Document RJzmxGqBKGEvnZwrQYB110jyn

K&L GATES August 28,2008 Kfrkpatrick & Lockhart Preston Gates Ellis ilp A Deisiare IMled SaisEty partiBrsItfp One Newark Center, Tenth Floor Newark, NJ 07102-5285 t 973.848,4000 m.klgates.oom Mark D. Marino D 973.S48.4013 F 973.848.4001 mark.marino@kigates.com Via Federal Express Rachel A. Plaeitella, Esq. Cohen, Plaeitella, & Roth, P.C. 127 Maple Avenue Red Bank, New Jersey 07701 . Re: Howard Bird and Deborah Bird v. 3M Company, et al. Docket No.: MID L-3599-08___________________________ Dear Ms. Plaeitella; Enclosed, please find Defendant Square D Company's Responses to Plaintiffs' Form B Interrogatories in connection with the above-referenced matter. Any defendant wishing to obtain a copy of these Responses is asked to contact the undersigned at mark.marino@klgates.com. Very truly yours. cc: All Defense Counsel of Record (w/o encl.) NW-228643 vl SC-SDC-5650 Anthony P, La Hocco, Adminbtratlve Partner, New Jersey Howard Bird and Deborah Bird V. 3M Company, et al MID-L-3599-08AS COUNSEL LIST Counsel:' ' .V N./ L v John S. McGowan, Esq. McGowan Law Offices, LLC 54 Main Street Chatham, NJ 07928 Christopher A. Barbarisi, Esq. Mark D. Marino, Esq. K&L Gates LLP One Newark Center - 10th Floor Newark, NJ 07102-5285 Attorneys for: .i.:: VV'-'-. .LV. Attorney for Defendant Sears Roebuck & Co. Attorneys for Defendant Square D Company William Sanders, Esq. Jennifer Hally, Esq. McGivney & Kluger, PC 23 Vreeland Road, Suite 220 Florham Park, NJ 07932 Attorneys for Defendants Hubbell Power Systems, Inc., DAP, Inc. Ronald S. Suss. Esq. Picillo, Caruso, Pope, Edell & Picini, PC 60 Route 46 East Fairfield, NJ 07004 Attorneys for Defendants Ceratainteed, Union Carbide Joseph Hanlon, Esq. Wilson, Elser, Moskowitz, Edelman & Dicker, LLP 33 Washington Street, 18th Floor Newark, NJ 07102 Timothy J. McHugh, Esq. Lavin, O'Neil, Ricci, Cedrone, & Disipio, LLC 420 Lexington Avenue Greybar Building, Suite 2900 New York, New York 10170 Attorneys for Defendant Siemens Attorneys for Defendant 3M Sebastian Goldstein, Esq. Marks, O'Neill, O'Brien & Courtney, P.C. Copper River West, Suite 300 6981 North Park Drive Pennsauken, NJ 08109 Attorneys for Defendants Georgia Pacific, Whirlpool MW-228667 vl Howard Bird and Deborah Bird V. 3M Company, et al MID-L-3599-08AS COUNSEL LIST Carolyn Campanella, Esq. Eckert, Seamans, Cherin & Mellott 50 South 16th Street Two Liberty Place, 22nd Floor Philadelphia, PA 19102 Attorneys for Defendant CBS David Kochman, Esq. Harris Beach, LLP 100 Wall Street, 23rd Floor New York, New York, 10005 Attorneys for Defendant Progress Lighting GaryN, Smith, Esq. Hofheimer, Gartlir & Gross, Esqs. 530 5th Avenue, 9th Floor New York, New York 10036 Attorneys for Defendant Rapid American Corp, Joanne Hawkins, Esq. Speziali, Greemvald & Hawkins, PC 1081 Winslow Road Williamstown, NJ 08094 Attorneys for Defendant General Electric Jason Rubin, Esq, Goldberg, Miller & Rubin, PC 121 South Broad Street, Suite 1500 Philadelphia, PA Attorneys for Defendant Ecton Electrical Michael A. Moroney, Esq. Wber, Gallagher, Simpson, Stapleton, Fires, & Newby, LLP 1101 North Kings Highway Cherry Hill, NJ 08034 Attorneys for Defendant Frigidaire K&L GATES LLP One Newark Center, Tenth Floor Newark, NJ 07102 (973) 848-4000 Attorneys for Defendant Square D Company Howard Bird and Deborah Bird, Plaintiffs vs. SUPERIOR COURT OF NEW JERSEY LAW DIVISION MIDDLESEX COUNTY DOCKET NO. L-3599-08 Civil Action 3M Company, et al., Defendants). DEFENDANT SQUARE D COMPANY'S RESPONSES TO PLAINTIFFS' FORM B INTERROGATORIES Defendant Square D Company ("Square D") serves the following objections and responses to Plaintiffs' Form B Interrogatories (Plaintiffs' discovery") as follows: PRELIMINARY STATEMENTS The following responses are based upon the information that is presently known and available to Square D based upon a continuing and ongoing reasonable investigation. Square D believes that these responses are accurate as of the date made. However, many of the matters inquired about in Plaintiffs' discovery took place decades ago. Therefore, some information may be incomplete or no longer available due to the passage of time. Although Square D has endeavored to conduct a reasonable investigation, it cannot exclude the possibility that its continued review of these subjects may reveal more complete information. Consequently, Square D's review of the matters inquired into by Plaintiffs' discovery continues, and, to the extent appropriate, Square D reserves the right to further supplement or amend its objections and responses. Square D's Preliminary Statements are incorporated into the discovery responses set forth below. GENERAL OBJECTIONS Square D's General Objections are incorporated by reference into the discovery responses set forth below, and are stated here for the convenience of the parties and the Court. 1. Square D objects to the unlimited scope and breadth ofPlaintiffs' discovery. For over 100 years, Square D has conducted operations manufacturing a diverse and broad range of electrical equipment products, which have been steadily developed and improved over time to satisfy emerging industry and customer demands as well as advances in design and technology. To require Square D to conduct an unlimited scope of inquiry into every product, and every iteration of every product, that it ever manufactured and to provide the kind of broad information requested by Plaintiffs' discovery is unfair, unreasonable, and would involve enormous expense and an unnecessary burden on Square D's part. 2. Square D objects to Plaintiffs' discovery to the extent that Plaintiffs have failed to identify a Square D product or products at issue. It is fundamentally unfair and unreasonable to require Square D to defend itself in a lawsuit when its alleged product is not sufficiently identified so as to put Square D on notice ofthe purported product liabilities asserted against it. Based on the limited information provided to date, it appears that Plaintiffs' alleged exposure, with respect to Square D, relates to certain broad and undefined general classifications of electrical equipment products. However, the design, function, materials, and construction applicable to the numerous electrical equipment products or configurations developed and manufactured by Square D over the last 100 years vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. As such, Square D has nevertheless made a reasonable and good faith effort to provide what it understands to be responsive 2 Information to this unlimited discovery request, subject, however, to the fact that Square D remains unaware of what Square D product or products remain at issue in this case. 3. In several instances, Plaintiffs' discovery requests refer to the interchangeable terms "Defendant," "You," "Your" and "Your Company." Unless otherwise stated, these terms shall be reasonably understood to refer to Square D Company, a business corporation originally formed in Michigan in approximately 1903 as the McBride Manufacturing Company, which after successive name changes, became known as Square D Company in approximately 1917. 4. Square D submits these responses on its own behalf and for no other entity, including without limitation, any other parent, subsidiary, or affiliated entities. 5. Square D objects to Plaintiffs' discovery to the extent it seeks information which is not, and may not have been, within the personal knowledge or possession or control of Square D, its employees, or agents. 6. Square D objects to Plaintiffs' discovery to the extent it seeks the production or disclosure of communications prepared by or for Square D's lawyers, which communications (a) were made by or to legal counsel in anticipation of or in connection with litigation, or (b) reflect confidential and privileged communications between or among counsel, representatives of Square D and/or non-testifying experts retained for purposes of assisting Square D or its counsel in litigation. Square D will not produce or disclose such privileged communications; in addition. Square D will not disclose or otherwise identify such privileged communications in response to written discovery or on any listing of documents or things withheld from production. 7. Square D objects to the phrase "asbestos products" and similar phrases to the extent those phrases imply all Square D electrical equipment products contained asbestos components, which is expressly denied. 8. In responding to Plaintiffs' discovery, Square D does not waive, and expressly preserves the following objections: 3 a. all objections regarding competency, relevancy, materiality and admissibility; b. all objections regarding the use of the responses in any proceeding; and c. all objections to any further interrogatories or other discovery requests involving, or related to, any ofthe requests in Plaintiffs' discovery. 9. Square D does not concede that any of its responses to Plaintiffs' discovery are admissible evidence at any trial or any other legal proceeding in which evidence is heard. Accordingly, Square D does not waive any objections, on any ground, whether or not asserted herein, to the use of such answers at trial. DEFENDANTS INTERROGATORIES FORM B B.l. State the name, address and job position of each and every individual signing these interrogatories on behalf of the defendant. a. State the name, address and employer and job position of each person, whether defendant's employees or otherwise who was consulted with or who assisted in die answering of these interrogatories. RESPONSE: Subject to and without waiving its foregoing General Objections, the information set forth in these answers has been compiled by legal counsel from information developed during the course of discovery activities for similar, previously filed litigation. Such information has developed over a period oftime through conversations with individuals and by reviewing documents and other materials. By way of further answer, Robert Barbaglia provided certain information used in answering these Interrogatories and verifies these answers. B.2. Give a full and detailed description of the nature of the business that your company is engaged in. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the 4 discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course ofits over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Subject to and without waiving its foregoing objections, Square D responds that its business generally involves the manufacture and sale of electrical equipment products. B.3. When did your company commence its business? RESPONSE: In addition to its foregoing General Objections, Square D objects that this Interrogatory is vague and ambiguous. Subject to and without waiving its foregoing objections, Square D was originally incorporated in Michigan in approximately 1903 under the name McBride Manufacturing Company. After successive name changes, McBride Manufacturing Company eventually became known as Square D Company in approximately 1917. In or about 1988, Square D Company reincorporated in Delaware. B.4. a. b. Are or have any of defendant's predecessors, affiliates, subsidiaries, or parent corporations engaged in the mining, sale and distribution of asbestos and/or asbestos fiber and/or asbestos containing insulation products? If so, state the name of each such entity, describe the nature of the involvement that each entity has or has had in the mining, distribution or sale of these products and materials, and set forth the inclusive dates each was involved in each aspect ofthis business, As to each such entity referred to in (a) above, state: 1. The relationship between defendant and each such entity; 2. The date each such relationship began and terminated; 5 3. The names and addresses of each such entity's corporate officers and Board of Directors; and 4. The names and addresses of your corporate officers and Board of Directors. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D also objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D objects that this Interrogatory seeks legal conclusions regarding "predecessors," "affiliates," and "subsidiaries." Square D further objects to the phrase "asbestos containing insulation products" as being vague and ambiguous, particularly as applied to Square D, and to the extent that it implies all Square D electrical equipment products contained asbestos components, such an implication is expressly denied. Subject to and without waiving its foregoing objections, Square states that it has not manufactured "asbestos containing insulations products" as it reasonably understands that phrase. By way of further response, Square D was not a miner or seller ofraw asbestos fibers. Additionally, Square D incorporates by reference its objections and response to Interrogatory B.14. 6 B.5, From the year 1925 until the present, identify and state the address of any organization in which defendant, its officers, agents or employees have belonged, having anything to do with setting standards, regulations or the conducting of research into the use of asbestos, asbestos products or asbestos fiber. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D further objects to the phrase "having anything to do with setting standards, regulations or the conducting ofresearch into the use ofasbestos, asbestos products or asbestos fiber" as being vague and ambiguous. Subject to and without waiving its foregoing objections. Square D states to the best of its present knowledge, it has not belonged to any organizations which it views as relating to "asbestos, asbestos products or asbestos fiber." B.6. Has defendant ever been a member of or affiliated with any trade groups, professional associates or organization? If so, identify each such group, association or organization and set forth the inclusive dates of defendant's membership in each. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory Is not reasonably calculated to lead to the 7 discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Subject to and without waiving the foregoing objections, Square D states to the best ofits present knowledge, it has not belonged to any organizations which it views as relating to "asbestos-containing products." By way of further answer, but without conceding the relevance of this response, Square D states that it or its employees may have belonged to organizations, including; National Electrical Manufacturers Association; American Society of Safety Engineers; Home Safety Council; Institute of Electrical and Electronics Engineers; and National Safety Council. As noted above, Square D's investigation ofthis matter is continuing and it reserves the right to modify or to supplement this response should additional information become available. As noted above, Square D's investigation ofthis matter is continuing and it reserves the right to modify or to supplement this response, as necessary, subject to its other objections. B.7. Has defendant ever been a member of or affiliated with the Asbestos Textile Institute? If so, indicate when your company was affiliated or was a member of this organization. RESPONSE: Subject to and without waiving its foregoing General Objections, and to the best of its present knowledge, Square D is unaware that it was a member ofthe above referenced organization. 8 B.8. Does your company publish or distribute a manual or booklet which describes the nature of the business that defendant is engaged in? If so, set forth the title of such manual or booklet, indicate when it was published and attach a copy of same hereto. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Additionally, Square D objects that this Interrogatory is vague and ambiguous. Subject to and without waiving its foregoing objections, Square D states that over the years it has published digests that would have referenced various Square D products. B.9. Has any employee or representative of your cooperation ever attended a conference or meeting of the Asbestos Textile Institute? If so, identify each such individual who attended these conferences or meetings and set forth the dates on which each such individual went to such a conference or meeting. RESPONSE: Subject to and without waiving its foregoing General Objections, and to the best of its present knowledge, no. Moreover, Square D is unaware of facts or circumstances necessitating that it attend such an event. B.10. Has your company ever been a member of, been affiliated with or provided funding for the Industrial Hygiene Foundation? If so, indicate when your company was a member or affiliate of this organization and set forth the dates, if applicable, when you provided funding to this organization. 9 RESPONSE: Subject to and without waiving its foregoing General Objections, and to the best of its present knowledge. Square D is unaware that it was a member of the above referenced organization. B. 11. Does your company have a Board of Directors? RESPONSE: In addition to its foregoing General Objections, Square D objects that this Interrogatory is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence because it seeks information which is not relevant to the facts of this case. B. 12. Does your company's Board ofDirectors conduct meetings? RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory B.ll, B.13. Have minutes of the Board of Directors meetings been taken and maintained by your company? If so, indicate who has custody ofthe minutes at this time. RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to InterrogatoryB.il. B.14. Has your company, and/or its subsidiaries or affiliates ever manufactured or distributed asbestos containing products? RESPONSE: ha addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts 10 and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D further objects that this Interrogatory seeks legal conclusions regarding "subsidiaries" and "affiliates." Subject to and without waiving its foregoing objections. Square D generally states that it manufactured and sold many different types of electrical equipment products over the course of its over one hundred year history. For many decades, these products incorporated molded or bonded component parts manufactured from composite materials. Generally, molded or bonded composite materials were used in some, but not all, electrical equipment products for structural support, mechanical operation, electric arc suppression, or for physical barriers. Molded or bonded component parts used in electrical equipment products were manufactured with various materials, including ceramics, plastics, and other composites. Over time, molded or bonded composite materials used for these purposes incorporated a wide variety of ingredients--most ofwhich were proprietary to the third-party entities, which manufactured, marketed, and sold such composite materials. For limited periods of time, some of the composite materials may have included some quantity of encapsulated asbestos fibers. At all relevant time periods, molded or bonded composite materials were generally manufactured or supplied by third-parties, however, for a period of time before approximately 1975, Square D purchased raw chrysotile asbestos from at least Carey-Canadian Mines Ltd. for use in the manufacture of certain cold-molded component parts used in certain types of electrical equipment. 11 From approximately 1978 to the mid-1980s, suitable replacement composite materials, which did not contain asbestos, were becoming available from suppliers of such materials. Accordingly, by approximately the mid-1980s, non-asbestos-containing replacement materials, which did not and do not contain asbestos, came to be used generally. As noted above, molded or bonded composite component parts were made from a variety of ingredients. Upon information and belief, the constituent composite materials, including any asbestos or other fibrous material contained in the molded or bonded materials, were chemically and/or physically bound within the compound itself. Thus, the encapsulated fibers could not be released in a respirable form under reasonably anticipated usage conditions. Moreover, the molded or bonded component parts that were incorporated into Square D products did not require alteration or modification by persons using the products for their intended purpose. At the present time, Square D is generally unable to ascertain when, where or to whom electrical equipment products were supplied or placed into service, particularly during time periods when molded or bonded composite materials containing encapsulated asbestos may have been used. By way of further response, to the best of its present knowledge. Square D generally did not specify that suppliers of composite materials use asbestos. Instead, Square D generally required that materials used to make component parts of its electrical equipment products meet certain physical and performance specifications. Additionally, Square D states that to the best of its knowledge, information regarding the specific chemical composition and ingredients of such molded or bonded materials utilized in Square D electrical equipment products would be in the possession of the suppliers ofthose materials and not necessarily with Square D. B.15. Give a complete and detailed description of the particular qualities that asbestos has or had that caused your company and/or its subsidiary or affiliate to utilize asbestos in your products. 12 RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Subject to and without waiving its foregoing objections, to the best of its present knowledge, Square D generally did not specify that suppliers of composite materials use asbestos. Instead, Square D generally required that materials used to make component parts of its electrical equipment products meet certain physical and performance specifications. Additionally, Square D states that to the best of its knowledge, information regarding the specific chemical composition and ingredients of such molded or bonded materials utilized in Square D electrical equipment products would be in the possession of the suppliers of those materials and not necessarily with Square D. By way of further response, Square D incorporates by reference its objections and response to Interrogatory B.16. Did any of the entities from whom you received asbestos fiber or any of the entities referred to in B6, B7, B9 and BIO ever inform you or your company's employees that asbestos was potentially hazardous to the health of individuals who were exposed to it? RESPONSE: In addition to its foregoing General Objections, Square D objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, and seeks information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of 13 that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence in that Plaintiffs do not allege that they were Square D employees or injured in any way at facilities where Square D products were manufactured or assembled. Square D also objects to this Interrogatory to the extent that it is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantity of encapsulated asbestos, despite vast distinctions in their sold form and application, create similar potential hazards, if any. By way of further objection, the process of designing and manufacturing Square D products is vastly different from any exposure Plaintiffs may allege. Put simply, any asbestos that may have been incorporated in certain composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method ofmanufacture of a Square D product would present a significantly different potential exposure to asbestos that would not be similar in any way to Plaintiffs' alleged exposure. As such, information on the means and method ofmanufacture of Square D products is not relevant to this action and is an unfair attempt to mislead the jury as to the nature of Plaintiffs' alleged injury. B. 17. If so, for each such company that transmitted such information to you and your company, set forth the following information. a. The name of each and every entity that informed your company that asbestos was potentially hazardous to health; b. The dates you received this information from each such company; c. Indicate how this information was transmitted to you; d. The substance of each warning; and e. Annex hereto copies of each such warning. 