Document REaB2KJxQZ6r0XqkjNVk4XeX

Gorr, Moser, Dell s Louchney attorneys at law 1300 FRICK BUILDING Pittsburgh. Pennsylvania 15219 TELEPHONE 412/471-1180 FAX 412/471-9012 VLSTMCRELAND COUNTY OFflCI 412/636*5959 DONALD J. McCORMICK PETER MOUNARO. JR. PATRICK I. LOUCHNEY* RICHARD W. DELL MELVIN L MOSER'* ARTHUR R. GORR' CARL HUDSON SHELLY' ELEONORA M. ZYCH SEAN P. HANNON MARK R. LANE' JOHN H. WILLIAMS, IR. ANDREA R. BARTER* .ALSO ADMITTED fN W '.ALSO ADMITTED fN W AND FL ALSO ADMITTED IN OH February 18, 1994 File No. KMT m Cathy S. Gatson, Clerk of Court Kanawha County Courthouse P.O. Box 2351 Charleston, WV 25328 RE: Asbestos III, Civil Action 92-C-8888 Dear Ms. Gatson: Enclosed for filing please find a Notice of Service of Plibrico's Answers and Objections to all Plaintiffs' October 20, 1993 Joint Interrogatories and Request for Production Directed to all Defendants. Copies of the Answers have been sent to all plaintiffs' counsel. Defense counsel will be provided copies upon request.by contacting Kris Buday. -CHS/keb Enclosure cc: All Counsel IN THE CIRCUIT COURT OF KANAWHA COUNTY, WEST VIRGINIA IN RE: ASBESTOS CASES m CIVIL ACTION NO. 92-C-8888 (Judge MacQueen) NOTICE OF SERVICE I, Carl Hudson Shelly, do hereby certify that I have this 21+4 day of February, 1994, mailed a true copy of Plibrico's Answers and Objections to all Plaintiffs' October 30, 1993 Joint Interrogatories and Request for Production Directed to all Defendants to all plaintiffs' counsel of record in accordance with the Third Amended Consolidated Service List filed with the Clerk of Circuit of Kanawha County on January 11, 1994. GORR, MOSER, DELL & LOUC ounsel for ftitirico Cojpjfany, Defendant Carl Hudson Shelly, Esquire GORR, MOSER, DELL & LOUGHNEY 1300 Frick Building Pittsburgh, PA 15219 (412)471-1180 . JUN 07 1993 Cork, Moser, Dell s Loughney ATTORNEYS AT LAW 1300 FRICK BUILDING ^msBURCH, Pennsylvania 15219 REPHONE 412/471*1180 FAX 412/471-9012 VtSTUOULAND CXXINTT Otna 412/U64SS9 DONALD J. McCORMICX PETER MOUNARO. JR. PATRICK J. LOUGHNEY* RICHARD V. DELL MELVIN I- MOSER** ARTHUR R. CORK* CARL HUDSON SHELLY* ELEONORA M. ZYCH SEAN P. HANNON THOMAS OLLASON MARK R. LANE* JOHN H VILLJAMS, JR. * ALSO AEUJTOD K W ** AlSOADMUTtMNR.W June 4, 1993 File No.: Kanawha Mass m Cathy S. Gatson, Clerk of Court Kanawha County Courthouse 500 Quarrier Street Charleston, WV 25329 RE: In Re: Asbestos m, Civil Action 92-C-8888 Dear Ms. Gatson: Enclosed for filing please find a Certificate of Service of Answers and Objections of Plibrico Company to Plaintiffs' Joint Interrogatories and Request for Production of Documents Concerning Product Identification. Copies of the Answers have been sent to all known counsel of record. Sincerely, PJL/keb Enclosure: cc w/enc: Patrick J. Loughney Certificate of Service Theordore Goldberg, Esquire' James F. Rion, Jr., Esquire Scott S. Segal, Esquire Jofin Sutter, Esquire /ames F. Humphreys, Esquire David L. Meade, Esquire William Field, Esquire All Defense Counsel of Record IN THE CIRCUIT COURT OF KANAWHA COUNTY, WEST VIRGINIA IN RE: ASBESTOS m Civil Action No. 92-C-8888 ANSWERS AND OBJECTIONS OF PLIBRICO COMPANY TO PLAINTIFFS' JOINT INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS CONCERNING PRODUCT IDENTIFICATION TO ALL DEFENDANTS Counsel for Plibrico Company: Arthur R. Gorr, Esquire Patrick J. Loughney, Esquire Carl Hudson Shelly, Esquire GORR, MOSER, DELL & LOUGHNEY 1300 Frick Building Pittsburgh, PA 15219 (412) 471-1180 ANSWERS AND OBJECTIONS OF PLIBRICO COMPANY TO . PLAINTIFFS* JOINT INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS CONCERNING PRODUCT IDENTIFICATION TO ALL DEFENDANTS AND NOW comes Plibrico Company and responds to the Plaintiffs' Joint Interrogatories as follows: Defendant, Plibrico Company objects to each and every Interrogatory in Plaintiffs Joint Interrogatories on the following grounds: A. The Interrogatories are vague, ambiguous, overly broad and unduly burdensome because they seek information which is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; B. The Interrogatories are objectionable to the extent they seek to invade the attomey/client communication privilege or the attorney work product material privilege. C. The Interrogatories seek irrelevant information because they are not limited to the time period of Plaintiffs alleged exposure to asbestos containing materials. D. The Interrogatories are improper because this Defendant has no obligation to provide product identification information in discovery unless and until Plaintiffs have produced direct evidence that Plaintiffs were exposed to an asbestos containing product manufactured or distributed by this Defendant. Plaintiffs have failed to produce such threshold evidence in this case and this Defendant has no automatic obligation to answer discovery relating to products which have not been previously identified by Plaintiffs or any other party to the lawsuit. -2- E. The Interrogatories are unreasonable and unduly burdensome to the extent they seek information from persons who are not now officers, directors or managing agents of this Defendant F. The Interrogatories are improper because they seek information in the abstract and are not limited to specific Plaintiffs and specific time frames. As such, they are overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. G. The Interrogatories are improper to the extent they seek information which is proprietary or a trade secret H. The Interrogatories are objectionable to the extent they seek information concerning non-asbestos containing products manufactured, sold or distributed by Plibrico Company. Without waiving said objections, Plibrico Company submits the following Answers to Plaintiffs' Joint