorneys for W.R. Grace M. Stephen Smith, Esquire Rumberger, Kirk, et. al. Two S. Biscayne Boulevard Suite 3100 Miami, Florida 33131 Attorneys for Garlock Rodd Buell, Esquire Blackwell & Walker, P.A. 2400 Sunbank International Center One S.E. Third Avenue Miami, Florida 33131 Attorneys for Allied Signal Jeffrey M. Bell, Esquire Myron Shapiro, Esquire 1901 W. Cypress Creek Road Suite 400 Ft. Lauderdale, FI 33309 Attorneys for Briggs & Stratton Ben E. Girtman, Esquire 1020 E. Layfayette Street Suite 207 Tallahassee, Florida 32301 Attorney for Abex Steven Y. Leinicke, Esquire Wicker, Smith 1 E. Broward Boulevard, 5th FI Ft. Lauderdale, FI 33301 Attorney for Rechtein International and International Harvester (Navistar) Chris N. Kolos, Esquire Cabannis, Burge & Wagner Suite 1800, 800 N. Magnolia Ave. Orlando, Florida 32802 Attorneys for Ford & Mack Trucks Robert D. Brown, Esquire Akerman, Senterfitt & Eidson 801 Brickell Avenue 24th Floor Miami, Florida 33131 Attorneys for Carlisle Companies Gordon James, III, Esquire Conrad, Schrer & James P. O. Box 14723 Fort Lauderdale, Florida 33302 Attorney for Caterpillar Susan Kent, Esquire Scott Cole, Esquire Walton, Lantaff, et. al. 2 South Biscayne Boulevard 25th Floor Miami, Florida 33131 Attorneys for Fel-Pro, Inc. and Kohler Tom Schulte, Esquire Lee, Schulte & Eaton 1001 N. Hwy US No. 1 Suite 500 Jupiter, Florida 33477 Attorneys for Wagner Electric Jeffrey Tew, Esquire Kirkpatrick & Lockhart 201 South Biscayne Boulevard 2000 Miami Center Miami, Florida 33131 Attorneys for Teledyne, Inc. Tracy Tomlin, Esquire Otero, Mullin & Tomlin, P.A. 75 Valencia Avenue Coral Gables, Florida 33134 Attorney for Brockway James M. Redmond, Esquire Wicker, Smith, et. al. 2900 Middle Street Miami, Florida 33133 Attorneys for Deere & Co. and Oshkosh Ronald E. Solomon, Esquire 633 S. Federal Highway 7th Floor Fort Lauderdale, Florida 33302 Attorneys for Volvo GM Heavy Truck Corp. Virginia Forbes, Esquire Stephens, Lynn, et. al. 9100 South Dadeland Boulevard Suite 1500 Miami, Florida 33156 Attorneys for Peterbilt Motors Co. and Kenworth Trucks Harold Morlan, II, Esquire Boroughs, Grimm, et. al. P.0. Box 3309 Orlando, Florida 32802 Attorneys for Dresser Thomas Campion, Esquire Shanley & Fisher, P.A. 131 Madison Avenue Morristown, New Jersey 07960 Co-Counsel for Allied Signal Timothy Clark, Esquire Law Offices of Timothy Clark New World Tower 100 North Biscayne Boulevard Suite 1207 Miami, Florida 33132 Attorney for Lipe-Rollway Corp. Don McClean, Esquire Arent, Fox, Kitner, et. al. 1050 Connecticut Avenue, N.W. Washington, D.C. 20036-5339 Co-Counsel for Fel-Pro Susan Cole, Esquire Blaire & Cole 2801 Ponce de Leon Boulevard Coral Gables, Florida 33134 Medical Counsel Dan Casey, Esquire Kirkpatrick & Lockhart 2000 Miami Center 201 S. Biscayne Boulevard Miami, Florida 33131 Attorneys for Continental/Teledyne H. Roger Lutz, Esquire Charles TeleFair One Sarasota Tower Suite 500 2 North Tamiami Trail Sarasota, Florida 34236 Attorneys for McCord, Clevite, J.P. Industries