14 RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory B. 16. B.18. Has defendant distributed or sold asbestos or asbestos containing products in the State of New Jersey? If so, set forth the following information: a. The date that defendant commenced selling asbestos or asbestos containing products in the State of New Jersey; b. The date the defendant terminated the sale of asbestos or asbestos containing products in the State ofNew Jersey; and c. The areas of New Jersey where asbestos or asbestos containing products were sold. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Subject to and without waiving its foregoing objections. Square D states that it sold its products primarily through distributors or original equipment manufacturers. Thus, at the present time, Square D is generally unaware as to the specific identity of entities or persons to whom its products were 15 ultimately sold, at which job sites they may have been delivered or used, or when those sales took place. Moreover, at the present time. Square D is generally unable to ascertain specifically to whom its products were sold during time periods when certain of its products may have contained molded or bonded component parts manufactured from composite materials which could have contained some quantity of encapsulated asbestos. By way of additional response, Square D states that at the present time, and in the absence of additional information, such as, for example, product-specific catalog and/or factory order numbers. Square D is generally unable to ascertain when, where, or to whom certain Square D electrical equipment products were supplied to or placed into service. Square D reserves the right, however, to supplement this response if responsive information becomes available. B.19. Did defendant ever affix any warnings to any of the asbestos or asbestos containing products it marketed and distributed? If so for each such product that contained a warning set forth the following information: a. The brand and trade name of each such product that contained a warning; b. The date a warning was attached to each such product; c. The substance of each warning; and d. Annex hereto copies of each such warning. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts 16 and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D further objects to the extent that this Interrogatory is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantities of asbestos, despite vast distinctions in their finished form and application, create similar potential hazards, if any. Subject to and without waiving its foregoing objections. Square D states that it has published and distributed written materials providing warnings, cautions and instructions with respect to potential hazards associated with the use ofits products. However, Square D has no reliable information that its electrical equipment products posed an asbestosrelated hazard when used as intended. Therefore, safety warnings accompanying Square D products were not altered on the basis ofwhether molded or bonded component parts manufactured from composite materials which could have contained some quantity of encapsulated asbestos and Square D is unaware of facts or circumstances necessitating the provision of such warnings or instructions in connection with the normal and intended use of its products. For purposes of defending itself in this litigation, however, Square D may retain expert witnesses to review case materials, prepare reports, and testify relative to, among other things, the historic and current understandings with respect to the connection between asbestos exposure, asbestos, fiber types, fiber release, and possible disease in humans, particularly in the context of the use and handling of electrical equipment products that may have included molded 17 or bonded component parts manufactured from composite materials. Disclosure of these experts and their work will be provided in accordance with the Court's Orders and the New Jersey Rules of Civil Procedure. . B.20. Set forth the name, address and job position of each and every individual who took part in your company's decision to place a warning on its asbestos or asbestos containing products. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course ofits over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D further objects to the extent that this Interrogatory is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantities of asbestos, despite vast distinctions in their finished form and application, create similar potential hazards, if any. Subject to and without waiving its foregoing objections. Square D incorporates by reference its objections and response to Interrogatory B. 19. 18 B.21. Prior to 1964, did any employee of the defendant ever recommend that it utilize a warning on its asbestos containing products? If so, identify each such employee, indicate when he made such a recommendation, indicate what the recommendation was, to whom it was given and what action was taken thereon. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D further objects to the extent that this Interrogatory is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantities of asbestos, despite vast distinctions in their finished form and application, create similar potential hazards, if any. Subject to and without waiving its foregoing objections. Square D incorporates by reference its objections and response to Interrogatory B. 19. B.22. Has defendant ever established or maintained a library or libraries which in any way dealt with industrial hygiene, medicine, safety and engineering? If so, state: a. Where the library was or is located; 19 b. The names of all journals which that library subscribed to: c. For whom and for what purpose the library was established; and d. Whether there is an inventory of the books and publications which are or were housed in this library, and if so, attach a copy hereto. RESPONSE: Subject to and without waiving its foregoing objections, Square D maintained general reference materials and technical materials throughout the company which may have included, from time to time, various industry periodicals, occupational health and medicine periodicals, and other topical reference materials. Such materials, however, were not indexed throughout the company, readily searchable, or organized in a library. Square D's investigation of these matters is ongoing, and Square D reserves the right to amend or supplement this response. B.23. Did defendant or its agents or employees ever make any effort to keep abreast of medical literature concerning potential health hazards posed by the use of and/or exposure to asbestos? Indicate the name, addresses and job positions of all your company's employees who reviewed this literature. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D further objects that this 20 Interrogatory is vague and ambiguous. Square D also objects that this Interrogatory is vague and ambiguous in its use ofthe phrase "ever make any effort to keep abreast ofmedical literature." Additionally, Square D objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, and seeks information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence in that Plaintiffs do not allege that they were Square D employees or injured in any way at facilities where Square D products were manufactured or assembled. Square D also objects to this Interrogatory to the extent that it is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantity of encapsulated asbestos, despite vast distinctions in their sold form and application, create similar potential hazards, if any. By way of further objection, the process of designing and manufacturing Square D products is vastly different from any exposure Plaintiffs may allege. Put simply, any asbestos that may have been incorporated in certain composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method of manufacture of a Square D product would present a significantly different potential exposure to asbestos that would not be similar in any way to Plaintiffs' alleged exposure. As such, information on the means and method ofmanufacture of Square D products is not relevant to this action and is an unfair attempt to mislead the jury as to the nature of Plaintiffs' alleged injury. B.24. Prior to 1964 had your company done any studies or tests or had your company participated in, been the subject of, or been aware of any studies or tests by others concerning the potential effects of inhalation of asbestos dust or fibers by one using or being exposed to asbestos or asbestos containing products. If so, state: a. The date each study or test was conducted and the date defendant became aware of said study or test; b. The names and addresses ofthe persons conducting each test or study; 21 c. The purpose of the study or test; d. The results of each study or test; and e. Ifreduced to writing attach a copy hereto. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D also objects to this Interrogatory to the extent that it is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantity of encapsulated asbestos, despite vast distinctions in their sold form and application, create similar potential hazards, if any. Square D also objects that this Interrogatory is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence because Plaintiffs in this litigation do not claim that they worked at or were otherwise exposed to asbestos-containing products at Square D facilities. By way of further objection, the 22 process of designing and manufacturing Square D products is vastly different from any exposure Plaintiffs may allege. Put simply, any asbestos that may have been incorporated in certain composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method ofmanufacture of a Square D product would present a significantly different potential exposure to asbestos that would not be similar in any way to Plaintiffs' alleged exposure. As such, information on the means and method of manufacture of Square D products is not relevant to this action and is an unfair attempt to mislead the jury as to the nature of Plaintiffs' alleged injury. Subject to and without waiving its foregoing objections, Square D has no reliable information that its products posed an asbestos- related hazard when used as intended. As such, Square D did not conduct tests to determine whether its electrical equipment products release respirable asbestos when used as intended in the ordinary course ofbusiness. For purposes of defending itself in this litigation, however, Square D may retain expert witnesses to review case materials, prepare reports, and testify relative to, among other things, the use and handling of electrical equipment products that may have included molded or bonded component parts manufactured from composite materials. Disclosure of the work of the aforementioned experts shall be provided in accordance with the Court's Orders and the New Jersey Rules of Civil Procedure. B,25. Prior to 1964, did defendant's agents or employees conduct any experiments with laboratory animals to determine whether or not its asbestos containing products were potentially hazardous to the health of workers who were using them? If so, for each such experiment which was conducted, indicate who conducted it, state when it was conducted and describe the results of each such experiment. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally 23 unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course ofits over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to this Interrogatory to the extent that it is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantity of encapsulated asbestos, despite vast distinctions in their sold form and application, create similar potential hazards, if any. Subject to and without waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B.24. By way of further response, Square D is unaware of facts or circumstances necessitating it perform such experiments. B.26. Since 1964 has your company done any studies or tests or has your company participated in, been the subject of, or been aware of any studies by others concerning the effects of inhalation of asbestos dust and fibers by one using or being exposed to asbestos or asbestos containing products? If so, state the following: a. The date each such study or test was conducted and the date defendant became aware of said study or test; b. The names and addresses of persons conducting the tests or studies; c. The purpose of the tests; d. The results of each test or study; and e. Attach a copy of any reports based upon each study or test. 24 RESPONSE: la addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D also objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D also objects to this Interrogatory to the extent that it is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantity of encapsulated asbestos, despite vast distinctions in their sold form and application, create similar potential hazards, if any. Square D further objects that this Interrogatory is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence because Plaintiffs in this litigation do not claim that they worked at or were otherwise exposed to asbestos-containing products at Square D facilities. By way of further objection, the process of designing and manufacturing Square D products is vastly different from any exposure Plaintiffs may allege. Put simply, any asbestos that may have been incorporated in certain 25 composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method ofmanufacture of a Square D product would present a significantly different potential exposure to asbestos that would not be similar in any way to Plaintiffs' alleged exposure. As such, information on the means and method of manufacture of Square D products is not relevant to this action and is an unfair attempt to ' mislead the jury as to the nature of Plaintiffs' alleged injury. Subject to and without waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B.24. B.27. Since 1964, has defendant or its agents or employees sponsored or performed any laboratory experiments with animals to determine whether or not its asbestos containing products were potentially hazardous to the health of workers who were using them? If so, state who conducted each study, indicate where each study was conducted, and describe what the results of each test were. RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory B.24. B.28. Prior to 1964, did defendant or its agents or employees ever go out to construction sites, factories or power houses where its asbestos or asbestos containing products were being used to determine or measure the levels of asbestos dust or fibers in the work environment? If so, for each such study or experiment that was conducted, set forth the following information: a. When and where each measurement, study or test was conducted; b. Who conducted each measurement, study or test; c. What types of equipment were utilized to measure the levels of asbestos dust or fibers in the air; d. What the results of each measurement, test or study were; and e. Attach a copy of any reports concerning the measurements, tests or studies. RESPONSE: Subject to and without waiving its foregoing objections. Square D incorporates by reference its objections and response to Interrogatory B.24. 26 B.29. Since 1964, has defendant and/or its agents or employees ever gone out to any construction sites, factories or power houses where its asbestos or asbestos containing products were being used to determine the levels of asbestos dust or fibers which were in the work environment? If so, for each study or experiment which was conducted, set forth the following information: a. Who conducted each measurement, study or test; b. When and where each measurement, study or test was conducted; c. What type of equipment was utilized to measure the levels of asbestos in the working environment; d. What the results of each study, measurement or test were; and e. Attach a copy of any report concerning each measurement, study or test. RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory B.24. B.30. Give a complete description of all programs implemented and precautions taken by the defendant at its plants and facilities where it manufactures asbestos or asbestos containing products to reduce the levels of asbestos dust and fibers in the air. Include in this description all programs implemented and precautions taken since each plant was in operation. Include in this answer the date that each precaution was taken or procedure was implemented. RESPONSE: hi addition to its foregoing General Objections, Square D objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D also objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, and seeks information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence in that Plaintiffs do not allege that they were Square D employees or injured in any way at facilities where Square D products were manufactured or assembled. Square D further objects to this Interrogatory to the extent that it is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes 27 that all products incorporating some quantity of encapsulated asbestos, despite vast distinctions in their sold form and application, create similar potential hazards, if any. By way of further objection, the process of designing and manufacturing Square D products is vastly different from any exposure Plaintiffs may allege. Put simply, any asbestos that may have been incorporated in certain composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method ofmanufacture of a Square D product would present a significantly different potential exposure to asbestos that would not be similar in any way to Plaintiffs' alleged exposure. As such, information on the means and method of manufacture of Square D products is not relevant to this action and is an unfair attempt to mislead the jury as to the nature of Plaintiffs' alleged injury. B.31. Did defendant at any time require its employees who worked in the manufacture of asbestos or asbestos containing products to wear respirators, face masks or other protective devices? If so, set forth which employee (by type) was required to wear such protective devices, when the directive relative to same was issued for each type of employee and specify what type of device was to be worn by each type of employee. RESPONSE: In addition to its foregoing General Objections, Square D objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, and seeks information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence in that Plaintiffs do not allege that they were Square D employees or injured in any way at facilities where Square D products were manufactured or assembled. Square D further objects to this Interrogatory to the extent that it is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantity of encapsulated asbestos, despite vast distinctions in their sold form and application, create similar potential hazards, if any. By way of further objection, the process of designing and manufacturing Square D products is vastly different from any exposure Plaintiffs 28 may allege. Put simply, any asbestos that may have been incorporated in certain composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method ofmanufacture of a Square D product would present a significantly different potential exposure to asbestos that would not be similar in any way to Plaintiffs' alleged exposure. As such, information on the means and method ofmanufacture of Square D products is not relevant to this action and is an unfair attempt to mislead the jury as to the nature of Plaintiffs' alleged injury. B.32. Give a complete explanation of why each and every employee set forth in the preceding answer was required to wear a respirator, face mask or other protective device while working with asbestos. RESPONSE: In addition to its foregoing General Objections, Square D objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, and seeks information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence in that Plaintiffs do not allege that they were Square D employees or injured in any way at facilities where Square D products were manufactured or assembled. Square D further objects to this Interrogatory to the extent that it is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantity of encapsulated asbestos, despite vast distinctions in their sold form and application, create similar potential hazards, if any. By way of further objection, the process of designing and manufacturing Square D products is vastly different from any exposure Plaintiffs may allege. Put simply, any asbestos that may have been incorporated in certain composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method ofmanufacture of a Square D product would present a significantly different potential exposure to asbestos that would not be similar in any way to 29 Plaintiffs' alleged exposure. As such, information on the means and method ofmanufacture of Square D products is not relevant to this action and is an unfair attempt to mislead the jury as to the nature of Plaintiffs' alleged injury. B.33, Has any worker employed by your company, its subsidiaries or affiliates ever filed a worker's compensation claim against defendant or its predecessors, affiliates or subsidiaries, for an occupational disease or condition which was allegedly caused by exposure