Interrogatories. INTERROGATORIES 1. Identify each and every asbestos-containing product manufactured, and/or sold, and/or distributed, and/or marketed, and/or supplied, and/or purchased and/or used by defendant at anytime between 1930 and the present, and for each such product provide the following: (a) The date such activity began; (b) The years during which such activity took place; (c) The date when such activity was terminated; -3- (d) If such activity was terminated, the reason(s) why; (e) The geographical area into which you claim the asbestos-containing produces) were sold; (f) Identify the organizational unit of defendant so engaged; (g) The site(s) at which each such product was manufactured, sold purchased or used; (h) The material components/ingredients of each such product, giving specific or approximate percentage both by weight and by volume of each material component/ingredient (this interrogatory is not limited to the asbestos component of the product but seeks information as to the nature, weight and volume of non asbestos ingredients, as well) of each such product; and 0) The specific type of asbestos fiber, i.e., chrysotile, amosite, crocidolite, used as a component of each asbestos-containing product. ANSWER: (a) through (c), For certain time periods, Plibrico manufactured and sold Plicast Airlite and Plicast LWI-24G which contained asbestos. Plicast LWI-24 and other Plicast LWI products never contained asbestos. Plibrico manufactured asbestos-containing Plicast Airlite and Plicast LWI-24G until sometime in 1972; Plicast Airlite and Plicast LWI-24G did not contain asbestos after sometime in 1972. Based on information and belief, the manufacture and sale of both products commenced in the mid 1950s; investigation is continuing. On information and belief, Plibrico commenced the sale of asbestos containing Plisulate Insulating Cements Nos. 101 and 102 from 1963 to 1972, although investigation continues on this issue. Asbestos containing Plisulate Insulating Cements No. 101 and 102 were available nationally until 1972, but Plibrico has no present or actual knowledge on when and where sales of this product were actually made. Upon information and belief, and pursuant to further investigation of corporate records and other information obtained from Keene Corporation, it -4- is believed that Plisulate Insulating Cement No. 101 was manufactured by Keene Corporation t and repackaged under the name "Plibrico Plisulate Insulating Cement No. 101" during the years 1968-1972. Accordingly, Plibrico Company is not in possession of any formula sheets indicating the chemical composition and percentage contribution of the components, as Plibrico did not manufacture this particular product. Counsel for Plibrico are in possession of a description of Keene No. 1 Plus Insulating Cement a/k/a Super 1900 Insulating Cement, a/k/a Plisulate Insulating Cement No. 101, which is advertised as a formula of "a dry mix composed of spun mineral wool nodules and clay", and is "asbestos free." Plibrico has also seen product literature for Pliseal Boiler-Wall Coating, a product which may have contemplated the use of asbestos. However, Plibrico has no information from any source which would confirm or verify that Pliseal Boiler-Wall Coating was ever sold or distributed to any customer, site or facility. If such product was ever sold, it was in extremely limited quantities and did not contain asbestos after sometime in 1972. Plibrico is in possession of formula sheets of another product, Plibrico AR Cement, which specified small quantities of asbestos. However, there is no evidence that there were ever any production runs on this product. No sales records of AR Cement have been located. If such product was ever sold, it was in extremely limited quantities and did not contain asbestos after sometime in 1972. (d) The distribution and sale of all asbestos-containing products manufactured or sold by Plibrico terminated in 1972 because the OSHA regulations regarding asbestos were in place -5- and the company wanted to insure that its products did not contain any potentially hazardous materials. (e) Refer to the attached Summary of Sales in West Virginia and Surrounding Areas, and attached sales records produced. Plibrico products, both non-asbestos-containing products and the asbestos-containing products listed on the Summary of Sales, were sold to customers by wholly-owned subsidiaries of Plibrico and independent distributors. (f) See answer to Interrogatory 1(e). In West Virginia and the surrounding areas (as listed in Interrogatory 8) these were: Plibrico Sales and Service (no longer exists) 1216 Quarrier Street Charleston, WV Plibrico Sales and Service, Inc. 590 E. Western Reserve Road Youngstown, OH 44514 Plibrico Sales & Service Co. Div. of Frank W. Schaefer, Inc. 1500 Humphrey Avenue P.O. Box 1508 Dayton, OH 45401 Plibrico Company (no longer exists) New Castle, PA Plibrico Sales & Service Co. (no longer exists) 300 Mt. Lebanon Blvd. Pittsburgh 34, PA (g) See attached Summary of Sales in West Virginia and Surrounding Areas, and attached sales records produced. (h) Plicast Airlite contained 10% chrysotile asbestos. Plicast LWI-24G contained 1% chiysotile asbestos. Plibrico AR Cement contained 2% chrysotile asbestos. -6- (i)See answer to Interrogatory 1(h). 