Document V3KVGMG25B3xQoN7DvokmJ14K

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION WILLIAM RINKER and MARIANNE RINKER, NO. 94 L 14 Plaintiffs, v. UNITED STATES MINERAL ' PRODUCTS COMPANY, INC, et al., Defendants. : : : : : : / RESPONSE OF UNITED STATES MINERAL PRODUCTS COMPANY / TO PLAINTIFFS' INTERROGATORIES / United States Mineral Products Company's-^hereiriiafter "U.S. Mineral") responses to interrogatories incorporates the following Preamble. PREAMBLE This Defendant has attempted to answer these interrogatories as they relate to this litigation to the best of its knowledge. This information has been compiled from several sources and represents the best compilation of facts presently available. Since this Defendant manufactured and sold asbestos-containing OPT/DPT/142500.1 CAFCO products from 1954-1972 only, unless otherwise stated in a specific answer to an Interrogatory, the answers to these interrogatories shall be limited to those products and that period of time. 1. State the name, address and job title of each person who has supplied information used in answering these interrogatories. RESPONSE: These responses to interrogatories were prepared with the assistance of legal counsel. They are verified by: Paulette A. Kaminski, Assistant Corporate Secretary United States Mineral Products Company Furnace Street Stanhope, New Jersey 2. Please state whether or not this Defendant is a corporation. If so, please state your correct corporate name, the state of your incorporation, the address of your principal place of business and whether you have ever held a Certificate of Authority to do business in the State of Illinois. RESPONSE: United States Mineral Products Company is incorporated in the state of Delaware with its principal place of business in Stanhope, New Jersey. U.S. Mineral has never had a certificate of authority to do business in Illinois. DPT/DPT/142500.1 2- - 3. Has Defendant at any time engaged in the manufacture of products containing asbestos? If so, indicate the subsidiary or division responsible for said manufacture. RESPONSE; United States Mineral Products Company formerly known as United States Mineral Wool Company manufactured asbestos-containing CAFCO products between 1954-1972 at its Stanhope, New Jersey facility. In 1954, at the inception of the manufacture of asbestos-containing CAFCO products, the Defendant's legal name was United States Mineral Wool Company. In that year, a wholly owned subsidiary, Columbia Acoustics and Fireproofing Company, was formed by United States Mineral Wool Company to market these products under the tradename of CAFCO, and to license contractors to apply those products. On December 12, 1964, Defendant's legal name was changed to United States Mineral Products Company. Along with the legal name change, Columbia Acoustics and Fireproofing Company was liquidated, and its responsibilities were performed by the CAFCO division of U.S. Mineral. The CAFCO division of U.S. Mineral marketed asbestos-containing CAFCO products from 1964- DPT/DPT/142500.1 3- - 1972, after which time, U.S. Mineral ceased all manufacture and sales of asbestos-containing CAFCO products. 4. Has Defendant at any time engaged in the marketing and sale of products containing asbestos? If so, indicate the subsidiary or division responsible for said marketing or sale. RESPONSE: See this Defendant's response to Interrogatory No. 3. 5. Interrogatory No. 3 or No. 4 is in the affirmative, please state as to each affirmative answer the following: (a) The trade or brand name of each such product manufactured and/or marketed; RESPONSE: CAFCO. See Exhibit A for a list of products (b) The dates each were placed on the market; (c) The dates each were withdrawn from the market, if ever; RESPONSE: See this Defendant's response to Interrogatory No. 3. (d) A description of the physical/chemical composition of each, including the type of asbestos contained in each such product; RESPONSE: U.S. Mineral's asbestos-containing CAFCO products DPT/DPT/142500.1 4- - chrysotile asbestos. These products were principally composed of mineral wool, together with non-asbestos proprietary binders. See attachment A which is incorporated herein by reference. (e) A description of the physical appearance of each such product; RESPONSE: This Defendant's asbestos-containing CAFCO