to asbestos, asbestos products, asbestos dust or fibers? If so, set forth: a. The date each claim was made; b. Where each claim was made; c. The name and address ofthe party making the claim; and d. The name and address of the party against whom the claim was made. RESPONSE: hi addition to its foregoing General Objections, Square D objects that this Interrogatory seeks legal conclusions regarding "predecessors," "affiliates," and "subsidiaries." Square D also objects to the phrase "asbestos products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D also objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, and seeks information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence in that Plaintiffs do not allege that they were Square D employees or injured in any way at facilities where Square D products were manufactured or assembled. Square D further objects to this Interrogatory to the extent that it is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantity of encapsulated asbestos, despite vast distinctions in their sold form and application, create similar potential hazards, if any. By way of further objection, the process of designing and manufacturing Square D products is vastly different from 30 any exposure Plaintiffs may allege. Put simply, any asbestos that may have been incorporated in certain composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method ofmanufacture of a Square D product would present a significantly different potential exposure to asbestos that would not be similar in any way to Plaintiffs' alleged exposure. As such, information on the means and method of manufacture of Square D products is not relevant to this action and is an unfair attempt to mislead the jury as to the nature of Plaintiffs' alleged injury. B.34. If any employee or officer of defendant has testified at trial or by deposition in any litigation involving an alleged occupational exposure to asbestos, state: a. Name, address and title of each such person who testified; b. Date, location and form of testimony; and c. Whether defendant has a copy of such testimony. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at Issue in this case. Subject to and without waiving its foregoing General Objections, with respect to electrical equipment products, Robert Barbaglia 31 was deposed in connection with the Maynard and Carter cases in West Virginia in 2005, the Pounds case in California in 2006, the Eubanks case in California in 2007, the Engle case in Minnesota in 2007, the Whitmire case in California in 2008, and the Grossman case in New York in 2008. B.35. Has defendant at any time since its inception, maintained any office or department dealing with medical research? If so, state: a. The name of each such department; b. The dates each such department was in operation; and c. The name, address and job position of each such person who has been in charge of said department or departments. RESPONSE: In addition to its foregoing General Objections, Square D objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, and seeks information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence in that Plaintiffs do not allege that they were Square D employees or injured in any way at facilities where Square D products were manufactured or assembled. Square D also objects that the phrase "dealing with medical research" is vague and ambiguous. By way of further objection, the process of designing and manufacturing Square D products is vastly different from any exposure Plaintiffs may allege. Put simply, any asbestos that may have been incorporated in certain composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method ofmanufacture ofa Square D product would present a significantly different potential exposure to asbestos that would not be similar in any way to Plaintiffs' alleged exposure. As such, information on the means and method of manufacture of Square D products is not relevant to this action and is an unfair attempt to mislead the jury as to the nature ofPlaintiffs' alleged injury. 32 B,36. When was the first time the defendant became aware of or knowledgeable of any disease or illness associated with or causally related to the inhalation of asbestos, asbestos fibers or asbestos dust in any form whatsoever? Indicate which disease defendant became aware of and describe how defendant became aware of its alleged relationship to inhalation or exposure to asbestos. RESPONSE: In addition to its foregoing General Objections, Square D objects to this Interrogatory because it poses an incomplete hypothetical without context and without any connection whatsoever to any products allegedly manufactured by Square D. Square D further objects to the extent that this Interrogatory is misleading and unfair because it merely presumes facts and information that do not exist, are unproven, and/or do not apply to Square D. For example, this Interrogatory erroneously and unfairly presumes that all products incorporating some quantities of asbestos, despite vast distinctions in their finished form and application, create similar potential hazards, if any. Subject to and without waiving its foregoing objections. Square D states that it has no reliable information that its products posed an asbestos-related hazard when used as intended. By way of further response, in the 1970s and early-1980s, Square D became generally aware of emerging regulatory restrictions and requirements associated with the use and handling of, and reporting obligations in connection with, asbestos and later, certain non-electrical products containing asbestos; efforts by component part suppliers to supply non asbestos containing substitute products; and a generalized public concern with asbestos exposure. By way of further response, Square D may retain expert witnesses to review case materials, prepare reports, and testify relative to, among other things, the historic and current understandings with respect to the connection between asbestos exposure, asbestos, fiber types, fiber release, and possible disease in humans, particularly in the context of the use and handling of electrical equipment products that may have included molded or bonded component parts manufactured from composite materials. Disclosure ofthese experts and their work will he provided in accordance with the Court's orders and the New Jersey Rules of Civil Procedure. 33 B.37. In reference to the preceding interrogatory, if defendant acknowledges a casual relationship between asbestos and disease or illness, set forth the following information: a. What diseases or illnesses defendant acknowledges are causally related to or associated with exposure to asbestos dust or fibers; b. The date upon which defendant became aware of the association with or casual relation to each such disease or illness; c. The date upon which defendant confirmed the casual relation of each such disease to exposure to asbestos dust or fibers; and d. How defendant became aware of each such casual relationship or association, indicating the source of all such information, RESPONSE: In addition to its foregoing General Objections, Square D objects that this Interrogatory calls for an expert opinion. Subject to and without waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B.36. B.38, If your company manufactured any products which contained asbestos and which were commonly used by insulation workers and pipe coverers, describe how the following products were cut, shaped, mixed and applied when used: a. Asbestos cement; b. Asbestos containing pipe covering; c. Asbestos sheeting; and d. Asbestos insulation to cover extremes ofheat as well as cold. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts 34 and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrases "insulations workers" and "pipe covers' as being vague and ambiguous as applied to Square D. Subject to and without waiving its foregoing objections, Square D reasonably believes that this Interrogatory is not directed to it. B.39. Prior to 1964, were there any memoranda written by, distributed, or circulated among defendant's employees, agents or representatives concerning the potential health hazards concerned with asbestos containing products? If so, state: a. Dates of each memorandum; b. Name, address and job position of each individual who wrote each memorandum; c. Name and address and job position of each individual to whom the memorandum was directed; d. Where each memorandum is kept; and e. Attach copies of each memorandum hereto. RESPONSE: In addition to its foregoing General Objections, Square D objects to the phrase "asbestos-containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D also objects that this Interrogatory is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence because Plaintiffs in this litigation do not claim that they worked at or were otherwise exposed to asbestos-containing products at Square D facilities. By way of further objection, the process of designing and manufacturing Square D products is vastly different from any exposure Plaintiffs may allege. Put simply, any asbestos that may have been incorporated in certain composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method ofmanufacture of a 35 Square D product would present a significantly different potential exposure to asbestos that would not be similar in any way to Plaintiffs' alleged exposure. As such, information on the means and method of manufacture of Square D products is not relevant to this action and is an unfair attempt to mislead the jury as to the nature of Plaintiffs' alleged injury. B.40. Has defendant or its predecessor corporations ever had a division, affiliate or subsidiary which was involved in contracting for or installation of asbestos-containing materials in New Jersey? If so, for each such entity involved in the contracting or installation of these products, set forth the following information: a. Name of each such entity and the nature of its relationship to the parent corporation; and b. The exclusive dates that each ofthe above mentioned entities were in existence. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D objects to the phrase "asbestos-containing materials" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D also objects that the phrase "contracting for or installation of' is vague and ambiguous. Square D further objects that this Interrogatory seeks legal conclusions regarding "predecessor corporations," "divisions," 36 "affiliates/' and "subsidiaries." Square D further objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, and seeks information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence in that Plaintiffs do not allege that they were Square D employees or injured in any way at facilities where Square D products were manufactured or assembled. Subject to and without waiving its foregoing objections, and to the best of its present knowledge, no. By way of further response, but without conceding the relevance ofthe same. Square D has offered certain maintenance and/or field repair services for its electrical equipment products. B.41. Did defendant ever provide any of the employees who worked in the contracting for or installation of asbestos containing materials with any respirators, face masks or protective clothing? If so, indicate what types of protective clothing, respirators or face masks were provided, describe when each type was first provided to each employee and describe why they were provided to each type of employee. RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory B.40. B.42. Has any individual who was ever employed in the contracting and insulation business referred to above ever filed a claim for workmen's compensation because of an alleged occupational disease sustained allegedly because of occupational exposure to asbestos? If so, for each such employee who has filed a claim set forth the following information: a. Name of each such employee; b. When each claim was filed; c. Where each claim was filed; and d. Name of the attorney who represented the petitioner and respondent. RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory B.40. B.43. State the full name, job title and present residences, business and professional addresses of any and all persons who have knowledge of any relevant facts relating to this case and the defense of your company. Unless already set forth in answers to a prior question, set forth in detail the facts of which each person allegedly has knowledge. 