Document RJo5w0ZYY1vBL9eLKnXaxxwQ7

FILE NAME: Kaiser Gypsum (KG) DATE: 0000 DOC#: KG001 DOCUMENT DESCRIPTION: Legal - Exhibit List KAISER GYPSUM COMPANY A U T H E N T IC A T IO N KG1 Kaiser Gypsum Company, Inc. ("KG") J-M Authenticity Bv Asbestos & Health Meeting List of Attendees: Contents of Writing June, 5, 1970; August 8, 1972; April 25, 1973; A writing may be October 17, 1973; December 3, 1973; December 4, 1973; October 18, 1975; January 15-17, 1974; June 24, 1975; September 24-25, 1974; December 7, 1976 authenticated by evidence that the writing refers to or states matters unlikely to be known by anyone other than the person who is claimed to be the author of the writing; handwritten information on reverse side of document could have been supplied only by specific person. Admission bv Onnosing Party ~ Actions bv Onnosing Partv. Comparison by Others [certified copy of bond certificate]. Comnarison bv Exoert Witness An expert witness may be able to authenticate by comparison typewriting and other forms of communication. See Ca. Evid Sec. 1418, Comment. Unlike experts who may authenticate any "writing" by comparison, the trier o f fact may make only handwriting comparisons. Ca Evid Sec. 1417. KG2 Johns-Manville Presentation "Asbestos and See Authentication KG1, Health" customer seminars, dated March 1974. above. Reeularlv Published NewsDaoers or Publications Printed material purporting to be a regularly published newspaper or publication is presumed to be authentic. CA Evid. Sec. 645.1 RELEVANCE Kaiser Gypsum Exhibit List Page 1 KAISER GYPSUM COMPANY A U T H E N T IC A T IO N KG3 KG inter-office memo from L.R. Flicker to See Authentication KG1, R.L. Allgood, et al., dated March 1,1965, received from the Gypsum Association: Report above. on Industrial Hygiene Foundation of America, Jan. 12-14, 1965 and "Asbestos is Pointed Out As Cause of Lung Cancer", by Alton Blakeslee; AP Science Writer KG4 KG Inter-office Memorandum from L.R. See Authentication KG1, Flicker to All Safety Supervisors, dated March above. 29, 1966 KG5 July 30, 1970 Union Carbide Asbestos Toxicology Report. See Authentication KG1, above. KG6 Kaiser Cement & Gypsum Corporation, GYPSUM DIVISION Organizational Charts, dated November 1, 1970 See Authentication KG1, above. KG7 December 27, 1971 KG Grigg letters to Harold See Authentication KG1, above. Plate, Carey-Canadian Mines, Western Chemical Co. and Robert Tucker, Pacific Asbestos Corp. re: KG's "concern of data that asbestos may be a health hazard." KG8 January 4, 1972 KG memo to Plant Managers re: Asbestos Ecology & do not respond to inquiries re: asbestos fibers. See Authentication KG1, above. KG9 January 11, 1972 KG memo attaching "Emergency Standards for Exposure to Asbestos Dust." See Authentication KG1, above. KG 10 February 4, 1972 Calidria Asbestos Marketing Manager John Myers letter to R. Grigg replying to inquiry re: asbestos toxicology. See Authentication KG1, above. KG11 March 1, 1972 Schaper, KG VP Operations letter to EPA. See Authentication KG1, above. KG12 March 9, 1972 Carey-Canadian Asbestos letter attaching President R.J. Merrill's response to inquiry re: asbestos health hazards using CC's asbestos. See Authentication KG1, above. KG13 April 11,1972 letter from Pacific Asbestos Corp.'s R. Tucker to Grigg responding to inquiry re: asbestos health hazards using CC's asbestos. See Authentication KG1, above. KG 14 June 28, 1972 KG inter-office memo re: Respirators for Asbestos workers. See Authentication KG1, above. KG15 August 7, 1972 Kaiser Cement & Gypsum Corp. ("KC&G") KG inter-office from McCoe to G. Davis re: Plastic-Plastic Gun Cement warning label revision "this cement contains a small percentage of asbestos fibers." See Authentication