products were best described as a bulk, loose, fibrous material. (f) A detailed description of the intended uses of each such product; RESPONSE: Objection. This interrogatory is overbroad and nonspecific as to the term "detailed description". Without waiving this objection, with the exception of COMINCO and Patching Fiber, this Defendant's products were all designed for spray application. COMINCO was mixed by hand in a pail and troweled or hand-applied. Spray application of all products, except U.S. Mineral's Mark II and WEATHER-SHIELD coating products, involved use of a spray machine consisting of a hopper device into which several bags of dry fiber were placed. The machine then meters and pneumatically conveys dry fiber through a hose into a spray nozzle. At this point, an DPT/DPT/142500.1 5- - atomized water spray is introduced for the first time as the spray is directed to the surface to be covered. U.S. Mineral's Mark II and WEATHER-SHIELD coating products involved the use of a spray machine consisting of a hopper device into which bags of dry fiber were placed and mixed with water. The machine then pumped the material to a spray nozzle where it was applied. There is no cutting or sawing or of this Defendant's products. (g) The name of the manufacturer of each such product; RESPONSE: See this Defendant's response to Interrogatory No. 3. 6. If a product listed in response to Interrogatory No. 5 above was discontinued, state why such manufacture, sale or distribution ceased. RESPONSE: U.S. Mineral ceased manufacturing asbestos-containing products in 1972. The reason for this was there was a decline in demand for asbestos-containing products which was caused at least in part by increased concerns about the exposure of workers to asbestos while handling or using asbestos-containing products. OPT/OPT/142500.1 6- - 7. For each product listed in response to Interrogatory No. 5, state whether said product was ever sold or distributed in the State if Illinois and, if so, state which years each product was sold in the State of Illinois. RESPONSE; Objection. This interrogatory is overbroad, unduly burdensome, vague and nonspecific as to plaintiffs jobsite(s). Further, this interrogatory attempts to shift the burden of proof from the plaintiff to this Defendant. Without waiving this objection, this Defendant sold its asbestos-containing CAFCO spray products to licensed CAFCO applicators only. The product would be shipped to the licensed applicator, typically at the location where it was to be installed. 8. For each product listed in response to Interrogatory No. 5, state the names and addresses, per year, of customers purchasing same in the State of Illinois. RESPONSE; Objection. This interrogatory is overbroad, unduly burdensome, vague and nonspecific as to plaintiffs jobsite(s). Further, this interrogatory attempts to shift the burden of proof from the plaintiff to this Defendant. Without waiving this objection, this DPT/DPT/142500.1 7- - Defendant sold its asbestos-containing CAFCO spray products to licensed CAFCO applicators only. The product would be shipped to the licensed applicator, typically at the location where it was to be installed. Listed below are U.S. Mineral's licensed applicators who received shipments of asbestos-containing CAFCO products in the State of Illinois. Allied Construction Service Asbestos & Magnesia Materials Behlen Manufacturing Co. Commonwealth Edison Company Mid-States Lathing & Plastering Wisconsin Acoustics & Fireproofing 9. For each product listed in response to Interrogatory No. 5, state the names and addresses of any distributors who sold said products on this Defendant's behalf, the years during which they sold said products, and whether they sold said products in the State of Illinois. RESPONSE: Objection. This Defendant did not sell its asbestos- containing CAFCO products to distributors. See this Defendant's response to Interrogatory No. 8. 