37 RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course ofits over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D further objects to this Interrogatory to the extent it seeks information which is not, and may not have been, within the personal knowledge or possession or control of Square D, its employees, or agents. Square D further objects that this Interrogatory is premature in that discovery is ongoing, including discovery of Plaintiffs. Subject to and without waiving its foregoing objections, Square D states that it has not yet made a determination regarding witnesses it may call in a trial ofthis matter. By way of further response, Square D will produce its witness list in accordance with the Court's Orders and the New Jersey Rules of Civil Procedure. B.44. State the name, address and credentials of each and every expert witness you intend to utilize at the time of trial, and annex hereto a copy of their report. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally 38 unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D further objects that this Interrogatory is premature in that discovery is ongoing, including discovery of Plaintiffs. Subject to and without waiving its foregoing objections, Square D states that it has not yet made a determination regarding expert witnesses it may call in a trial ofthis matter. By way of further response, Square D may retain expert witnesses to review case materials, prepare reports, and testify relative to, among other things, the historic and current understandings with respect to the connection between asbestos exposure, asbestos, fiber types, fiber release, and possible disease in humans, particularly in the context of the use and handling of electrical equipment products that may have included molded or bonded component parts manufactured from composite materials. Disclosure of these experts and their work will he provided in accordance with the Court's orders and the New Jersey Rules of Civil Procedure. B.45. Do you contend that Plaintiffs' illness is a consequence of the negligence or the fault of a third party or anyone who is not a party to this action? If so, state the name and address of each such party and set forth all facts which support your contention. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly he at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into 39 the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Subject to and without waiving these objections, Square D responds that the special and affirmative defenses which maybe applicable in this case have been set forth in Square D's Answer to the Complaint, thus giving Plaintiffs notice of Square D's potential defenses to the Complaint. However, Square D has been provided with limited information regarding the basis of Plaintiffs' allegations against Square D. At the present time, and under the circumstances of such limited information base, Square D's investigation and discovery regarding the issues raised by those defenses is continuing. By way of further response. Square D does not reasonably believe that its products posed an asbestosrelated hazard when used as intended. Square D states that Plaintiffs have alleged exposure to many asbestos-containing products. If Plaintiffs have sustained asbestos-related injuries. Square D states that Plaintiffs were injured by the products or actions of other parties, not Square D. Moreover, Square D may retain expert witnesses to review case materials, prepare reports, and testify relative to, among other things, the historic and current understandings with respect to the connection between asbestos exposure, asbestos, fiber types, fiber release, and possible disease in humans, particularly in the context of the use and handling of electrical equipment products that may have included molded or bonded component parts manufactured from composite materials. Disclosure of these experts and their work will be provided in accordance with the Court's Orders and the New Jersey Rules of Civil Procedure. 40 B.46. Do you contend that the illness and/or death of the decedent in this action was not causally related to an occupational exposure to asbestos dust and fibers? If so, give a full and detailed description of your contentions. RESPONSE: In addition to its foregoing General Objections, Square D objects that this Interrogatory calls for expert medical opinions which are beyond the scope ofknowledge of Square D. Subject to and without waiving its foregoing objections, after a reasonable inquiry concerning the subject matter ofthis Interrogatory, Square D states that the information known or readily obtainable is insufficient to enable Square D to respond to this Interrogatory. Plaintiffs' medical records, including pathology materials, still need to be obtained and reviewed by defense experts. By way of further response, Square does not reasonably believe that its electrical equipment products posed an asbestos-related hazard when used as intended. For purposes of defending itself in this litigation, however. Square D may retain expert witnesses to review case materials, prepare reports, and testify relative to, among other things, the historic and current understandings with respect to the connection between asbestos exposure, asbestos, fiber types, fiber release, and possible disease in humans, particularly in the context of the use and handling of electrical equipment products. Disclosure of these experts and their work will be provided in accordance with the Court's Orders and the New Jersey Rules of Civil Procedure. B.47. Do you contend that other agents and/or substances caused the illness and/or death of Plaintiffs in this matter? If so, identify each such agent and/or substance and set forth all facts to support your contentions. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the 41 course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D further objects to this Interrogatory to the extent it seeks information which is not, and may not have been, within the personal knowledge or possession or control of Square D, its employees, or agents. Square D further objects that this Interrogatory is premature in that discovery is ongoing, including discovery ofPlaintiffs, Square D further objects that this Interrogatory calls for expert medical opinions which are beyond the scope ofknowledge of Square D. Subject to and without waiving its foregoing objections, after a reasonable inquiry concerning the subject matter ofthis Interrogatory, Square D states that the information known or readily obtainable is insufficient to enable Square D to respond to this Interrogatory. Plaintiffs' medical records, including pathology materials, still need to be obtained and reviewed by defense experts. For purposes of defending itself in this litigation, Square D may retain expert witnesses to review case materials, prepare reports, and testify relative to, among other things, the historic and current understandings with respect to the connection between asbestos exposure, asbestos, fiber types, fiber release, and possible disease in humans, particularly in the context of the use and handling of electrical equipment products. Disclosure of these experts and their work will be provided in accordance with the Court's Orders and the New Jersey Rules of Civil Procedure. B.48. Has defendant and/or its agents or employees obtained any statements from anyone who had knowledge ofthe facts surrounding this cause of action? If so, set forth: a. Name, address and job position ofthe person that obtained the statement; b. The name, address and job position of the person who gave the statement; 42 c. The date the statement was given; and d. Whether the statement is in writing, and if so, who has custody of it. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts arid pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D further objects that this Interrogatory seeks legal conclusions regarding "agents." Square D also objects that this Interrogatory is premature in that discovery is ongoing, including discovery of Plaintiffs. Subject to and without waiving its foregoing objections, Square D states that to the best of its present knowledge it has not obtained statements other than depositions taken in this case. By way of further response, Square D's investigation of this matter is ongoing, and it reserves the right to amend or supplement this response. B.49. Does defendant contend that Plaintiffs or Plaintiffs' decedent suffered injuries and/or death due to his own negligence? If so, set forth all facts which support your contentions. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the 43 discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Subject to and without waiving these objections. Square D responds that the special and affirmative defenses which maybe applicable in this case have been set forth in Square D's Answer to the Complaint, thus giving Plaintiffs notice of Square D's potential defenses to the Complaint. However, Square D has been provided with limited information regarding the basis ofPlaintiffs' allegations against Square D. At the present time, and under the circumstances of such limited information base. Square D's investigation and discovery regarding the issues raised by those defenses is continuing. By way of further response. Square D does not reasonably believe that its products posed an asbestosrelated hazard when used as intended. Square D states that Plaintiffs have alleged exposure to many asbestos-containing products. If Plaintiffs have sustained asbestos-related injuries, Square D states that Plaintiffs were injured by the products or actions of other parties, not Square D. Moreover, Square D may retain expert witnesses to review case materials, prepare reports, and testify relative to, among other things, the historic and current understandings with respect to the connection between asbestos exposure, asbestos, fiber types, fiber release, and possible disease in humans, particularly in the context of the use and handling of electrical equipment products that may have included molded or bonded component parts manufactured from composite 44 materials. Disclosure of these experts and their work will be provided in accordance with the Court's Orders and the New Jersey Rules of Civil Procedure. B. 50. Does defendant contend that Plaintiffs or Plaintiffs' decedent failed to use defendant's asbestos or asbestos containing products properly? If so, set forth all facts which support your contentions. RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory B.49. C. l. Has defendant and/or its affiliates or subsidiaries purchased asbestos fiber for use in its business or for manufacturing its products? If so, set forth the following information: a. The inclusive dates that your company purchased asbestos fiber; b. The name and address of each and every entity that you purchased the asbestos fiber from; c. The nature and types ofproducts that your company used asbestos fiber for; and d. The type of asbestos fiber that your company purchased. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course ofits over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D further objects that this 45 Interrogatory seeks legal conclusions regarding "affiliates" and "subsidiaries." Subject to and without waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B.14. C.2. Does defendant have or has it had any plants, factories or production facilities located in the State of New Jersey which were or are engaged in the importation, manufacture, processing, converting, compounding, packaging, distribution, and/or sale of asbestos, asbestos containing products and/or asbestos containing insulation products? If so, for each such plant, factory or facility which is or has been located in New Jersey, set forth the following information; a. The name and address of each such plant, factory or production facility; b. The inclusive dates that each plant, factory or facility existed; and c. A complete and detailed description of all products that each plant, factory or production facility was engaged in producing (include in your description the type ofproduct and its generic and trade name). RESPONSE: In addition to its foregoing General Objections, Square D objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D further objects to the phrase "asbestos containing insulation products" as being vague and ambiguous, particularly as applied to Square D. Square D also objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, and seeks information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence in that Plaintiffs do not allege that they were Square D employees or injured in any way at facilities where Square D products were manufactured or assembled. By way of further objection, the process of designing and manufacturing Square D products is vastly different from any exposure Plaintiffs may allege. Put simply, any asbestos that may have been incorporated in certain composite materials would be encapsulated and thus Plaintiffs would not be exposed to respirable asbestos. Accordingly, the means and method ofmanufacture of a Square D product would present a significantly 46 different potential exposure to asbestos that would not be similar in any way to Plaintiffs' alleged exposure. As such, information on the means and method ofmanufacture of Square D products is not relevant to this action and is an unfair attempt to mislead the jury as to the nature of Plaintiffs' alleged injury. C.3. Indicate which asbestos products and asbestos materials manufactured and distributed by the defendant are or were classified as "insulating materials." RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrases "asbestos products" and "asbestos materials" to the extent that they imply all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D further objects that the phrase "insulating materials" is vague and ambiguous, particularly as applied to Square D. Subject to and without waiving its foregoing objections, Square D did not manufacture "insulating materials" as it reasonably understands that phrase and as it is commonly used in asbestos litigation. 47 C.4. With reference to the preceding question, give a Ml and complete description of the purposes for which defendant's asbestos containing insulating materials were designed. RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory C.3. C.5. Set forth the name and address of each and every entity that your company purchased or received asbestos fiber from which was utilized in the manufacture of your company's asbestos containing insulation products. Include in your answer the inclusive dates that your company purchased asbestos from each such entity. RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory C.3. C.6. As to any asbestos products or raw asbestos mined, converted, fabricated, produced, compounded, manufactured, processed, sold or distributed by defendant, state whether any was shipped or sold to Plaintiffs' employer in New Jersey either directly or through a third party, stating which. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Subject to and without waiving its 48 foregoing objections. Square D sold its products through distributors and original equipment manufacturers. Thus at the present time, Square D is generally unaware as to the specific identity of entities or persons to whom its products were ultimately sold, at which job sites they may have been delivered or used, or when those sales took place during time periods when those products incorporated component parts, some of which may have contained composite materials that contained some quantity of encapsulated asbestos. By way of additional response. Square D states that at the present time, and in the absence of additional information, such as, for example, product-specific catalog numbers and/or factory order numbers. Square D is generally unable to ascertain when, where, or to whom certain Square D electrical equipment products were supplied to or placed into service. Subject to and without waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B.18. C.7. If the answer to C6 is in the affirmative, state as to each asbestos product, or raw asbestos: a. Exactly what produces) or type(s) ofasbestos was (were) shipped or sold to Plaintiffs' employer; b. The dates and quantities of each such product shipped or sold; c. Whether any warnings, cautions, caveats or directions accompanied the materials so shipped, the date these appeared and the exact wordings of the warnings, cautions, caveats or directions and where the warnings, cautions, caveats or directions appeared; d. The name and address of any intermediate supplier or distributor who sold this defendant's products to Plaintiffs' employer during the period referred to above; e. Did your company affix its corporate logo or insignia on the packages of asbestos containing insulation products that it distributed and sold? If so, describe the type oflogo or insignia which was used, indicate which products it was affixed to, and set forth the inclusive dates that each insignia or logo was utilized. Annex hereto a photograph or copy of each such logo described in this matter; and 49 f, Please describe in detail the type ofpackages in which defendant has sold, distributed or manufactured asbestos material, listing the dates each type ofpackage was used, a physical description thereof and description of any printed material or trademark that appeared thereon. RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory C.6. C.8. Have any of the products listed in Interrogatory C7 above been altered in chemical composition since being marketed? If so, set forth the following information: a. The date of each alteration; b. A detailed description ofthe nature of each alteration; and c. The reason for such alteration. RESPONSE: Subject to and without waiving its foregoing General Objections, Square D incorporates by reference its objections and response to Interrogatory C.6 and C.7. C.9. Have you discontinued manufacturing and/or distributing and/or supplying or selling any asbestos or asbestos products referred to in C7. If so, set forth the following information: a. What such product is; b. The reasons therefor; and c. When the discontinuance took place. If your answer to C6 is either "No" or "Unknown" but your answer to B14 is "Yes" provide answers to CIO through C18. Otherwise you may proceed to C19. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts 50 and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Subject to and without waiving its foregoing objections. Square D incorporates by reference its objections and response to Interrogatories C.6 and C.7. C.10. Give a complete and detailed description of each and every asbestos containing product that your company has designed, manufactured and distributed into the stream of commerce. Include in your description the trade, brand and generic names of each such product and indicate the type and amount of asbestos that was contained in each particular product. Include in this answer the inclusive dates that each particular product was manufactured and distributed. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing product" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Subject to and without 51 waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B.14. C.ll. With reference to your answer to B18 state the names and addresses of the entities to whom the products were sold. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course ofits over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Subject to and without waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B. 18. C.12. Did your company and/or its affiliates or subsidiaries do business with or utilize any distributors in the State of New Jersey for purposes of selling or installing its asbestos products? If so, identify each such entity, indicate and describe the nature of the business that you did with each such entity, and set forth the dates this business relationship existed. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally 52 unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D further objects that this Interrogatory seeks legal conclusions regarding "affiliates" and "subsidiaries." Subject to and without waiving its foregoing objections, Square D sold its products through distributors and original equipment manufacturers. Thus at the present time, Square D is generally unaware as to the specific identity of entities or persons to whom its products were ultimately sold, at which job sites they may have been delivered or used, or when those sales took place during time periods when those products incorporated component parts, some ofwhich may have contained composite materials that contained some quantity of encapsulated asbestos. By way of additional response, Square D states that at the present time, and in the absence of additional information, such as, for example, product-specific catalog numbers and/or factory order numbers, Square D is generally unable to ascertain when, where, or to whom certain Square D electrical equipment products were supplied to or placed into service. Subject to and without waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B. 18. C.13. Has your company ever employed any employees or salesmen whose responsibility it was to sell your company's asbestos containing products to a geographical area 53 encompassing the State of New Jersey? If so, for each such employee or salesman who worked for your company, indicate the dates ofhis employment, his name and address. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course ofits over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase ``asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D also objects to the phrase "geographical area" as being vague and ambiguous. Subject to and without waiving its foregoing objections. Square D states that it sold its products primarily through distributors or original equipment manufacturers. Thus, at the present time. Square D is generally unaware as to the specific identity of entities or persons to whom its products were ultimately sold, at which job sites they may have been delivered or used, or when those sales took place. Moreover, at the present time. Square D is generally unable to ascertain specifically to whom its products were sold during time periods when certain of its products may have contained molded or bonded component parts manufactured from composite materials which could have contained some quantity of encapsulated asbestos. By way of additional response, Square D states that at the 54 present time, and in the absence of additional information, such as, for example, product-specific catalog and/or factory order numbers, Square D is generally unable to ascertain when, where, or to whom certain Square D electrical equipment products were supplied to or placed into service. Square D reserves the right, however, to supplement this response ifresponsive information becomes available. By way of further response, Square D has had sales offices in New Jersey, including at various times in Bellmawr, Parsippany, Pine Brook, Secaucus and Trenton. C, 14. Give a complete and detailed description of the manner in which your company packaged each of the asbestos containing products that it manufactured and/or distributed in the State of New Jersey. Include in your description the type of packaging which was used and the material each type ofpackaging was comprised of. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that tins Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products'3 to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Subject to and without waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B. 18. By way of further response, and without conceding the relevance of the 55 same, packaging of Square D electrical equipment products varied depending on the size and shape ofproducts, and would have included cardboard boxes and wooden crates. C.15. Did your company affix its corporate logo or insignia on the packages of asbestos containing products that it distributed and sole [sic] in the State of New Jersey? If so, describe the type of logo or insignia which was used, indicate which products it was affixed to, and set forth the inclusive dates that each insignia or logo was utilized. Annex hereto a photograph or copy of each such logo described in this answer. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course ofits over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Square D further objects that this Interrogatory seeks legal conclusions regarding "affiliates" and "subsidiaries." Subject to and without waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B. 18, By way of further response, and without conceding the relevance of the same, Square D sometimes used the "Square D" trademark and logo on many products. The Square D logo typically includes a blue or black capital letter "D" centered in a one-dimensional blue or black square box against a yellow or black background. 56 C.l 6. Did the packages or containers for the asbestos containing products that your company sold or distributed in the State of New Jersey contain any writing or labels? If so, for each such package or container which contained a label, set forth the following information about the writing on the package or label. a. The size of each label; b. The substance of all writing on the label; c. The inclusive dates that each writing or label appeared on each type of product; and d. Annex hereto copies of or photographs of each such label that your company used. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Additionally, Square D objects that this interrogatory is vague and ambiguous. Subject to and without waiving its foregoing objections, Square D incorporates by reference its objections and response to Interrogatories C.l4and C. 15. 57 C.17. Give a complete and detailed description of each and every asbestos containing product that your company has designed, manufactured and distributed into the stream of commerce. Include in your description the trade, brand and generic names of each such product and indicate the type and amount of asbestos that was contained in each particular product. Include in this answer the inclusive dates that each particular product was manufactured and distributed. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such. Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing product" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Subject to and without waiving the foregoing objections, Square D incorporates by reference its objections and response to Interrogatory B. 14. C.18. During the years that your company manufactured and/or sold asbestos containing materials, did your company prepare and/or publish any sales or promotional literature which depicted and describe there [sic] products? If so, describe the particular literature which your company prepared and indicate the information the literature contained. Describe who has custody of this literature at the present time. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly he at issue in this 58 case. As such. Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing materials" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Subject to and without waiving its foregoing objections, Square D states that over the years it has offered sales brochures in general, but such materials do not relate to "asbestos-containing products" as such. Moreover, Square D did not offer sales brochures related to "asbestos-containing products" as such. By way of further answer. Square D has published digests that would have referenced various Square D products. C.l 9. Has your company manufactured asbestos containing products and materials which were distributed by another entity or corporation under this name or trademark? If so, identify each such entity which sold or distributed these products, indicate which of your company's products this company marketed and indicate the inclusive dates that this particular commercial arrangement existed. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into 59 the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D also objects to the phrase "asbestos containing products" to the extent that it implies all Square D electrical equipment products contained asbestos components, which is expressly denied. Additionally, Square D objects that this Interrogatory is vague and ambiguous in its use ofthe phrase "under this name or trademark." Subject to and without waiving the foregoing objections, and to the best ofits present knowledge, Square D is unaware ofrebranding agreements involving electrical equipment products which may have contained molded or bonded component parts manufactured from composite materials. C.20. Has your company marketed under its own name or trademark any asbestos containing insulation products which were manufactured by another corporation? If so, identify each and every product which your company marketed which was manufactured by another corporation, indicate the inclusive dates that you marketed each product and describe the name, trade name and generic name of each such product which your company marketed. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many 60 hundreds of different products, product configurations, and many thousands ofindividual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D further objects to the phrase "asbestos containing insulation products" as being vague and ambiguous, particularly as applied to Square D, and to the extent that it implies all Square D electrical equipment products contained asbestos components, such an implication is expressly denied. Subject to and without waiving its foregoing objections. Square D states that it did not manufacture "asbestos containing insulation products" as it reasonably understands that term. C.21. Were any of the asbestos containing insulation products that defendant sold or distributed into the stream of commerce accompanied by written instructions or package inserts? If so, indicate which such products were provided with such instructions and package inserts, indicate when each product was accompanied by these materials, state the substance of what the instructions or package inserts stated and annex copies of same hereto. RESPONSE: In addition to its foregoing General Objections, Square D objects that Plaintiffs do not provide reasonable notice regarding what Square D products may allegedly be at issue in this case. As such, Square D objects that this Request is not reasonably calculated to lead to the discovery of admissible evidence and is an improper, overly broad, onerous, and fundamentally unfair attempt by Plaintiffs to require Square D to conduct a nearly unlimited investigation into the broad and diverse variety of electrical equipment products that it manufactured over the course of its over one hundred year history that vary greatly and could possibly include many hundreds of different products, product configurations, and many thousands of individual parts and pieces. Square D objects that Plaintiffs have failed to provide information, such as, for example, product-specific catalog numbers and/or factory order numbers, which would assist Square D in determining the products at issue in this case. Square D further objects to the phrase 61 "asbestos containing insulation products" as being vague and ambiguous, particularly as applied to Square D. Subject to and without waiving its foregoing objections, Square D states that it did not manufacture "asbestos containing insulation products" as it reasonably understands that term. 62 VERIFICATION Bird v. 3M Company, et al. Middlesex County, New Jersey I, Robert Barbaglia, state that'I am ah employee of Square D Company and- am authorized to make-this verification for- and on behalfofSquare D Company. I have read Defendant Square D Company's Responses to Defendant's Interrogatories Fonn B and am familiar with the contents thereof -Ideelare under penalty ofperjury under the laws ofthe State ofNew Jersey that the answers ofSquare D Company are true to the best ofmy knowledge, information, and belief as I have been informed by others, limited records and information available with respect to the subject matters at issue. August Is .2008 Robert Barbaglia \ 62 AFFIDAVIT OF SERVICE STATE OF NEW JERSEY COUNTY OF MIDDLESEX ) WILLIAM J. HARRISON III, being duly sworn, deposes and says: I am not a party to the action, am over 18 years of age and am employed by the law firm of K&L Gates, LLP, located at One Newark Center, 10th Floor, Newark, New Jersey 07102, On August 21, 2008, I served the within RESPONSES TO PLAINTIFF'S FORM B INTERROGATORIES, by Federal Express, to the last known address(es) of the addressee(s) as follows: TO: Rachel A. Placitella, Esq. (Via Federal Express) COHEN, PLACITELLA & ROTH, P.C. Attorneys for Plaintiffs 127 Maple Avenue Red Bank, New Jersey 07701 ALL REMAINING DEFENSE COUNSEL (Via First Class Mail) (See Attached Service Rider) Sworn to before me this 21st day of August, 2008 USA MARIE WHITE ' A,Notary Public of New Jersey My Commission Expires November 14,2009