2. Identify each and every industrial insulation product, aside from those identified in response to Interrogatory No. 1, which were manufactured, and/or marketed, and/or supplied, and/or purchased and/or used by defendant at any time between 1930 and the present, and for each such product provide the following: (a) The date such activity began; (b) The years during which such activity took place; (c) The date when such activity was terminated; (d) . If such activity was terminated, the reason(s) why; (e) The geographical area into which you claim the product(s) were sold, purchased and/or used; (0 Identify the organizational unit of defendant so engaged; (g) The site(s) at which each such product was manufactured; (h) The material components of each such product, giving specific or approximate percentage both by weight and by volume of each material component of each such product; (i) The temperature ranges for which each produces) was intended to be used; O') The product's generic name; (k) The product's trade or brand name; (l) The container in which the product was shipped, (i.e., paper bags, cardboard boxes) including the size and amount of the container; (m) A description of any logos, writing impressions or identifying markings which appeared on the product, as well as a description of the package used, the dates that type of package was used, and any logos, product names, trademarks, etc., which appeared in the package; (n) Whether the word "asbestos" was used on the package; (o) A detailed description of the intended method of preparation and application of the product; and (p) A description of the physical appearance of the product, including size, shape, color and texture. ANSWER: (a) through (p) Objection. The defendant Plibrico objects to this Interrogatory as irrelevant and unlikely to lead to the discovery of relevant evidence since the Kanawha County Mass Trial will only involve asbestos-containing products. Judge MacQueen has specifically ruled that Mass Trial IE will not include non-asbestos-related claims and that no defendant will be required to defend non-asbestos-containing products. Furthermore, the interrogatory is overbroad and burdensome. Subject to this objection, Plibrico manufactured a variety of non-asbestos products, including a soft, pliable," non-asbestos containing fire brick between the years requested in said interrogatory. In addition, counsel for Plibrico has in its possession documents and advertising brochures containing information on these non-asbestos products. Said documentation is available for inspection and copying at the law offices of Gorr, Moser, Dell & Loughney in Pittsburgh, Pennsylvania. 3. Has Defendant engaged in the manufacture, and/or sale, and/or distribution, and/or marketing, and/or supply, and/or purchase and/or use of non-asbestos containing products for use in connection with temperatures above 25 since 1930. If so, please state: (a) The date such activity began; (b) The years during which such activity took place; (c) The date when such activity was terminated; -8- (d) If such activity was terminated, the reason(s) why; (e) The geographical area into which you claim the product(s) were sold, purchased or used; (f) Identify the organizational unit of defendant so engaged; (g) The site(s) at which each such product was manufactured; (h) The material components of each such product, giving specific or approximate percentage both by weight and by volume of each material component of each such product; 0) The temperature ranges for which each produces) was intended to be used; 0) The product's generic name; (k) The product's trade or brand name; (l) The container in which the product was shipped, (i.e., paper bags, cardboard boxes) including the size and amount of the container; (m) A description of any logos, writing impressions or identifying markings which appeared on the product, as well as a description of the package used, the dates that type of package was used, and any logos, product names, trademarks, etc., which appeared in the package); (n) Whether the word "asbestos" was used on the package; (o) A detailed description of the intended method of preparation and application of the product; and (p) A description of the physical appearance of the product, including size, shape, color and texture. ANSWER: See answer to Interrogatory No. 2. -- 4. Did Defendant ever market or distribute any asbestos-containing product manufactured in whole or in part by someone else? If so, please state the following for each such product: -9- (a) The name and address of the manufacturer; (b) The product's trade and brahd name; (c) The organizational unit of Defendant who did so; (d) Date(s) beginning, ending and during which the marketing or distributing took place; (e) Whether the product was distributed through the same channels as those used for products manufactured by Defendant, and if not, please explain the exact channels of distribution; and (0 Identify all documents relating, to the marketing or distribution. ANSWER: Yes, see answer to Interrogatory No. 1. 5. Did Defendant ever sell or purchase any asbestos containing product and rebrand the product, or allow or cause it to be rebranded. If so, please state the following as to each such rebrand product: (a) The original brand name, trade name and manufacturer of the product; (b) Who performed the physical rebranding and where was it accomplished; (c) Brand name and trade name used after the rebranding; (d) User or seller of the product after rebranding; (e) Dates beginning, ending and during which the rebranding of the product took place; (f) Identify all documents reflecting any terms or conditions incident to the rebranding of a product; and (g) Summarize the financial consideration (including amounts) between the participants in the rebranding arrangement. ANSWER: Yes, see answer to Interrogatory No. 1. -10- 6. For each and every asbestos containing product required to be identified in your answer to Interrogatory No. 1,4, or 5 above, state as to each product the date and quantity sold, supplied or shipped to each of the locations as attached on Exhibit "A" and, if supplied to that location by any entity other than yourself, identify that entity. ANSWER: See Summary of Sales in West Virginia and Surrounding Areas, and attached sales records produced. 