10. State whether any of this Defendant's distributors and/or customers were provided with any instructions with regard to DPT/DPT/142500.1 8- - the use of this Defendant's asbestos-containing products. If so, please state: (a) By whom and when these instructions were made; (b) Whether the instructions were written or oral. If written, please attach a copy; if oral, please state the content thereof. RESPONSE: For the entire period of time during which asbestos- containing CAFCO products were manufactured, the Sales and Application Manual supplied to all contractors licensed to spray-apply U.S. Mineral's products, contained rules, advice, warnings, directives, instructions and recommendations as to the proper handling and application of the products. This manual included a directive that crew members in proximity to the spray area must be equipped with respiratory protection approved by the United States Department of the Interior, Bureau of Mines for pneumoconiosis- producing dusts such as asbestos. U.S. Mineral regularly updated the Sales and Application Manual by sending Bulletins to its licensed applicators. Additionally, beginning in 1962, the following warning was printed prominently on all bags of asbestos- DPT/DPT/142500.1 9- - containing CAFCO products: CAUTION This product contains asbestos. Inhalation of asbestos dust over long periods may be harmful. If employees are exposed to dust during use in application, those employees should be equipped with adequate personal protective devices. This warning was placed on the package beneath the application instructions, so that applicators and those handling the product, traditionally plasterers, would see the caution statement. In 1968, licensed applicators were furnished with copies of the T-l-68 Sprayed Mineral Fiber Manufacturers Bulletin, which contained instructions on the application of asbestos-containing sprayed mineral fiber products. Thereafter, U.S. Mineral provided to its licensed applicators copies of the SMFMA Recommended Code of Practices for Application of Sprayed Fireproofing Material. This document was given the widest possible distribution, which included, distribution to trade unions, general contractors, construction organizations and certain state and local agencies. DPT/DPT/142500.1 -10- 11. Does this Defendant claim that any patent would cover any products listed above in response to Interrogatory No. 5? If so, for each such product, please state: (a) The number of each patent; (b) The date same was issued; pending. (c) The number of each patent application that is RESPONSE: No. 12. Have any of the products listed above in response to Interrogatory No. 5 been altered in chemical composition since first being marketed? If so, please state: (a) The trade name of each such product; (b) The date each such product was altered; (c) The nature of the alteration, giving old and new compositions; (d) The reason for said alteration. RESPONSE: From the outset of its entry into the manufacture of asbestos-containing products, U.S. Mineral on occasion would alter or modify its products in an effort to improve its products. In the early 1960s, U.S. Mineral sought to manufacture a whiter and harder acoustical DPT/DPT/142500.1 -11- product, and the eventual result was the development of SOUND-SHIELD 85, a non-asbestos acoustical plaster product. In 1964, U.S. Mineral introduced CAFCO BLAZESHIELD Type D, which contained lesser amounts of asbestos, with an increase in the binder content and density. Throughout the 1960s, U.S. Mineral reduced the amount of asbestos contained in Cominco, to the point that in 1967, it contained less than 10% chrysotile asbestos. Beginning in late 1968, U.S. Mineral began to work on removing the asbestos from its asbestos-containing CAFCO products. The result was that in late 1969 and continuing into 1970, U.S. Mineral offered to the market asbestos free versions of all its CAFCO products. 13. What is the name, address and job title of each individual who participated in the design and preparation of manufacturing specifications for each such product? RESPONSE: Frank Stumpf, former Vice President of Research and James P. Verhalen, current Chairman were involved with the formulation of this Defendant's asbestos-containing DPT/DPT/142500.1 -12- CAFCO products. 14. Do any written memoranda, specifications, blueprints or other written materials of any kind or character relating to the design and preparation of said products now exist? If so, please state: (a) List each such written material of document; (b) Who presently has possession of each such document; (c) Where is it located? RESPONSE: All non-privileged responsive documents in the possession of U.S. Mineral will be made available for review at a mutually convenient time at its offices in Stanhope, New Jersey. 