Document RJ873ebYN517L5d4b4rErxZdv

1 John E. Dittoe J. David Bickham 2 CROSBY, HEAFEY, ROACH & MAY Professional Corporation 3 1999 Harrison Street Oakland, CA 94612 4 (415) 763-2000 '8 5 Attorneys for Defendant Chrysler Corporation 6 7 "N 8 SUPERIOR COURT OF CALIFORNIA COUNTY OF SOLANO 9 10 IN RE: SOLANO COUNTY COMPLEX ASBESTOS LITIGATION 11 __________________________________ / No. 2830 12 13 DEFENDANT CHRYSLER CORPORATION'S FURTHER RESPONSE TO PLAINTIFFS' STANDARD 14 INTERROGATORIES TO DEFENDANT PURSUANT TO GENERAL ORDER 30.00 15 16 PROPOUNDING PARTY 17 RESPONDING PARTY Plaintiffs Defendant Chrysler Corporation 18 SET NUMBER One 19 20 Without waiving any of the general or specific objections 21 stated in its original response, defendant Chrysler Corporation 22 (Chrysler) provides the following further response to plaintiffs' 23 interrogatories, both for itself and as success in interest to 24 American Motors Corporation (AMC): 25 //// 26 //// 1 FURTHER RESPONSE TO INTERROGATORY NO. 34; Yes. 2 3 (a) Unknown, except for those documents previously 4 produced. Discovery and investigation are continuing. 5 6 (b) Hot applicable. 7 8 DATED: February 4 1991. 9 10 CROSBY, HEAFEY, ROACH & MAY Professional Corporation 11 12 By. 13 3jf David Bickham Attorneys for Defendant 14 Chrysler Corporation 15 16 17 18 19 20 21 22 23 24 25 26 -2- 1 PROOF OF SERVICE BY MAIL (1013.2015.5 C.C.P.) 2 3 I am a citizen of the United States and a resident of Contra Costa____ County. I am over 4 the age of eighteen years and not a parry to the within action; my business address is 1999 Harrison Street, 5 Oakland, California 94612. On_____ February 5_ 19 $i , I served the within 6 DEFENDANT CHRYSLER CORPORATION'S FURTHER RESPONSE 7 TO PLAINTIFFS' STANDARD INTERROGATORIES TO DEFENDANT PURSUANT TO GENERAL ORDER 30.00 8 9 in said action by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully pre 10 paid, in the United States mail at Oakland, Alameda County, California, addressed as follows: 11 PLEASE SEE ATTACHED LIST 12 13 14 15 16 17 18 19 20 21 22 I declare under penalty of perjury that the above is true and correct. 23 Executed on___ February 5, 1991 at Oakland, California 24 25 26 , Cheryl. Cunningham CAW OFFICES CROSBY. HEAFEY. ROACH ft MAY FROFCSSlONAl CORPORATION 1999 HARRISON STREET OAKIANO. CA S46I2 TclC*mom< 7*3*2000