7. For each and every asbestos containing product required to be identified in your answer to Interrogatory No. 1, 4 or 5 above, state as to each product the date and quantity used on any jobsite or locations as attached on Exhibit "A" and, if supplied to that location by any entity other than yourself, identify that entity. ANSWER: Yes, see answer to Interrogatory No. 1. Also, see Summary of Sales in West Virginia and Surrounding Areas, and attached sales records produced. 8. Please state whether you sold or distributed asbestos containing products to any wholesaler, distributor, hardware store or other merchant in the following geographical areas: (a) Pittsburgh, Pennsylvania; _ (b) Allegheny County, Pennsylvania; * (c) Washington, Pennsylvania; (d) Washington County, Pennsylvania; (e) Waynesburg, Pennsylvania; (f) Greene County, Pennsylvania; -11- (g) Uniontown, Pennsylvania; (h) Fayette County, Pennsylvania; (i) Connellsville, Pennsylvania; 0) Chambersburg, West Virginia; (k) Franklin County, Pennsylvania; (l) Athens, Ohio; (m) Athens County, Ohio; (n) Cambridge, Ohio; (o) Guernsey County, Ohio; (p) Marieta, Ohio; (q) Washington County, Ohio; (r) Steubenville, Ohio; (s) Jefferson County, Ohio; (t) Cumberland, Maryland; (u) Allegany County, Maryland; (v) Hagerstown, Maryland; (w) Washington County, Maryland; (x) Ashland, Kentucky; (y) Boyd County, Kentucky; (z) Winchester, Virginia; (aa) Frederick County, Virginia -12- ANSWER: Yes, see Summary of Sales in West Virginia and Surrounding Areas, and attached sales records produced. 9. If your answer was affirmative to Interrogatory No. 8 above, please state the following: (a) The name of the business or person to which you distributed or sold products; (b) Their address; and (c) The type and quantity of products sold or distributed. ANSWER: Yes, see Summary of Sales in West Virginia and Surrounding Areas, and attached sales records produced. 10. Please state whether you sold or distributed asbestos containing products to any wholesaler distributor, hardware store or other merchant in the State of West Virginia. ANSWER: Yes, see Summary of Sales in West Virginia and Surrounding Areas, and attached sales records produced. 11. If your answer was affirmative to Interrogatory No. 10 above, please state the following: (a) The name of the business or person to which you distributed or sold products; -*- (b) Their address; and (c) The type and quantity of products sold or distributed. -13- ANSWER: Yes, see Summary of Sales in West Virginia and Surrounding Areas, and attached sales records produced. 12. Have you ever owned or operated a business or portion thereof which engaged in construction, erection or tear out of furnaces, pipes, boiler, turbines, lehrs, etc? If so, please state: (a) The name of said business; (b) The date of commencing business and cessation of business, if applicable; (c) Type of construction or tear our performed; (d) State whether said business installed or supplied asbestos containing products on the furnaces, pipes, boilers, turbines, lehrs, etc., i.e.; gaskets, pipe covering, block, cement, rope, cloth, clothes, etc., containing asbestos, asbestos pipe, board, etc.; (e) State whether said business performed construction, installation or tear out of asbestos containing products at any site listed on Attachment "A"; (f) State the trade name and/or manufacturer of any asbestos containing product which you installed or supplied to any construction site on Attachment "A"; and (g) Provide the dates for the applicable construction, installation or tear-out project. ANSWER: Plibrico Sales and Service did, under certain circumstances, contract to perform the installation of its products in furnaces. The vast majority of these jobs involved the installation of Plibrico non-asbestos plastic firebrick. According to records reviewed, none of these job files with respect to the sites listed in Plaintiffs' Exhibit A or in the geographical regions listed in Interrogatory No. 8 included the use of insulation or asbestos. Nor did the jobs involve the use or installation of any Plibrico asbestos-containing product. -14- REQUEST FOR PRODUCTION OF DOCUMENTS 1. Please produce copies of all records that show sales, receipt, use, re-sold, distribution, inventory, re-order, shipment, bill of loading, or orders of asbestos containing products. ANSWER: SUMMARY OF SALES IN WEST VIRGINIA AND SURROUNDING AREAS To Triangle Conduit and Cable, Glendale, WV one five gallon can of Pliseal, sold 9/20/56. To California State College, California, PA (Washington Co.), thirteen 50-pound bags of Plisulate 101 or 102 cement, shipped 11/8/66. To Bottom House at Weiiton Steel Division, National Steel Corporation, Weirton, WV, fifteen 50-pound bags of Plicast Airlite, shipped 6/17/69. To Site unknown, sold to WV Bureau of Mines, one bag (40 or 50 pounds) of Plicast Airlite, 1/23/70. To Site unknown, sold to WV Bureau of Mines, six bags of Plicast Airlite, 2/9/70. Attached are documents in response to Plaintiffs' Request for Production of Documents. -15- ANSWERS SUBMITTED BY Arthur R. Gorr, Esquire Patrick J. Loughney, Esquire Carl Hudson Shelly, Esquire Gorr, Moser, Dell & Loughney 1300 Frick Building Pittsburgh, PA 15219 Attorneys for Plibrico Company, Defendant STATE OF ILLINOIS COUNTY OF COOK ) ) ) VERIFICATION Now comes ROBERT W. SCHAEFER, JR., and deposes and says that he is Corporate Secretary of defendant, Plibrico Company in the foregoing action; that he has read the foregoing Responses to Plaintiffs' Joint Interrogatories and Request for Production of Documents and that the same are true, to the best of his knowledge, information and belief based on such records of Plibrico Company as are available to him at this time and on statements made to him by employees of Plibrico Company and others believed to have knowledge of relevant Sworn to and subscribed f before me this J * day of , 1993. "OFFICIAL SEAL' ALICE D. McHUGH $ Notary Public Cook County, Illinois. My Commission Expires Sept. 19.1994 j m************ ********************  BILLING ORDER and ASSIGNMENT ' i;or value received, I/we hereby transfer and assign to Plibrico Company the account receivable arising out of the sale described hereafter. I I . I II -- ! II............... ! HI................... --.... 