15. Prior to releasing the products listed in response to Interrogatory No. 5 to the public for sale, were any tests conducted by this Defendant, your agents or employees on same to determine potential health hazards involved in the use of materials contained therein? If so, please state: (a) The name, address and job classification of each individual who conducted such tests; (b) The results of such tests DPT/DPT/142500.1 -13- RESPONSE: U.S. Mineral states that when it entered into the business of the manufacture and sale of asbestoscontaining CAFCO spray products, it knew of the disease asbestosis which it understood might result in asbestos mining and textile work, where there were exposures to high concentrations of asbestos, in unventilated areas over a lifetime of work without respiratory protection. As a result, for the entire period of time during which asbestos-containing CAFCO products were manufactured, the Sales and Application Manual supplied to all contractors licensed to spray-apply U.S. Mineral's products, contained rules, advice, warnings, directives, instructions and recommendations as to the proper handling and application of the products. This manual included a directive that crew members in proximity to the spray area must be equipped with respiratory protection approved by the United States Department of the Interior, Bureau of Mines for pneumoconiosisproducing dusts such as asbestos. 16. Do any documents of any kind or character, prepared by this Defendant, your agents, employees or anyone outside your DPT/DPT/142500.1 -14- company, exist relating to the testing of said products? If so, please state: (a) A list of such documents; (b) Who presently has possession of such documents, and where they are located. RESPONSE: All non-privileged responsive documents in the possession of U.S. Mineral will be made available for review at a mutually convenient time at its offices in Stanhope, New Jersey. 17. Has this Defendant at any time published and/or distributed any brochures, pamphlets or other written materials of any kind or character that contain any warnings concerning the possibility of injury resulting from the use of the products listed in response to Interrogatory No. 5? If so, please state: (a) The wording of each such warning; (b) A description of each such printed material; (c) The method used to distribute the warning to persons who are likely to use the products; (d) The dates each such warnings were issued; (e) The name, address and job classification of each person who presently has possession of the above described DPT/DPT/142500.1 -15- documents. RESPONSE: See this Defendant's response to Interrogatory No. 10. 18. Please list each individual who has acted in a medical advisory capacity to this Defendant's company for the past thirtyfive (35) years and the current address and job title of each such individual, whether the person was a full-time employee or merely consulted from time to time. RESPONSE; U.S. Mineral never hired a consultant or physician with regard to the possible health effects of asbestoscontaining products. However, U.S. Mineral through its membership in SMFMA, regularly consulted with Dr. Irving Selikoff and on occasion other members of the Mount Sinai School of Medicine concerning the possible hazards associated with asbestos-containing products. 19. Has any written material of any kind or character been prepared by this Defendant, or its agent, indicating how Defendant's products should be used and maintained? If so, please state the following: (a) The name, address and job classification of each person who prepared same. DPT/DPT/142500.1 -16- (b) The name, address and job classification of each person who presently has possession of same; (c) The dates and manner in which said material was distributed to purchasers of Defendant's products. RESPONSE; See this Defendant's response to Interrogatory No. 10. 20. Does this Defendant have policies of insurance that might cover the claim that has been made by plaintiff herein? If so, please list the name of each insurance carrier who may have coverage, the amount of such coverage, and the dates of each such policy. RESPONSE: Since at least the mid-1950's, USM has been insured for products liability and general liability with primary and excess coverage. These policies have been written by many companies in varying amounts at different times. Some or all of such policies may apply to claims asserted herein. See Exhibit B attached. 