KG1, above. RELEVANCE Kaiser Gypsum Exhibit List Page 2 KAISER GYPSUM COMPANY A U T H E N T IC A T IO N KG 16 September 28, 1972 KC&G inter-office memorandum from John Rohrer to C. Grimme, et al. re: Caution Notice on Gun Plastic Cement Bags See Authentication KG1, above. KG17 KG18 KC&G inter-office memorandum from J.E. Toomey to McCoe, et al., dated September 28, 1972 re: Asbestos-Labeling Kaiser Cement Products. Recommendation: "Kaiser Cement not apply caution or warning labels to any of its cement packages, except those containing asbestos." October 5, 1972 memo re: Labeling Plastic & Plastic Gun Cement sacks. See Authentication KG1, above. See Authentication KG 1, above. KG19 Minutes of the Annual Meeting Gypsum Association, Sheraton Blackstone Hotel, Chicago, Illinois, dated April 4, 1973 See Authentication KG1, above. KG20 July 6, 1973 KC&G inter-office memo re: California Asbestos Regulations See Authentication KG1, above. KG21 Minutes of the Ninety-First Meeting of the Technical Committee, August 1, 2, 3,1973 See Authentication KG1, above. KG22 Minutes of the Safety Committee Meeting, Airport Holiday Inn, Cleveland, Ohio, September, 19, 1973 See Authentication KG1, above. KG23 KG24 Minutes of the Semi-Annual Meeting, The Homestead, Hot Springs, Virginia, October 10 12, 1973 with Report of Special Task Force on Joint Treatment Compound. Johns-Manville, Internal Correspondence from N.W. Hendry to J.R.M. Hutcheson, dated December 7, 1973 "Asbestos & Health Presentations" See Authentication KG1, above. See Authentication KG1, above. KG25 December 18, 1973 Western Chemical & Manufacturing Co. letter to KG not producing 1600 Asbestos filler after 1/1/74. See Authentication KG1, above. KG26 February 11, 1974 KC&G inter-office memo re: Safety Survey - Santa Ana Plant-1/23/74. See Authentication KG1, above. KG27 KG28 March 1, 1974 KG inter-office memo from J.S. Sheahan at Antioch R&D to G.B. Kirk re: Dust from Joint Compound job operations. Attaching 3 reports from the Gypsum Association on asbestos dust and siliceous dusts during mixing and sanding ofjoint compound on typical jobs. March 7, 1974 Minutes of the Safety Committee Meeting, Dallas, Texas. See Authentication KG1, above. See Authentication KG1, above. KG29 June 12, 1974 memo re Industrial Hygiene Inspection-KG Delanco Plant See Authentication KG1, above. Kaiser Gypsum Exhibit List RELEVANCE Page 3 KAISER GYPSUM COMPANY A U T H E N T IC A T IO N K.G30 Minutes of the Ninety-Third Meeting of the Technical Committee, August 7, 8, 9, 1974 See Authentication KG1, above. KG31 August 14, 1974 Minutes of Safety Committee Meeting. See Authentication KG1, above. KG32 February 20, 1975 Gates, McDonald Co. re: safety inspection recommendations of 7/10/74. "Of interest is the fact that State inspections have disclosed acceptable asbestos counts." See Authentication KG1, above. KG33 Minutes of the Ninety-Eighth Meeting of the Technical Committee, February 16, 17, 18, 1977 See Authentication KG1, above. KG34 KG35 Minutes of the Annual Meeting, Gypsum Association, The Drake Hotel, Chicago, Illinois, April 6, 1977 Minutes of the Ninety-Ninth Meeting of the Technical Committee, August 10, 11, 12, 1977 See Authentication KG1, above. See Authentication KG1, above. KG36 Minutes of the Semi-Annual Meeting of the Gypsum Association, October 12-13,1977 See Authentication KG1, above. KG37 KG38 KC&G Corp.'s Answers to Interrogatories served Januarv 31. 