11111, . II !! I Sold To California State College Customer** Order mw10246Q01 PLCASC ATTACH ORIGINAL OROKR Date of Cust. Order_____ requisition No- ad- it em Skipped ToAddress-------City and State. California Same 6375Distributor's Order No. , 15419cw Pa invoice ini XXMgW-TRieiiCATt-QUAgpgqgKK _______________________________ ____ Zonestate--------------- . County- Washington DATE SKIPPED- ttov. 8. 1966 chicago & Firebrjic Shipped From. F. O. B--....- Pittsburgh **LIBRI CO....................... "LIBRICO SUPER........................... i fa.irn^ ..,TMf Baffle Mix MATIRIAU SOLD ClpTrtW* r.iornN* rTART,,,JP 5 Ridi 500 SttLING PRICE - TnTAi >* f f Totm. L f f ClVT CwT, * . .Totai. Ih f tTotav 0 7 A 05 ft. Cwt. do not write here Cwt Cwt, f^ rm-\Arr / &Arj)' l lfAf|- f Totai. Im ft Cwt, f Cwt t IP1BV j LICA^ { iYDATE........................................................ Rir.t Pina Totai l f* TOTM. ? f * Total 1_bb. s a (Vf, * r.wr ft Twt ft r.urr Turr r.WT 3emon Attt.ftrr Drums. Rtvr Total t " e * Turr Tutp 3 EM ON AlR.BET DRUMS. Size____________ Total Lbs. 0 * Cwt. s Cwt. 13 - 50# bags #107. Plu&ylate Cement & $6.55 cwt. TV \v(y> jL L' *\dd Prepaid Freight or Cartage Charges 14.40 < Attach Receipted Freight Bill) ADDITIONAL INSTRUCTIONS FOR INVOICING CONTRACTS. LABOR, OTHER MATERIALS. CTC. yt> r0 ^ NOTE TO CHICAGO* This above material was misquoted on a bid to the State and we did not notice the error until after the order-- was placed .and--it. wa-s. .too-lafce to re-bid same. We quoted the #102 per cwt instead of per bag. We will have to let it go through this way as une state will not ---------change -the-prioe now. ------------------- 77^ 7 V/ i>r i-k. ^--77 distributor's signatureTom. Eichler -- Pittsburgh Office MARKET ANALYSIS. PLEASE CHECK MATERIAL USE. X 4* <51 BOILERS - INCINERATORS REFINERY ft CHEMICAL EQUIPMENT CEMENT MILL INDUSTRIAL DRYERS GYPSUM FURNACES INDUSTRIAL FURNACES STEEL MILL EQUIPMENT f PREPAID FREIGHT To:Pitt ah: rA! Dote 11-Hr66 We are today prepaying freight to the amount of 12. IQ________ ._________ covering shipment of___________________________________________________ shipped to______California State Collage___________________ ' This material was shipped on date of 11-8-66 ____________ From---------------- ftyfertek----------------------- Via---- Ccmnemlal--------- COPY TO CHICAGO OFFICE COPY TO DISTRIBUTOR PLIBRICO COMPANY By------- pda------------------ SHIPPING ORDER PLIBRICO SALES & SERVICE CO .cartons Plibrico STANDARD .cartons Plibrico STANDARD AIR-BOND .cartons Plibrico SUPER .cartons Plibrico SUPER AIR-BOND .cartons Plibrico SUPERAL .cartons Plibrico SUPERAL AIR-BOND .cartons Pliosil STANDARD _cartons Pliosil SUPER __cartons PLI-RAM-SR-60 .cartons PLI-RAM-SR-90 .bags Piicast No. 15 .bags Piicast No. 27 .bags Piicast No. 31 .bags Piicast No. 34 .bags Piicast Hearth Cement .bags Beco-Tumer Baffle-Mix .bags Piicast Hydro-Mix .bags Piicast K-L-Mix .bags Piicast Steel-Mix Above material received in apparent good condition v.. 4,any Name_________ ________________________ Per. .bags Piicast Trowl-Mix .bags Piicast Tuff-Mix .bags Piicast L-W-I-20 A .bags Piicast L-W-I-24 .bags Piicast L-W-I-26 .bags Piicast Tuff-Lite .bags Piicast VERILITE .bags Burner Set .bags Demon Air Set .bags Plistix SUPER .bags Hyrate refractory cement .drumslbs. each Demon Air-Set .drumslbs. each Demon Air-Set .drums. Jbs. each Demon Air-Set /i- .drums PLI-RAM-80 .dnrums PrUL'IA-RAAWMV-1 V - jj r fi. .Date. to IW. *** TO COMMONWEALTH OF PENNSYLVANIA IFORNIA STATE COLLEGE IFORNIA, PENNA. 15419 S. DESTINATION (UNLESS OTHERWISE SPECIFIED} ABOVE________________________ Pierce Supply the Following as Directed SEND ITEMIZED INVOICE IN TRIPLICATE TOi SAME DELIVERY DATE _02_ I 1/14/66 PROPOSAL OPENING DATE 10/20/66 Vcr<wOk> *et Rc*CRit ilOt FOX INSTRUCTIONS DATE NOV. 7. 1966 IDEN. NO. PURCHASE ORDER NO. 10246-01 41 PURCHASE REQUISITION NO. INDEX NO. 1.0246 SERIAL NO. ORGANIZATION UNIT NO. TEL ACT. OBJ. ROUTE OR EQUIP. NO. 67256 PL IBRI CO SALES & SERVICE CO. 615 WASHINGTON ROAD PITTSBURGH, PENNA. 15228 DIRECTOR OF PURCHASES UPPUES ITEM NO. ARTICLE AND DESCRIPTION OR SPECIFICATION NO. AND EFFECTIVE DATE QUANTITY UNIT UNIT PRICE vm~ BAFFLE MIX STANDARD CASTABLE HYD 500 .BS 8.30 RAULIC SETTING, DEVELOPS GOOD STRENGTH WHEN MIXED WITH WATER MAY BE POURED, TAMPED, TROWELED- OR GUNNED. CWT ASBESTOS RETORT CEMENT EXTREMELY 100 .BS 7.80 DURABLE, IRON WILL MELT WHERE THIS CEMENT WILL STAND. BAG DRY ASBESTOS CEMENT FOR INSULATING 50 & PATCHING BV ASBESTOS INSULATING CEMENT - CEMENT 3.93 SHOULD HAVE EXCELLENT INSULATING VA LUE. REASONABLE HARD, WITH SUPERIOR CWT CHARACTERISTICS. 500 .BS 7.80 <1 9* AMOUNT 41.50 7.80 3.93 39.00 LUMP SUM TOTAL 92.23 NET 60 DAYS 15 rr5:rV 0? P^'5 IW EF3SW* CS TO j .MvE .HOW W A-1495 85 HIGHWAYS REQUISITION NO. ACCOUNT CODES FUND DEPT. APPROP. YEAR ACT. LLLL LLLL SYM. ALLOT. ORGAN. 