21. On what date did this Defendant first become aware that inhalation of asbestos fibers by human beings could cause adverse health consequences. RESPONSE: U.S. Mineral states that it cannot identify exactly when it first learned that there was a possible harm DPT/DPT/142500.1 -17- associated with the exposure to asbestos during use. However, when U.S. Mineral began manufacturing asbestoscontaining CAFCO spray products in 1954, it knew of the disease asbestosis, which it understood to be caused by long term exposure to high concentrations of asbestos dust, such as the conditions found in asbestos mines, mills and asbestos textile factories. In the late 1950s, U.S. Mineral learned of the American Conference of Governmental Industrial Hygienist's Threshold Limit Value for asbestos dust. In the mid 1960s, U.S. Mineral as a member of the SMFMA began to meet with Dr. Irving Selikoff of the Mount Sinai School of Medicine to discuss his work on asbestos and the potential health hazard. These meetings with Dr. Selikoff and the Mount Sinai School of Medicine continued into the early 1970s, during which time numerous documents and information was exchanged by the parties. U.S. Mineral states that it is impossible to identify all documents and information obtained during the years it manufactured asbestoscontaining CAFCO products. However, it will make its records available for review at a mutually convenient time at its offices in Stanhope, New Jersey. DPT/DPT/142500.1 -18- 22. Please describe in detail the type of packages in which this Defendant has sold asbestos material, listing the dates each type of package was used, a physical description thereof, and a description of any printed material or trademark that appeared thereon. RESPONSE; U.S. Mineral's asbestos-containing CAFCO products were packaged in 50-pound, multi-wall kraft paper bags. A CAFCO BLAZE-SHIELD Type D bag can be viewed at this Defendant's headquarters in Stanhope, New Jersey per mutually convenient scheduled appointment. 23. Has this Defendant conducted, or had conducted for it, any investigation, study, test, review or analysis (hereinafter referred to as "study"), concerning asbestos-related diseases, asbestosis, pulmonary diseases and/or the safety aspect concerning use of Defendant's product? If so, identify each study by: (a) The date each study was conducted; (b) The person authorizing the study; (c) The person in charge of the study; (d) The people participating in the study; (e) The title and subject of the study; (f) The results of each study; DPT/DPT/142500.1 -19- (g) If statistical analysis were made, state the results and describe the date and assumptions upon which they were based; (h) If in writing, either attach a copy of the study or identify it by date, title, identification number, present location and custodian. RESPONSE: In 1966, the Industrial Commission of Ohio, Division of Safety and Hygiene, tested U.S. Mineral's asbestoscontaining product during application for compliance with the threshold limit value ("TLV") for asbestos as set by the American Conference of Governmental Industrial Hygienists. ("ACGIH") In addition, in 1967, the Florida State Board of Health tested U.S. Mineral's asbestos-containing product for compliance with the TLV. In both instances, the reports concluded that U.S. Mineral's product did not create a health hazard due to asbestos. 24. Did this Defendant ever recommend to purchasers or users of the asbestos products listed in your answer to Interrogatory No. 5 that respirators, protective masks and/or clothing be worn with the product? If so, state: DPT/DPT/1425(30.1 -20- (a) The date or dates when such recommendation was made to each purchaser; (b) to each user; The date or dates when such recommendation was made (c) Who made the recommendation (d) Who received the recommendation; (e) If recommendation; oral, the manner and substance of the (f) If written, identify the document by title, date, file designation and author of each such recommendation, and the location and present custodian of each such recommendation. RESPONSE: U.S. Mineral states generally asbestos workers were not licensed applicators of U.S. Mineral's asbestos- containing CAFCO products. However, from the date of U.S. Mineral's entry into the manufacture and sale of asbestos-containing spray applied products, it recommended in its Sales and Application Manual supplied to all contractors licensed to spray-apply U.S. Mineral's products, contained rules, advice, warnings, directives, instructions, and recommendations as to the proper handling and application of the products. This manual included a directive that crew members in DPT/DPT/142500.1 -21- proximity to the spray area must be equipped with respiratory protection approved by the United States Department of the Interior, Bureau of Mines for pneumoconiosis-producing dusts such as asbestos. U.S. Mineral regularly updated the Sales and Application Manual by sending Bulletins to its licensed applicators. 25. State the full name and address of all Illinois distributors of asbestos products made by United States Mineral Products Company during the following years: (a) 1959 through 1964; RESPONSE: This Defendant did not sell its asbestos-containing CAFCO products to distributors. See this Defendant's response to Interrogatory No. 8. (b) 1988 through 1990. RESPONSE: Not applicable. This Defendant ceased the manufacture of asbestos-containing CAFCO products on 1972. 26. State the full name and address of all Illinois distributors of asbestos products made by Keene Corporation during the following years: DPT/DPT/K2500.1 -22- (a) 1959 through 1964; (b) 1988 through 1990. RESPONSE: This interrogatory is not directed to this Defendant. 27. State the full name and address of all Illinois distributors of asbestos products made by Keene Building Products during the following years: (a) 1959 through 1964; (b) 1988 through 1990. RESPONSE; This interrogatory is not directed towards this Defendant. 28. State the full name and address of all Illinois distributors of asbestos products made by Baldwin Ehret Hill, Inc. during the following years: (a) 1959 through 1964; (b) 1988 through 1990. RESPONSE; This interrogatory is not directed towards this Defendant. 29. Briefly describe the relationship between Isolatek International and United States Mineral Products Company at DPT/DPT/142500.1 -23- present. RESPONSE: United States Mineral Products Company does business as Isolatek International. 30. State the name and address of the company that made CAFCO Heat Shield and Cafco Blaze Shield during the following years: (a) 1959 through 1964; RESPONSE: See this Defendant's response to Interrogatory No. 3. (b) 1988 through 1990. RESPONSE: Not applicable. This Defendant ceased the manufacture of asbestos-containing CAFCO products in 1972. 31. State the name and address of Illinois distributors of CAFCO Heat Shield and Cafco Blaze Shield during the following years; (a) 1959 through 1964; RESPONSE: This Defendant did not sell its asbestos-containing CAFCO products to distributors. See this Defendant's response to Interrogatory No. 8. (b) 1988 through 1990. RESPONSE: Not applicable. This Defendant ceased the manufacture DPT/DPT/142500.1 -24- of asbestos-containing CAFCO products in 1972. 32. Did Cafco Heat Shield and Cafco Blaze Shield contain asbestos when these products were made during the following years: (a) 1959 through 1964; RESPONSE: See response to Interrogatory 5. (b) 1988 through 1990. RESPONSE: Not applicable. This Defendant ceased the manufacture of asbestos-containing CAFCO products in 1972. 33. Identify all asbestos products sold by answering Defendant to Airtite Company in Chicago in 1962 and 1963. RESPONSE: This Defendant sold its asbestos-containing CAFCO products to licensed CAFCO applicators only. The product would be shipped to the licensed applicator, typically at the location where it was to be installed. U.S. Mineral has conducted a search of its sales records with regard to Airtite Company in Chicago, Illinois. This Defendant's sales records do not indicate sales or shipment of its asbestos-containing CAFCO products to this site. DPT/DPT/142500.1 -25- 34. Identify all asbestos products sold by answering Defendant to Asbestos Magnesium Materials Company in Chicago from 1959 through 1964. RESPONSE: Objection. This interrogatory is overly broad, unduly burdensome, vague and nonspecific as to plaintiff's jobsite. Without waiving this objection, this Defendant states that Asbestos and Magnesia Materials was a licensed applicator. If plaintiff will provide information regarding plaintiff's jobsite, this Defendant will attempt to supplement this response. 