Document Qkeo6z00v9kjaka9K5JNzQLYv

FILE NAME Cape Asbestos CAPE DATE 1982 Nov 4 DOC CAPE127 DOCUMENT DESCRIPTION Legal - North American Corp. Answers to Plaintiff's Request for Production Legal - Tibbs Case Exhibit 25 C DISTRICT COURT BOULDER IN PE ASBESTOS CASE NO LOUIS PACELLO Plaintif CAST NO 0069 V. MANVILLE MANVILLE SALES CORPORATION successor by merger to PRODUCTS CORPORATION et al Defendants NOV 24 24 1962 NORTH AMERICAN ASBESTOS CORPORATION ANSWERS TO PLAINTIFF'S REQUEST FOR PRODUCTION OPENING STATEMENT NORTH AMERICAN was formed in 1953 for the purpose of expediting and facilitating the movement of raw crocidolite asbestos sold by Cape Blue Mines Pty Ltd. of Koegas and Pomfret South Africa and raw amosite asbestos sold by EGNEP Pty Ltd. of Penge South Africa as well as for the sale of raw asbestos and certain asbestos products such as rope yarns and cloth purchased from other sources The company was essentially a man operation consisting of a president representative and four office clerical personnel Robert Cryor now deceased acted in the capacity as president and director of the corporation from 1953 through 1970. Mr. C. G. Morgan acted as Director and Chief Sales Representative from December 1 1971 through May 19 1978 and was President from June 10 1974 through May 19 1978. The company was voluntarily dissolved on May 19 1978 NORTH AMERICAN operated a small experimental manufacturing facility at 500 McKinley Mundelein Illinois from time to time during the years of 1963 through 1966. This operation produced an experimental basis an asbestos like product sold under the name of Noramite and was used primarily in the plastics and space industries The great majority of Noramite produced at the Mundelein facility was sold to a single customer California The company has not been in existence since May 19 1978 and has had no officers directors of employees since that date who can provide personal knowledge as to the company's affairs The information which formed the basis of the Defendant's 6 6-80 CAPEG00119 @ C C Answers herein herein Trustee Illinois Mr. Max Max 60603 60603 of the said trustee trustee existing business records gathored by counsel for the Liquidating 115 South LaSalle Street Chicago besed part information derived of in information NORTH on derived the personel knowledge by counsel From AMERICAN now in custody of counsel Many of the company's company's are now unavailable Records of purchases and sales company for the peric~ 1963 through 1967 were 1970 at the time the company moved to new and smaller Drive Chicago Illinois at 150 South Wacker AMERICAN Will permit Plaintiff to inspect and copy its remaining business records upon receipt of an appropriate document request therefor 1 The records and books of NAAC in the control and custody of Mary G. Oppenheim information Wasbington Street Chicago Illinois customers about names_and_locations names_and_locations Liquidating Receiver which contain of Defendant's West information for products quantity asbestos or containing the of insulation dis tributed to the State of Colorado and sold or used in the State of Colorado and the number or amount of products State of distributed to Colorado which the State of Colorado and sold in contain or are manufactured with the asbestos asbestos and which products would include products other than insulation insulation RESPONSE See opening statement The files and records of NAAC will be made available to you upon receipt of proper notice.- 2. All NAAC insurance policies where the company is the insured insured on a liability insurance policy incident referred to in the Complaint that would cover the RESPONSE The files and records of NAAC will be made available to you upon receipt of proper notice - oo 20 66-80 CAPE0001T C SINCE OP TLLINGIS) 1 SS SS COUNTY OF COOK ) OPPENHEIM who she is the Liquidating Receiver of the NORTH AMERICAN ASBESTOS CORPORATION Liquidating Trust Trust that the NORTH CORPORATION has been dissolved and liquidateliquidadted that that that that as liquidating Receiver of the Liquidating Trust she has custody of the existing business records of NORTH AMERICAN AASBESTOS SBESTOS CORPORATION and hes knowledge of the said files and records to the extent they are available as set forth in Exhibit A to NORTH AMERICAN's Answers herein In the course of the preparation of these Answers she examined the files and records of the corporation or caused the same to be examined and that she has read the foregoing Answers and based upon the aforesaid records of the corporation the same are true and correct to the best of her information and belief ---- ----,----, Mary G. Oppenheim Subscribed and sworn to before me this fe day of Pace 1932 Adrienne file AdriAdrieenne nfinlee Notary Public dz 66-80 CAPE000112