0| IS. 12 6 520 OBJ. PROJ. 390 NUMBER OF REQUISITION LIQUIDATED - AMOUNT OF REQUISITION LIQUIDATED * AMOUNT OF ENCUMBRANCE CODED. PRE-AUDIT POSTED TO REO____ POSTED TO E l E.L. (BXM OR K.P.) SHIPPING ORDER PLIBRICO SALES & SERVICE CO Ship Via- Shipping Date_ .cartons Plibrico STANDARD -cartons Plibrico STANDARD AIR-BOND .cartons Plibrico. SUPER .cartons Plibrico SUPER AIR-BOND .cartons Plibrico SUPERAL .cartons Plibrico SUPERAL AIR-BOND .cartons Pliosil STANDARD --cartons Pliosil SUPER __ cartons PLI-RAM-SR-60 .cartons PLI-RAM-SR-90 .bags Plicast No. 15 .bags Plicast No. 27 .bags Plicast No. 31 .bags Plicast No.'M .bags Plicast Hearth Cement Bags Beco-Tumer Baffle-Mix .bags Plicast Hydro-Mix .bags Plicast K-L-Mix -bags Plicast Steel-Mix Above material received in apparent good condition my Name_________________ Per. -PREPAID No.C^i_2v -Shipment C .bags Plicast Trowl-Mix .bags Plicast Tuff-Mix .bags Plicast L-W-I-20 .bags Plicast L-W-I-24 -bags Plicast L-W-I-26 .bags Plicast Tuff-Lite .bags Plicast VERILITE .bags Burner Set .bags Demon Air Set -bags Plistix SUPER -bags Hyrate refractory cement -drumslbs. each Demon Air-Set .drumslbs. each Demon Air-Set .drumslbs. each Demon Air-Set .drums PLI-RAM-80 .drums PLI-RA^f-90 > _Date_ IMPORTANT - SPECI.`X CONDITIONS TT IS UNLAWFUL FOR THE COMMONWEALTH TO PURCHASE ANY SUPPLIES, EQUIPMENT, OR TERIALS MANUFACTURED IN .NY STATE WHICH PROHIBITS THE SPECIFIC `TION FOR, OR USE , OR ON ITS PUBLIC BUILDINGS, OR OTHER WORKS, OR THE PURCHASE OF SUPPLIES, dqUIFMENT, OR MATERIALS NOT M-NUFACTURED IN SUCH STATE. BIDDER MUST INDICATE FOR EACH ITEM BID UPON THE N.ME 'ND ADDRESS OF THE MANUFACTURER OF THE ITEM, ND THE STATE IN WHICH THE ITEM WAS MANUFACTURED. IF NECESSARY, ATTACH ADDITION L SHEETS TO YOUR BID CONT `INING WE INFORMATION REQUESTED /DOVE, IDENTIFYING S ME BY ITEM NUMBER. FAILURE TO COMPLY WITH THE ABOVE, WILL RESULT IN REJECTION OF YOUR BID. THE COWDNWEALTH M..Y NOT PURCHASE FROM M NUFACTURERS IN THE FOLLOWING ST/.TES: ALASKA ARK USAS HAWAII . MONTANA NEW MEXICO NORTH DAKOTA WYOMING FUERTO RICO NEW JERSEY (paper only) PREPAID FREIGHT To:?n. S. k S.______ mtg. Dnte 11-16.66 We are today prepaying freight to the amount of -$RtPg____________________ covering shipment of n/L c Qilj;: shipped to California State College California. Pa. This material was shipped on date of 11.10-66______________ From . ChipagoVirr Cooner-Jarrett COPY TO CHICAGO OFFICE COPY TO DISTRIBUTOR PLIBRfCO COMPANY By_M. Boeing_________ TOW-T-iTo--r COOPER-JARRETT, >* -C. C,?] 23 S. ESSEX AVE., ORANGE. P/Q~UNIl /l HO OR ORift CARRUR. R*n 0* .. 07051 s s f -j ' Jv C 5T*f Iruimco co l 1 >.} MfCS6`JHY ST CHICAGO IU -NO PCS- -- MSCA'PTIO*- "PMl-i rj -i fRt^Aip.cnucci- W- fro TITO'.--NOT'---.........-- $7*37* 10-871872 THIS IS YOUR nuPUCATE FREIGHT INVOICE STCAUFOftKI* ST An* course 's feASmtiCTCiftKTY ! CAUfMKIA - RATI - MAIL ENCIOSEO . REMITTANCE ADVICE CARD WITH YOUR CHECK U 5AGS KIKCfUU. W08L CftfHT 252 TO: COOPER-JARRETT INC. P. o OX 13} 010110ANGE. N. 1. 13 r- V *at i r tt ;t i at** fit mii **t r.t; a: -*- /* -- n -- *** JK THIS 'S TOUR INVOICE. fCCERAl IAW PCOUIRES PAYMENT WITHIN 7 DA*S .101* WtK ess PAY THIS AMOUNT 1$!;9 lili DUPLICATE FREICHT ILl 8 SHIPPING MEMORANDUM PLIBRICO COMPANY ` ,ed To: CALIFORNIA STATE COLLEGE . WASHINGTON .COUNTI.............._______________ CAUFORNlA^P.ENNSyLVANIA___ ____________ ORDER .#10246-01 ^Distributor ... Car No.. Routing... "AS SOON AS POSSIBLE" Dote Shipped --N07 1966 .. Shipped From... CHICAGO. Invoice No. Shipment No----- G----- 914 Prepaid ' OX Collect D oijantity 1 l DiSCRIPTION 1 13 bags PLISULATE CMENT #101 1 1I 1 1 Shipper's So. Q 914 .Company Agent's No.. CHICAGO, ILL., MlNOV .i9_6i_F-m PLIBRICO COMPANY, nt property described below, in apparent good order, except ai noted (content* and condition of contents of packages unknown), marked, consigned and destined s indicated below, which said carrier (the word carrier being understood throughout this contract as meaning any person or corporation in possession of the property nder the contract) agrees to earry to its usual place of delivery at said destination, if on its route, otherwise to deliver to another carrier on the route to aaid extinction. It is mutually agreed, as to each carrier of all or anv of said property over all or any portion of said route to destination, and as to each party at any me interested in all or any of said property that every service to be performed hereunder shall be subject to all the terms and conditions of the Uniform Domestic ::asght Hill cf Ltding set forth (1) in Official, Southern. Western and Illinois Freight Classifications in effect on the date hereof, if this is a rail or a rainwater lipmcnt, or 12) in the applicable motor carrier clarification or tariff if this is a motor carrier shipment. Shipper hereby certifies that he is fomilior with oil the terms end conditions of the sold bill of lading, Including those os the bock thereof, set forth fa the tessificotSon or tori# which governs the fronsportotion of this shipment, end the said terms end conditions ore hereby agreed te by shipper endaccepted for himself *d his assigns. _______ _______________________ ______ nstgned to. CALIFORNIA STATE COLLEGE WASHINGTON COUNT! (Moll or street oddrew of eoMlaneo--fee purpose of netiftcotlea only,) ORDER *0.0246-01 ttinafion___ CALIFORNIA _su.cfjWKRSnWHIA. .County of__ rt._ Iverlng C,rri,r. acof'ZK <TAf\KeTT _Cr Initial.. .Cr No.. NO. ACKAGES DESCRIPTION OF ARTICLES. SPECIAL MARKS, AND EXCEPTIONS Cartons Plastic Firebrick Bags High Temp. Cement Crums High Temp. Cement (Bonding MortarJ JFIre Clay Saael (Bonding Mortar.) (Fire Clar Basr) Fire Brick drums Boiler Wall Cement Cartons Mineral Rock Wool with binder in solid flat blocks Bags Rough Castings Drums Rough Castings 13 Bags Mineral Wool Cement Iron or Steel Incinerator Pieces--Iron or Steel Incinerator parts WEIGHT (Subject to Cenictien) CLASS CHECK Subject to Section 7 of conditions, OR RATS COLUMN if this shipment ia to be delivered to the consignee without recourse on the consignor, the consignor shall sign the following statement; The carrier shall not make de livery of this shipment without pay ment of freight and all other lawful charges. 