Document RyLy3rRVKXaNpj7Xx9wNjLj7

FILE NAME Bechtel BECH DATE 1997 DOC BECH010 DOCUMENT DESCRIPTION Legal - Defendant's Responses to Interrogatories PHILIP R. PLACIER State Bar No. 029099 JENNIFER A. KUENSTER State Bar No.104607 THELEN MARRIN JOHNSON & BRIDGES LLP enn ane Two Embarcadero Center Suite 2100 San Francisco California 94111 Telephone 415 392-6320 Attorneys for Defendant SEQUOIA VENTURES INC formerly known as BECHTEL CORPORATION 10 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF ALAMEDA 12 IN RE 13 COMPLEX ASBESTOS LITIGATION 14 15 16 IN RE 17 SHIPYARD AND APPLICATOR ASBESTOS CASES CONSOLIDATED 18 FOR DISCOVERY Case No 607734-9 DEFENDANT SEQUOIA VENTURES INC.'S FORMERLY KNOWN AND ERRONEOUSLY SUED AS BECHTEL CORPORATION SUPPLEMENTAL RESPONSES INTERROGATORIES INTERROGATORIES No. 537868-7 19 PROPOUNDING PARTY Plaintiffs 20 RESPONDING PARTY Defendant SEQUOIA VENTURES INC 21 SET NUMBER ONE 1 22 Defendant SEQUOIA VENTURES INC FORMERLY KNOWN AS 23 BECHTEL CORPORATION Defendant hereby further responds to 24 Plaintiffs Interrogatories to Defendant | 25 i GENERAL OBJECTIONS 26 The following General Objections apply to and are 27 incorporated herein by reference in each and every response to C. Senior Administrative Assistant d Mr. Pugliese was first employed with Bechtel in May 1989 as a senior paralegal Mr. Pugliese assumed hi current position of Senior Administrative Assistant in September 1992 INTERROGATORY NO 4 State whether YOU have ever been registered or qualified to do business in the State of California If so state the date YOU became qualified to conduct business in the 10 State of California 11 SUPPLEMENTAL RESPONSE TO INTERROGATORY NO 4 12 Bechtel Brothers McCone Corporation now known as 13 Sequoia Ventures Inc. was issued a contractor's license by 14 the State of California in 1945 15 INTERROGATORY No. 16 16 If THIS DEFENDANT owned or operated facilities in 17 which CONTAINING PRODUCT have been manufactured 18 processed and assembled please state 19 a the date said facilities began operation 20 b the date said facility ceased operation and c 21 the name of each type of CONTAINING PRODUCT 22 manufactured processed or assembled at each such facility 23 SUPPLEMENTAL RESPONSE TO INTERROGATORY NO 16 24 25 a 1946 b 1953 26 C. Large bore pipe 27 INTERROGATORY NO 33 2 Has THIS DEFENDANT distributed any brochures or pamphlets that contain warnings of any asbestos health hazards if so please state a the wording of such warning b the method used to distribute such brochures or pamphlets C. the date such brochures or pamphlets were first issued 10 d whether THIS DEFENDANT has exemplar of such 11 brochures or pamphlets 12 e 13 exemplar the IDENTITY of the custodian of such 14 SUPPLEMENTAL RESPONSE TO INTERROGATORY NO 33 15 Defendant did not manufacture and distribute any 16 containing product At this time Defendant has no 17 information that it distributed any brochures or pamphlets 18 that contained warnings of any asbestos health 19 hazards 20 INTERROGATORY NO 34 21 Did THIS DEFENDANT warn its employees and 22 CONTRACT UNIT anywhere in the United States that exposure 23 to asbestos could be hazardous to human health If so state a whether copies of DOCUMENTS containing such 25 warnings exist 26 b the IDENTITY of the custodian of such 27 27 DOCUMENTS.