35. Identify all asbestos products sold by Baldwin Ehret Hill, Inc., to Airtite Company in Chicago in 1962 and 1963. RESPONSE: This interrogatory is not directed to this Defendant. United States Mineral Products Conpany OPT/DPT/142500.1 -26- EXHIBIT "A" 1. CAFCO Spray (1954-58) 2. CAFCO BLAZE-SHIELD (1958-71) 3. CAFCO BLAZE-SHIELD Type D (1964-72) 4. CAFCO BLAZE-SHIELD Patching Fiber (1954-71) 5. CAFCO BLAZE-SHIELD Patching Fiber Type D (1965-71) 6. CAFCO Spray Type 1 (1954-58) 7. CAFCO SOUND-SHIELD 8. CAFCO BLAZE-SHIELD Type H (1969-71) 9. CAFCO HEAT-SHIELD (1958-71) 10. CAFCO POWER-SHIELD (1964-71) 11. J Spray (1964-67) 12. COMINCO sometimes called Ace-Tite Cement or All Purpose) (pre-1958-71) 13. COMINCO Monoply (1963-71) 14. CAFCO HEAT-SHIELD Type 2 15. CAFCO BLAZE-SHIELD Type M 16. Mark II (1967-72) 17. CAFCO WEATHER-SHIELD ( 1970-72) Fireproofing, insulation and acoustical treatment of buildings Fireproofing of structural steel and steel floors Fireproofing of structural steel and steel floors Same as CAFCO BLAZE-SHIELD but fiber modified so it can be mixed with water and hand applied. Same as CAFCO BLAZE-SHIELD Type D but modified so it can be mixed with water and hand applied. Fireproofing, insulation and acoustical treatment of buildings Acoustical absorption Same as CAFCO BLAZE-SHIELD Type D; generally used for exposed acoustical areas Building Insulation High temperature power and process insulation High temperature power and process insulation Insulating cement used for elbow fittings Insulating cement used for elbow fittings Modification of CAFCO HEAT-SHIELD Modification of CAFCO BLAZE-SHIELD; organic binders added Coating for application over CAFCO products in areas of extreme velocity and/or abrasion Coating for application over CAFCO products to protect against unusual exposure to the elements. EXHIBIT B S/8/78-5/8/79 Chufcto & Sen (79) 7922-04-41 5/8/79-8/10/80 5/8/79-8/10/80 Puritan Ins. Co. UL 67 21 65 Nat'1.Union Fire Ins.Co. 1225415 of Pittsburgh, PA. 8/10/80-11/11/81 8/10/80-11/11/81 Midland Ins. Co. Nat:11.Union Fire Ins.Co. of Pittsburgh, PA. 704 247 991-0408 11/11/81-11/11/82 11/11/81-11/11/82 11/11/81-11/11/82 Integity Ins. Co. Ambassador Ins. Co. Firemens Fund ISX 106790 ELP 001136 XLX 137-33-07 11/11/82-11/11/83 11/11/82-11/11/83 8/8/83-11/2S/84 8/8/83-11/25/84 Integrity Ins. Co. Firemens Fund TVin City Fire North River.Ins. Co. ISX 110735 XLX 148-57-13 TXS 103131 522-018613-8 11/11/83-11/25/84 Integrity Ins. Co. 11/11/83-11/25/84 Firemens Fund ISX 113159 XLX 1618314 Re: William Rinker and Marianne Rinker va. United States Mineral Products Company, et al. Case No. 94 L 14 VERIFICATION STATE OF NEW JERSEY ) ) ss: COUNTY OF SUSSEX ) PAULETTE A. KAMINSKI, being duly sworn, says: I am the Assistant Corporate Secretary of UNITED STATES MINERAL PRODUCTS COMPANY, a Delaware Corporation and a party in the within action; I have read the foregoing RESPONSE OF DEFENDANT, UNITED STATES MINERAL PRODUCTS COMPANY TO PLAINTIFFS' INTERROGATORIES and know the contents thereof; that said answers were prepared with the assistance and advice of counsel and the assistance of employees and representatives of the corporation, upon which I have relied; that the answers set forth herein are subject to inadvertent or undiscovered errors, are based on and therefore necessarily limited by the records and information still in existence, presently recollected and thus far discovered in the course of the preparation of these answers; that consequently, this Defendant reserves the right to make any changes in the answers if it appears at any time that omissions or errors have been made therein or that more accurate information is available; and that subject to the limitations set forth herein, the said answers are true to the best of my knowledge, information and belief. Sworn to and subscribed before me this / 0 day Notary Public PATRICIA M. DOOLEY NOTARY PUBLIC OF NEW JERSEY My Commission Expires July 28,19S3 Paulette A. Kaminski Assistant Corporate Secretary for U.S. Mineral Products Company