650 (Signature of consignor) If charges are to be prepaid, write or stamp here, "To he Prepaid," TTT'-i 4 *yir-i T*r-N A Received X . 10 orply In prepay charge, cc the propci hereon. Agent or Caahier" Per---------------------------------------------------(The aignature t)cro acknowledge* only (he amount pre[>aid.) Charge, Advanced: the shipment move, between two port, by a earner by water, the law require, that the bill ot lading (bail *>*te pr ii is "carric/Ti or slyVper's weight.* TE.--Where the rate i, dependent on value, nhipprr* are lenuiredt'o Hair apccifually in-vrrhine the mrraf'ar-Atc\r^ ' va/uc o( ihc^/hpcriyT agreed or declared value of fhe property / t J / .t J J (/ rreby tpecIlUolly stated by the tbipper f, be not ereeediag. Kj pad BP~ 1MPANY, Shipper.' '" n*M post-office 60rtf at shippor- _dr_ 0 Kingsbury Street, CHICAGO, ILLINOIS 60614 .Agent, Per. mu w>7 LOCAL BIDS-CENTRAL AWARDS . INVITATION - BID PROPOSAL ^ftflMOKVEALTN|0F FERR3YLVARIA - DEPAITMERT OF PROPERTY AID SUPPLIES BUREAU OF PURCHASES Sealed Bids in DUPLICATE, subject to tbe CONDITIONS abown on tbe reverse hereof, will be received by the institution tuundd below until the due tltoe and date Indicated, after which time the bids will be forwarded to tbe Departaeat of Property and Supplies in Hartisburg for award. DUf OATS out TIM* WAILING DATS ITBM* TO * OKLIYaNBO NOB A.KHCT STONBNOOM October 20, 1966 IOlEALtJMfLLkEPUnCSLfiTtCCmCIOToRCTNEOnAINmSFFoOUOmNRRoNWMsISOaAHNiT. IOonN 10-6-66 IMQUI NY NUMSKN 10-10246 California State College California, Pennsylvania 15419 'EM otic*iptton er auticucs quantity 1. Baffle Mix standard castable hydraulic setting develops good strength when mixed vith vater may* be poured* tamped, troweled or gunned. . piiEnco Co. lMfg. Ohio 2 Asbestos Betort Cement extremely durable, iron vill malt where this cement will stand. Plibrico Co. Mfg. Chicago 111 3. Dry asbestos cement for insulating and patbhing. Plibrico Co. Mfg. - Illinoia 4. Asbestos insulating cement - cement should havfi excellent insulating value. Reasonably hard. v^^h^^>eri<grosticld|g characteristics. Illinois Bur' of days required to make delivery after receip 500 100 50 500 of order Failure to answer the above question may disqualify bjLd. Award will be made on total lump sum basis. CASH DISCOUNT OFFERED: VENDOR HEREBY AGREES THAT IN THE EVENT OF AN AWARD IF PAYMENT IS MADE WITHIN SIXTY (60) DAYS AFTER RECEIPT OF MATERIAL, HE WILL OFFER THE COMMONWEALTH A----------52------X DISCOUNT NO BID WILL BE CONSIDERED UNLESS BID PRICE IS FIRM WITHOUT QUALIFICATION. JL11L In covpllancs *ith thi abflve invitation for bid*, and subject to all the condition! thereof, the underaifned offers ssd agrees, if this bid be accepted, to furnish any or all iteaa upon vhich prices art Quoted, at tbe price and at the tlae set opposite each ltea, delirered at tbe polnt(s) as specified. This bid *111 rtBsla fir* to 12/3./ jp -Unless tlae is Halted by bidder, bid vill ratals flra for thirty (30) days. XECUTED AT Pittsburgh Pennsylvania CITY STATE THIS 17th Y - - _ _______________________________ ' >SEAL) lie* i* ink r T* *N KAK AIO/OS AOOtESl SItOi It IN EM0*. MAKE NECCISANY COMECTIOW. ej 10-20-66 Plibrico Sales & Service Co. 615 Washington Road Pittsburgh ,$4, Pennsylvania 15228 OAY OF October it 66 j itle__________ Secretary (OVMCR. PAT*Ca. 0* CMPONATl OTMCtsi ___Coaiaar.dLal.ii.otor._Ee1Company Agent's *. PLIBRICO COMPANY,FIREb,,.CK, 0H10._NPY.S*_i919-------------------------------------------------------- From h< property described below, in apparent good order, except at noted (contents and condition of contents of packages unknown), marked, consigned and destined .s indicated below which said canter (the word carrier being understood throughout this contract as meaning any person or corporation in possession of the property mdrr thr contract) agrees to carry to its u*ual place of delivery at said destination, if on its route, otherwise to deliver to another carrier on the route to said irstination. It is mutually agreed, as to each cairirr of all or any of said property over all or any portion of said route to destination, and as to each party at any ime interested in all or any of said property that every service to be performed hereunder shall be subject to all the terms and conditions of the Uniform Domestic traight Hill of Hading set forth (I) in Official. Southern. Western and Illinois Freight Classifications in effect on the date hereof, if this is a rail or a rathwater hipmem. or (2) in the applicable motor earner classification or tariff if this is a motor carrier shipment. Skipper hereby certifies tket be It familiar witk all Ike terms aad condition* of the sold bill af leding, Including those aa the back thereof, set fertk la the lesstficotiea or tariff which governs the transportation of fhft shipment, aad the sold terms and conditions are hereby agreed ta by shipper aad accepted tor bimsotf nd his assigns._________ ____________ _______________________________________ __________ _______ _____________________________________ ___ (Moll of street oddrost of consignee--Foe pvrpcit of oetificotion only,) n,t9n.do__C^ifoniEi_State..5oll8g# California, Penn* tfin.tion_____________________________________________________________________Stt* ofCounty of. ut,Comnarcial Kotor_Frt Hv.rin, C.rri.r Cor Initial Cor No. NO. 