1978. Demetrio Duran v. Johns-Manville Sales Com., et al., Superior Court, San Francisco County, Case No. 719 238. Plaintiffs First Set of Interrogatories Propounded to Defendant KG (Subcontractors, installer and/or applicators), served December 27th. 1984, IN RE: Los Angeles Unified School District v. Owens-Coming Fiberglas Corporation, et al., Superior Court of California, County of Los Angeles, Case No. C 440 317 KG39 Interrogatories Propounded and Served Concurrently with Requests for Admission to All Defendants, served April 18th 1985. IN RE: Los Angeles Unified School District v. Owens Coming Fiberglas Corporation, et al., Superior Court of California, County of Los Angeles, Case No. C 440 317 KG40 Kaiser Cement Corporation and Kaiser Gypsum Company, Inc.'s Answers to Interrogatories, Set No. 10, dated October 28, 1985. IN RE: Related Asbestos Cases Consolidated For Discovery (McOuaid, Bedford & Bravton), Superior Court of California, County of Solano, Case No. 1327 ** "Leading Plastering Contractor's names & pictures"** RELEVANCE Kaiser Gypsum Exhibit List Page 4 KAISER GYPSUMCOMPANY A U T H E N T IC A T IO N KG41 Kaiser Cement Corporation and Kaiser Gypsum Company, Inc.'s Responses to Plaintiffs' Standard Interrogatories to Defendants, dated February 12. 1986. IN RE: Comdex Asbestos Litigation, San Francisco Superior Court, Case No. 828684 KG42 Kaiser Cement Corporation and Kaiser Gypsum Company, Inc.'s Supplemental Responses to Plaintiffs' Standard Interrogatories to Defendants, served May 15, 1986. IN RE: Complex Asbestos Litigation, San Francisco Superior Court, Case No. 828684. KG43 Kaiser Gypsum Company, Inc.'s Amended Responses and Answers to Plaintiffs' Matter Set of Interrogatories and Request for Production to Defendants, dated July 27, 1992, In Re: All Asbestos-Related Personal Injury or Death Cases Filed or to be Filed in Dallas County, Texas, In the District Court, Dallas County, Texas 160th Judicial District KG44 Consolidated Partial Response of Kaiser Cement Corporation and Kaiser Gypsum Company, Inc. to Plaintiffs' Request for Production of Documents, served August 7, 1992, IN RE: Cossey v. Abex Corporation, et al., San Francisco Superior Court, Case No. 920148 KG45 KAISER CEMENT CORPORATION'S Response to Plaintiffs' Request for Production of Documents, served December 12, 1996, Bart Stocktman v. Abex Coro.. San Francisco Superior Court, Case No. 962298. KG46 KAISER GYPSUM COMPANY, INC.'s updated responses to plaintiffs' Standard Interrogatories to Defendants, served December 30. 1996. IN RE: Complex Asbestos Litigation. San Francisco Superior Court, Case No. 828684 KG47 KAISER GYPSUM COMPANY, INC's Responses to Plaintiffs' Standard Interrogatories to All Defendants, served July 22.1997. IN RE: Complex Asbestos Litigation, San Francisco Superior Court, Case No. 828684 KG48 KAISER GYPSUM COMPANY, INC.'s Responses to Plaintiffs' First Set of Interrogatories and Request For Production of ! Documents, served Mav 14. 1998. Pickner et al. V. Owens Coming, et al., in the Superior Court of Washington for King County Case No: 98-2-09390-1 SEA Kaiser Gypsum Exhibit List RELEVANCE Page 5 KG49 kaiser gypsum company I Condensed Transcript of Joseph Ross Hobby taken on November 4,1998, Pickner etal,--i Owens Coming, et.aL, in the Superior Court of Washington for King County Case No: 98-2 09390-1 SEA _________ _ KG50 Videotaped Deposition Transcript of John E. Crum taken on 11/06/98 inCmm, et al. V -JM B r Rartells Company, Supenor Court of the State of Washington, In and For the county of King, Case No. 98-2-24915-3SEA KG51 Videotaped Deposition of Brentwood Crosby taken on January 19,1999 in Crum, e ta lX The E.J. Bartells Company, Superior Court ot the State of Washington, In and For the county of King, Case No. 98-2-24915-3SEA KG52 KAISER GYPSUM COMPANY, IN C 's First Updated Responses to Plaintiffs' Standard Interrogatories to Defendants, served August 3, 1999; TN RF,: Comnlex Asbestos Litigation, San Francisco Superior Court, Case No. 828684 Kaiser Gypsum Exhibit List