'ACKAGCS DESCRIPTION OF ARTICLES. SFECIAL MARKS. AND EXCEPTIONS Cartons Plastic Firebrick 5 Bags High Temp. Cement Pails High Temp. Cement tFi'tJcu,Me>J 1 Pallet K,M|,e[J Drums High Temp. Cement }*/!e*3c"r*Vo*el^J Fire Brick Pails Boiler Wall Cement Drums Boiler Wall Cement barton,,s Mjnintoelria|1l R||>octkbWloeoko.l with binder Bags Rough Castings Drums Rough Castings Bags Mineral Wool Cement Order ar 10246-01 WEIGHT (Subject ti CsfTsctltn) '500 CLASS CHECK Subjoet to Section 7 of conditions, OR RATE COLUMN if this shipment is to be delivered to the consignee without recourse on the consignor, the consignor shall sign the following statement: The carrier shall not make de- livery of thu (hipment without pay _12.12.42 >mnt of freight and all other lawful 'Charge.. (Signature of consignor) If charges are to be prepaid, write or stamp bore, "To be Prepaid.** Prepaid ------- -------------- Received to apply in prepayment *f the charges oa the property described horeon. Rush Rush Rush - Agent or Cashiar Par .... (The signature hero acknowledges only the amount proputd.l Charges Advanced: * the .hipment move, between two port* by . earlier by water, tbe law requires th.t the bill ol Udine .hill tt.te whether it i* carrier', or .hipper*. weight.* TE.--Where the rate ta dependent on value, .hipper* .re rniuiied to Mate ipctifiially in writing the agreed or declared v.lue o( the property, ogreed or declared value of the property eroby speclftcolly ftoted by the shipper to be not exceeding, __ , ____ ________________ ptr______________________ BWCO^OMPANY, Shipper, ~ ^ rdm *t eOSl'OfltCt aCCfCAS Of ftiipptf. 'BRICK, OHIO .Agent, Per. L__ *k *;1 SHIPPING MEMORANDUM . PLIBRICO COMPANY Sh d T** California M.r.to College Oallfornfli_________________ Penn*_____________________ Date Shipped H-&-66 Shipped From Firebrick f0. v* ' Invoice No.----------------- : Shipment No.__P 1592 A' 4 v Distributor ?ltlsfanrj________________________________ ' - Car No^__; Routing.Conniarala.'l M o tor..-Kri Prepaid Collect OX1" ? vfcjh . GUANTJTY '* DESCKIFTION * 5 Sags Baffle Hix Order tr 10246-01 1 Kooden Pallet SIC 'Tr.3r.ic loa ,.4.` r us. n *. / : -V.;; *' - ' '.''lU.ff**'***......, **?,**!!* i '...'i"/;i**> . ,->*. .V - ,, .**: v.. ^ N i CO Fittsbur# . *- . ` ' ; !*, - :4 i * ! .*{.' * .... . ** "*'* ./I.;- ` ' ' ` - / ' .i ' v- .** .t * : ' :;i. * ." ..;V\ i1 1 * : |7.:- . " v (;*.* - - . .1 . ,f .. ' *:*'- ; ..\**8M** ' ` \ .. .* - .P / " . * , t.i * : , * *1. 'A |. i **.v} ''J'l'u:tUr:."* ! ...-.i: . 1. - -.( | ' :/;5i fi . ?! i J3ILLING ORDER and ASSIGNMENT For value received, I/we hereby transfer end assign to Flibrieo Company the account receivable arising out of the sale described hereafter. LD To>DR' nr---- 1RRED TO URERS-------- Weirton Steel Division National Steel Corporation Weirton. same -ZONE- .STATE W. Vq. 26062 Bottom House. Attn. J. Cain 240717-SW Customer's Order No.. PLCASC ATTACH ORIGINAL OROCR Date or Cust. order__________________ Requisition no.. Distributor's Order No.____ INVOICE IN: OURLICATC.TRIRLICATE-QUAORUPLieATC 6/Date Shirred-- 17/69 Shirred From--?&rgbrit;k-- RfCO.......... *.......................................... IPAf r-.~r , rrAT f iAm* f Air-Lite souMATERIALS n AITAIIC Difte Ria 750 ftivr fiivr .Tctal L-. 0 _ .Total Lftt f SEUINO FBICI CWT. .CWT. ...... do not WRITE HERE Clurr Furf .Total Lcr. p a. _C\/T. 9 .Total Lbs. 0 s- 180.33/H.T iCWT. $ - CWT C'w-r .Total Lbs. 0 a.Total Lbs. s- -CWT. t _CWT. f CWT. f-WT, .Total Lbs. s- -CWT. 9 C-WT, .Total Lbs. a s. -CWT. ? F-WT, Total Lbs. s. -CWT. 9 Cwr, Total Las. e i. Cwr. 9 Cwr. o Prepaid Freight or Cartage Charges s ' ( attach Receipted Freight Bill) OITIONAL INSTRUCTIONS FOR INVOICING CONTRACTS. LABOR, OTHER MATERIALS. ETC. See P. 0. #118695-SW, Dist. ,*69704 for frt. clues. . stributor's Signature *1 MARKET ANALYSIS. PLEASE CHECK MATERIAL USE. BOILERS INCINERATORS REFINERY a CHEMICAL EQUIPMENT CEMENT MILL INDUSTRIAL DRYERS - GYPSUM FURNACES INDUSTRIAL FURNACES .... STEEL MILL EQUIPMENT I IN AND OUT STOCK RECORD o FORM No. 61V > 3 0 Vs & 5 M A X IM U M ' M' IN IM U M ^ LO C A TIO N . a> o 3 m u s? zsff ? -e c r> "ft 3t lA Vol ? O 2f ft pAaJ vj* tv p* W uWaJ VA Oo r V . VJ ft * *-> M Si (S) -Ck 5* 1M \< 1 % .c: <t! .A*. * 7 -J & ft . rV>A _ t, ft >Ov' ft* ft lm O TV ccoC -F- J- T* V A% *XAte 4 7* 7 x. x r '- c: w J Si k rf r- n lo r-i % *. * r > Si. ( TN pg a ij ..1 Z \ < 7\ A A > M0+tek c* *. -- Xs o c --\ *s? > I \A --< xi V1 - zon "5u % * i, uAw>c A* V- C?s IV < < VM ft cc <& * fc v < 't 9 | > ~n b 1 -C *? ft ? c Tv S' f.t *> C & i $ at VI v 5 'C. ft tVv i * MSI <<s>> -*xa* >- V *"xft **4* (S Ul -ox J sj ? J r* O >v ? V -p Jcvj ft* , ^4 4 o 0 5n 0 z PA a tft *V S 9*4\. A * ft J_K !T ir S'o *ws -oJ ?> o A *n <v> r?** J1' [5 A >N c Z Ste S'V A oo W *A c<i V>* A o c H >m T* I i/V 1 0 / 1 v> A ft t IJ vjJ A s ozA - > 4 \ T* c* Vt Ci --o<r 0\6C 3T tv^ v *: A -< s ?? rv - A-T> 0 5 n 0 z* Pg a rr, i?v .*, W <, Z A TN C\ i YV O cz . A H a > !A 4 1 'A V5 zo i PI IN THE CIRCUIT COURT OF KANAWHA COUNTY, WEST VIRGINIA IN RE: ASBESTOS m Civil Action No. 92-C-8888 CERTIFICATE OF SERVICE I, Patrick J. Loughney, do hereby certify that I have this 4th day of June, 1993, mailed a true copy of the Answers and Objections of Plibrico Company to Plaintiffs' Joint Interrogatories and Request for Production of Documents Concerning Product Identification to AH Defendants to all counsel of record by U.S. Mail. Counsel for Plibrico Company: ------------------------------------Arthur R. Gorr, Esquire Patrick J. Loughney, Esquire Carl Hudson Shelly, Esquire GORR, MOSER, DELL & LOUGHNEY 1300 Frick Building Pittsburgh, PA 15219 (412) 471-1180